The Supreme Court ruled that the National Book Trust is "State" under Article 12 despite being registered as a society, while clarifying that its employees do not automatically become civil servants.

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• A bench of Justices Prashant Kumar Mishra and Augustine George Masih delivered the judgment on November 6, 2026, in The Chairman, National Book Trust, India v. A.R. Abdul Gaffar (2026 INSC 1202).
• The only question was whether the National Book Trust (NBT) is "State" within the meaning of Article 12 of the Constitution.
• The Court dismissed NBT's appeal, Civil Appeal No. 14369 of 2015, and upheld the Delhi High Court Full Bench's finding that NBT is an "other authority".
• It held that the government exercises deep and pervasive control over NBT's constitution, administration and finances.
• The Court said registration as a society or trust does not take a body outside Article 12 where governmental control is pervasive.
• Article 12 defines "State" for the purpose of enforcing fundamental rights, and NBT is therefore subject to the constitutional obligations attached to it.
• The ruling clarifies that "State" status does not make NBT's employees civil servants.
• The Delhi High Court had earlier held in 2012 that NBT was a State, reversing a single judge who followed precedent on the NCERT.
• That earlier precedent was Chander Mohan Khanna v. NCERT (1992), in which the Supreme Court had held the NCERT was not a "State".
• Senior advocate Sanjay Jain assisted the Court as amicus curiae, and the bench recorded its appreciation of his assistance.
• Legal commentary notes the ruling is relevant for registered societies, since society registration alone does not rule out Article 12 status.

Tags: Article12, NationalBookTrust, SupremeCourt