### Statutory Takeover Without Demonstrated Mismanagement or Just Compensation Is Manifestly Arbitrary and Unconstitutional

In 1924, Dr. Sachchidanand Sinha established the Smt. Radhika Sinha Institute and Sachchidanand Sinha Library in memory of his wife.

A formal Trust Deed was executed on March 10, 1926, providing that the eldest male family member would serve as Honorary Secretary and that property would revert to the family if the Trust failed.

In 1955, the Government of Bihar recognized it as a State Central Library while maintaining Trustee control.

After a failed acquisition attempt via ordinances in 1983, the State Legislature enacted the Srimati Radhika Sinha Institute and Sachchidanand Sinha Library (Requisition & Management) Act, 2015, which provided for the total takeover and vesting of the Institute and Library in the State.

The Appellant (great-grandson of the Settlor) challenged the Act’s validity.

The Patna High Court dismissed the writ petition, suo motu characterizing the entity as a "Public Trust".

The Court primarily applied the doctrine of "manifest arbitrariness" under Article 14 of the Constitution, as solidified in Shayara Bano v. Union of India, which permits the striking down of plenary legislation if it is capricious, irrational, or lacks an adequate determining principle.

It relied on E.P. Royappa v. State of Tamil Nadu to establish that equality is antithetical to arbitrariness.

The Court relied on Ajay Hasia v. Khalid Mujib to establish that equality is antithetical to arbitrariness.

Regarding property, the Court applied Article 300A, noting that while the State may deprive a person of property by law, such law must be fair, reasonable, and non-confiscatory.

Additionally, the Court referenced Section 3 of the Indian Trusts Act, 1882, regarding the definition of a trust as an obligation arising from reposed confidence.

The Court found that the High Court erred in unilaterally reclassifying the Trust as "Public" without evidence or pleading.

On the merits of the Act, the Court observed that the absolute vesting of property and dissolution of a century-old Trust under Sections 3 and 4(2) lacked a "rational or proportionate nexus" to the goal of "better management".

The Court's examination of original records revealed no prior communication or inquiry regarding mismanagement; in fact, the day-to-day administration was already supervised by a State-appointed Librarian, against whom no action was taken.

The Court reasoned that the State’s investment of ₹72 Crores did not justify a takeover, as such funding could have been achieved through less invasive "Grant-in-aid" or "regulatory oversight" mechanisms rather than total displacement.

Finally, Section 7 of the Act was deemed confiscatory because it limited compensation to a "nominal and illusory" maximum of one rupee without prescribed principles, thus failing the "just, fair, and reasonable" standard required for deprivation of property.

The Court declared the Srimati Radhika Sinha Institute and Sachchidanand Sinha Library (Requisition & Management) Act, 2015 unconstitutional and struck it down as manifestly arbitrary under Article 14 and confiscatory under Article 300A.

The Court ordered that the Trust’s management and administration be restored to its pre-enactment legal position, though the State remains permitted to provide financial or regulatory support in accordance with law.