On January 22, 2015, the Supreme Court of India, in its decision on an appeal filed by the Board of Cricket Control in India (BCCI) against an order given by the High Court of Bombay, said while BCCI did not come under of ambit of ‘State’ under Article 12 of the Constitution, it did fall within the purview of Article 226. The appeal arose out of a Public Interest Litigation (PIL) filed by the Cricket Association of Bihar (CAB) before the High Court of Bombay. While considering the Public Interest Litigation on July 30, 2013, the Court had ruled out the possibility of bringing the BCCI within the purview of Article 12 in a PIL filed under Article 32. The decision given by the Supreme Court was viewed by legal circles as a laudable one since it recognized the public functions performed by the Board. However, it also attracted criticism for having narrowed down the scope of ‘State’ under Article 12 of the Constitution. A body brought under the purview of ‘State’ was bound to comply with the fundamental rights given under Part III of the Constitution of India..

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