Writ jurisdiction over private associations requires State character or public duty; mere regulatory supervision is not enough.

A private stock exchange association is amenable to writ jurisdiction only if it is a State instrumentality or otherwise discharges a public duty under Article 226. An association governed by its own rules and bye-laws, without statutory force, deep or pervasive State control, or financial aid, does not satisfy that test. Mere supervisory regulation by the authority, including power to supersede the board in an appropriate case, is not enough to convert the body into the State or make its internal disciplinary and membership decisions subject to writ review. Relief against such internal orders must therefore be sought before the appropriate forum.

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Issues: Whether the writ petition was maintainable against the stock exchange association under Article 226 of the Constitution of India.

Analysis: The governing test is whether the body sought to be proceeded against is a State, State agency or instrumentality, or otherwise discharges a public duty amenable to writ jurisdiction. A private association formed to regulate its members' exchange business, governed by its own rules and bye-laws without statutory force, and functioning independently of any deep or pervasive State control or financial aid, does not answer that description. The mere fact that the regulatory authority may supervise the association or supersede its board in an appropriate case does not by itself convert the association into a State or make its internal disciplinary orders subject to writ review. Relief relating to internal membership and disciplinary matters of such a body is therefore not enforceable under Article 226.

Conclusion: The writ petition was not maintainable against the association.

Final Conclusion: The challenge to the impugned disciplinary and appellate orders failed, and the petitioners were left to pursue any remedy before the appropriate forum.

Ratio Decidendi: A private body is amenable to writ jurisdiction only if it is a State instrumentality or is shown to discharge a statutory public duty; supervisory regulation by the State, without deep and pervasive control or public duty, is insufficient.

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