Writ jurisdiction over private bodies requires a public duty and public law element; voluntary private employment disputes do not qualify.

Article 226 extends beyond bodies answerable under Article 12, but a writ of mandamus against a private body lies only where the impugned action is referable to a public duty, a positive public obligation, and a public law element. A voluntary non-governmental organisation without State funding, statutory compulsion, or pervasive governmental control was held not to satisfy that test. Its research, coordination and facilitation work, though publicly useful, was not treated as a sovereign or State-like function, and the challenged termination was characterised as a private employment matter. On those facts, writ jurisdiction was unavailable.

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Issues: Whether the respondent body was amenable to writ jurisdiction under Article 226 of the Constitution on the ground that it performed public duty, despite not being a State under Article 12.

Analysis: The relevant distinction is that Article 226 extends beyond authorities answerable under Article 12, but a writ of mandamus against a private body lies only where the body performs a public duty or discharges a positive public obligation. The governing test is the nature of the duty actually imposed and the presence of a public law element. Applying that principle, the body in question was found to be a voluntary, non-governmental organisation with no State funding, no statutory obligation to perform the impugned functions, and no pervasive governmental control. Its activities, though useful and public in impact, were held to be voluntary research, coordination and facilitation activities, not functions similar to those performed by the State in its sovereign capacity. The challenged termination of service was further treated as a private employment matter lacking a public law element.

Conclusion: The respondent was not amenable to writ jurisdiction under Article 226 on the pleaded facts, and the challenge to the termination could not be maintained in writ proceedings.

Ratio Decidendi: A private body is amenable to writ jurisdiction under Article 226 only when the impugned action is referable to a public duty or positive public obligation and involves a public law element; mere usefulness to the public, voluntary activity, or absence of State control does not suffice.

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