Money Bill classification upheld for LIC-related amendments, with Speaker certification treated as final absent a direct challenge.

Amendments to the Life Insurance Corporation Act introduced through Sections 128 to 146 of the Finance Act, 2021 were upheld as a valid Money Bill measure under Article 110 because the scheme was directed to the proposed LIC IPO and the receipt of money into the Consolidated Fund of India. Provisions on capital structure, governance, share issuance, shareholder reservation, fund management and audit were treated as ancillary or incidental to that fiscal object. The challenge also failed because the Speaker's certificate under Article 110(3) was not specifically assailed, and that certification was treated as final within the narrow scope of judicial review.

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Issues: (i) Whether the amendments introduced by Sections 128 to 146 of the Finance Act, 2021, including the changes to the Life Insurance Corporation Act, 1956, could validly be enacted as a Money Bill under Article 110 of the Constitution of India. (ii) Whether the challenge could succeed despite no challenge being laid to the Speaker's certificate under Article 110(3) of the Constitution of India.

Issue (i): Whether the amendments introduced by Sections 128 to 146 of the Finance Act, 2021, including the changes to the Life Insurance Corporation Act, 1956, could validly be enacted as a Money Bill under Article 110 of the Constitution of India.

Analysis: The amendment scheme was held to be aimed at enabling the proposed LIC IPO and the consequent receipt of money into the Consolidated Fund of India. The changes to capital structure, corporate governance, share issuance, shareholder reservation, fund management, audit and related matters were treated as either directly connected with, or incidental to, that core fiscal object. The Court read Article 110(1)(g) with the word "only" in Article 110(1) and held that incidental provisions do not take a Bill outside the Money Bill category when the substantial subject falls within Article 110(1)(c).

Conclusion: The amendments were upheld as falling within Article 110 of the Constitution of India and the challenge failed on merits.

Issue (ii): Whether the challenge could succeed despite no challenge being laid to the Speaker's certificate under Article 110(3) of the Constitution of India.

Analysis: The Speaker's certification that the Bill was a Money Bill was treated as final under Article 110(3), subject only to the limited scope of judicial review recognized in the authorities relied upon. Since the petitioner did not challenge the certificate itself, the Court held that the attack on the amendments could not be sustained in the face of the constitutional finality attached to that certification.

Conclusion: The absence of a challenge to the Speaker's certificate was fatal to the writ petition.

Final Conclusion: The writ petition disclosed no constitutional infirmity in the enactment of the impugned amendments and did not warrant interference with the legislative measure.

Ratio Decidendi: Where the substantive object of a Bill is to secure receipt of money into the Consolidated Fund of India, provisions that are ancillary or incidental to that object may be included within a Money Bill, and the Speaker's certification under Article 110(3) carries finality unless specifically and successfully challenged within the narrow scope of judicial review.

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