Recognition of a Ruler is distinct from private property rights and covenant-based succession claims may be non-justiciable.

Recognition of a successor Ruler under Article 366(22) was treated as a constitutional act of political power, not an adjudication of private property rights, so the challenge under Articles 19(1)(f) and 31 failed. The provision was held to confer power on the President to recognise and, where applicable, withdraw recognition. A covenant-based succession dispute was treated as non-justiciable under Article 363, because the covenant did not itself establish an enforceable law or custom. Recognition of rulership did not automatically vest rights in the former Ruler's private properties, which remained governed by ordinary succession law.

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Issues: (i) Whether the President's recognition of a successor Ruler under Article 366(22) of the Constitution infringed the petitioner's fundamental right to property under Articles 19(1)(f) and 31. (ii) Whether Article 366(22) merely defined a Ruler or also conferred power on the President to recognise a Ruler. (iii) Whether the dispute as to succession to Rulership and the covenant-based claim was barred from judicial examination by Article 363. (iv) Whether recognition of Rulership automatically carried with it rights to the private properties of the former Ruler.

Issue (i): Whether the President's recognition of a successor Ruler under Article 366(22) of the Constitution infringed the petitioner's fundamental right to property under Articles 19(1)(f) and 31.

Analysis: Recognition of a Ruler was held to be an act of political power relating to succession to the gaddi and not an act transferring or adjudicating rights in private property. The notification of recognition did not confer title to the late Ruler's private properties. A claim under Articles 19(1)(f) and 31 required proof that the petitioner owned or possessed a property right affected by the impugned act, which was absent here. Privy purse was also held not to be private property.

Conclusion: The challenge based on infringement of the fundamental right to property failed.

Issue (ii): Whether Article 366(22) merely defined a Ruler or also conferred power on the President to recognise a Ruler.

Analysis: The expression "is recognised by the President" was treated as carrying substantive content and not as a bare definition. The words "for the time being" indicated authority not only to recognise but also to withdraw recognition. The Constitution was read as embedding the power in the provision itself.

Conclusion: Article 366(22) was held to confer power on the President to recognise a Ruler.

Issue (iii): Whether the dispute as to succession to Rulership and the covenant-based claim was barred from judicial examination by Article 363.

Analysis: The claim to recognition of Rulership was treated as one of personal status and not as a purely hereditary or treaty-based claim enforceable in court. The covenant preserved succession according to law and custom, but did not itself establish such law or custom. Disputes founded on the covenant were treated as non-justiciable in view of Article 363.

Conclusion: The covenant-based challenge to recognition was held to be barred from judicial interference.

Issue (iv): Whether recognition of Rulership automatically carried with it rights to the private properties of the former Ruler.

Analysis: A clear distinction was drawn between recognition of Rulership and succession to private property. Private property rights were held to be governed by personal law of succession and not by the constitutional act of recognition. The recognition order did not operate upon the private estate of the deceased Ruler.

Conclusion: Recognition of Rulership did not automatically vest rights in the private properties of the former Ruler.

Final Conclusion: The constitutional challenge to the recognition of the successor Ruler and the associated claim to the late Ruler's private properties was rejected, and the proceedings were terminated in favour of the respondents.

Ratio Decidendi: Recognition of a Ruler under Article 366(22) is a constitutional act of political power distinct from succession to private property, and disputes founded on covenantal succession claims are not justiciable where barred by Article 363.

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