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Issues Involved:
1. Legislative competence of the Delhi State Legislature to enact the Tibbia College Act, 1952. 2. Violation of fundamental rights under Articles 14, 19, and 31 of the Constitution. 3. Conflict between the Tibbia College Act, 1952 and the Societies Registration Act, 1860. 4. Allegation of mala fide intent behind the enactment of the Tibbia College Act, 1952. Issue-wise Detailed Analysis: 1. Legislative Competence of the Delhi State Legislature: The petitioners argued that the Delhi State Legislature lacked the competence to enact the Tibbia College Act, 1952, as the Board of Trustees, Ayurvedic and Unani Tibbia College, was a corporation with objects extending beyond the State of Delhi, falling under Entry 44 of List I (Union List). The respondents contended that the Board was not a corporation but an unincorporated society, falling under the latter part of Entry 32 of List II (State List). The Court concluded that the Board, registered under the Societies Registration Act, 1860, was not a corporation but an unincorporated society. The Societies Registration Act did not confer corporate status. The impugned legislation, therefore, fell under Entry 32 of List II, allowing the Delhi State Legislature to dissolve the old Board and create a new corporate body confined to the State of Delhi. 2. Violation of Fundamental Rights: The petitioners claimed that the Tibbia College Act, 1952, violated their fundamental rights under Articles 14, 19, and 31 of the Constitution. They argued that the Act was arbitrary, lacked reasonable classification, and resulted in the deprivation of property without compensation. The Court held that the petitioners failed to prove that other similarly situated institutions were treated differently. The Act did not violate Article 14 as the petitioners did not provide evidence of unequal treatment. Regarding Article 31, the Court found that the Act did not involve compulsory acquisition of property for a public purpose. The transfer of management did not fall under Article 31(2) and was not a deprivation of property under Article 31(1). The Act did not infringe the petitioners' rights under Article 19(1)(f) as the members had no beneficial interest in the property of the dissolved society. 3. Conflict with the Societies Registration Act, 1860: The petitioners argued that the Tibbia College Act, 1952, conflicted with the Societies Registration Act, 1860, a Central Act, and was therefore void under Section 22 of the Government of Part C States Act, 1951. The Court rejected this argument, stating that Section 22 did not apply as the Societies Registration Act, 1860, was not a law made by Parliament. The Delhi State Legislature had the competence to amend the Societies Registration Act, 1860, in respect of unincorporated societies or to make a law for a particular unincorporated society. The impugned legislation did not conflict with the Societies Registration Act, 1860. 4. Allegation of Mala Fide Intent: The petitioners alleged that the Delhi State Legislature acted mala fide in enacting the Tibbia College Act, 1952. The respondents provided evidence of gross mismanagement by the old Board, leading to the necessity of the legislation. The Court held that the doctrine of colorable legislation did not involve questions of bona fides or mala fides. The Delhi State Legislature had the competence to enact the legislation, and the motives behind it were irrelevant. The affidavits filed by the respondents provided sufficient material to justify the dissolution of the old Board and the transfer of management to a new Board. Conclusion: The Supreme Court dismissed the petition, holding that the Delhi State Legislature had the legislative competence to enact the Tibbia College Act, 1952. The Act did not violate the petitioners' fundamental rights under Articles 14, 19, and 31 of the Constitution. There was no conflict with the Societies Registration Act, 1860, and the allegation of mala fide intent was unfounded.
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