International Journal of Human Rights Law Review

International Open Access Double Blind Peer Reviewed, Referred Journal

ISSN No. : 2583-7095

Constitutional Accountability and the Limits of Gubernatorial Discretion: A Case Comment on State of Tamil Nadu v. Governor of Tamil Nadu & Anr. (2025 INSC 481)

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Shubhi Mishra (2026). Constitutional Accountability and the Limits of Gubernatorial Discretion: A Case Comment on State of Tamil Nadu v. Governor of Tamil Nadu & Anr. (2025 INSC 481). International Journal of Human Rights Law Review, 5(4). Retrieved from https://ijhrlr.in/journal/constitutional-accountability-and-the-limits-of-gubernatorial-discretion-a-case-comment-on-state-of-tamil-nadu-v-governor-of-tamil-nadu-anr-2025-insc-481/

Abstract

The Supreme Court's decision in State of Tamil Nadu v. Governor of Tamil Nadu & Anr. (2025 INSC 481) constitutes a landmark development in Indian constitutional jurisprudence concerning the powers of Governors under Articles 200 and 201 of the Constitution. The dispute emerged from prolonged delays by the Governor of Tamil Nadu in acting upon several Bills passed by the State Legislature, resulting in a constitutional impasse between the elected government and the Governor's office. The Court was required to determine whether Article 200 permits a Governor to indefinitely withhold assent to legislation and whether re-passed Bills may subsequently be reserved for the consideration of the President. Through a purposive interpretation of the constitutional framework, the Court held that Governors do not possess a "pocket veto" and are obligated to act within constitutionally prescribed limits and timelines. Invoking its powers under Article 142, the Court deemed ten Bills to have received assent, thereby resolving the constitutional deadlock. The judgment significantly clarifies the role of Governors within India's federal structure, reinforces legislative supremacy, and strengthens constitutional accountability by preventing the misuse of discretionary powers. This case comment examines the factual background, legal issues, arguments advanced by the parties, judicial reasoning, and the broader constitutional implications of the decision

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