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Under Article 12, which of the following bodies has been authoritatively held by the Supreme Court NOT to fall within the meaning of 'State'?
Answer & Solution
Correct answer: A.
1. In **Zee Telefilms Ltd. v. Union of India, (2005) 4 SCC 649**, the Supreme Court applied the *Pradeep Kumar Biswas* tests and held that the **BCCI was not State** for Article 12 purposes because it was not financially, functionally or administratively dominated by Government; the Government's control was merely regulatory and not pervasive.
2. By contrast, **CSIR** was held to be State in *Pradeep Kumar Biswas v. IICB, (2002) 5 SCC 111*.
3. **International Airports Authority** was held to be State in *R.D. Shetty v. International Airports Authority, AIR 1979 SC 1628*.
4. LIC has long been treated as a State instrumentality. So the BCCI is the only correct answer.
_Source: ICSI CS Executive — Lesson 2, 'Definition of State', p. 30 ¶6._
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