The Supreme Court has reaffirmed that Article 131's original jurisdiction is strictly confined to disputes between the Union and States or between States inter se. A statutory authority — however powerful — cannot invoke this jurisdiction, as it is neither the Union of India nor a State. The ruling draws a firm boundary: entities created by statute must seek remedies elsewhere, such as under Article 226 or ordinary civil jurisdiction, and cannot dress up their disputes as constitutional inter-governmental conflicts.

Article 131 of the Constitution vests the Supreme Court with exclusive original jurisdiction over disputes involving questions of law or fact on which the existence or extent of a legal right depends, but only between the Union and one or more States, or between two or more States. The framers designed it as a specialised inter-governmental forum — a neutral arbiter for sovereign entities — not a general court of first instance for statutory bodies.

The critical doctrinal distinction is between constitutional persons (the Union, States) and statutory persons (corporations, boards, commissions created by legislation). A statutory body derives its existence from an Act of Parliament or a State Legislature; it is not itself the Union or a State even if it is wholly owned or controlled by one. Courts have consistently held that the real party in interest must be the governmental unit itself, not a creature of statute acting in its own name.

Precedents such as State of Bihar v. Union of India (1970) clarified that the dispute must be one in which the governmental units themselves are parties asserting their constitutional rights. Later, in Union of India v. State of Rajasthan (1984), the Court reinforced that commercial or service disputes routed through statutory bodies cannot be converted into Article 131 suits.

The practical consequence: statutory bodies like PSUs, regulatory authorities, or autonomous boards that have grievances against a State or the Centre must approach the High Court under Article 226 or invoke ordinary civil court jurisdiction. This ruling tightens that boundary and prevents forum-shopping through the Article 131 route.