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Thalappalam Service Cooperative Bank v. State of Kerala

Thalappalam Service Cooperative Bank v. State of Kerala (Supreme Court of India, 2013-10-07) (2013) 16 SCC 82 is a ruling on the Right to Information Act, 2005 — Section 2(h). Cooperative societies are public authorities only if substantially financed by Government — not by mere statutory regulation. A cooperative society is not automatically a public authority under §2(h) merely because it is registered under a State Cooperative Societies Act.

Holding

Cooperative societies are public authorities only if substantially financed by Government — not by mere statutory regulation.

Ratio

A cooperative society is not automatically a public authority under §2(h) merely because it is registered under a State Cooperative Societies Act. The test is functional — substantial Government finance and control.

Section(s) applied

Practitioner takeaway

§2(h) functional test of public authority; substantial Government finance required.

Citation

Last reviewed: 23 April 2026.