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.

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. The test is functional — substantial Government finance and control.

• Section 2(h)

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

• Citation: (2013) 16 SCC 82
• Court: Supreme Court of India
• Date: 2013-10-07
• Outcome: allowed
• Reporter / Cause-list: (2013) 16 SCC 82

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Last reviewed: 23 April 2026.