Article 151 of the Costitution of India with Case law
Article 151 of the Constitution of India
Title: Audit Reports
Bare Text of Article 151:
(1) The reports of the Comptroller and Auditor-General of India relating to the accounts of the Union shall be submitted to the President, who shall cause them to be laid before each House of Parliament.
(2) The reports of the Comptroller and Auditor-General of India relating to the accounts of a State shall be submitted to the Governor of the State, who shall cause them to be laid before the Legislature of the State.
Explanation:
Article 151 deals with the submission of audit reports by the Comptroller and Auditor-General (CAG) of India. It ensures transparency and accountability in the financial administration of the Union and the States.
Union Reports → Submitted to President → Presented to Parliament
State Reports → Submitted to Governor → Presented to State Legislature
The CAG audits the expenditure of public money to ensure it is done according to law and without irregularities.
Significance:
Empowers the CAG to function as a watchdog of public finance.
Ensures that public money is spent properly.
Lays foundation for legislative oversight on executive expenditure.
Reports can lead to Public Accounts Committee (PAC) inquiries.
Related Case Laws on Article 151 / CAG Powers:
1. A.R. Antulay v. R.S. Nayak, AIR 1988 SC 1531
Relevance: The Supreme Court upheld the independence of constitutional authorities like the CAG, reinforcing that their reports must be respected as they serve the public interest.
2. Common Cause v. Union of India, (1996) 6 SCC 530
Context: The CAG had submitted reports related to misuse of government resources (e.g., petrol pumps).
Held: The Supreme Court took cognizance of the findings and directed the government to act on the CAG’s observations, establishing its moral and legal significance.
3. Subramanian Swamy v. CBI, (2014) 8 SCC 682
Context: Relating to the 2G spectrum case, the CAG report revealed irregularities.
Held: The Supreme Court used the CAG findings as a basis for judicial scrutiny, reinforcing the credibility and evidentiary value of CAG reports.
4. CAG of India v. K.S. Jagannathan, AIR 1987 SC 537
Principle: CAG reports may be subject to judicial review, and their findings can lead to legal action if financial impropriety is revealed.
Conclusion:
Article 151 ensures that the findings of the CAG are brought into public and legislative scrutiny. It is a vital tool for maintaining financial discipline and checking executive accountability.
✅ Key takeaway: Article 151 forms the bridge between the CAG and the legislature, empowering democratic oversight of public finances.
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