Article 284 of the Costitution of India with Case law
🔹 Article 284 of the Constitution of India – Custody of Suits, Fines, and Other Monies
📘 Text of Article 284
"All moneys received by public servants and courts to be credited to the public account of the Union or the State."
Clause (1):
The following shall be paid into the public account of India or the State concerned:
All moneys received by public servants (in connection with the affairs of the Union or the State), and
All moneys received by courts.
Clause (2):
The custody of such moneys, their payment into the appropriate public account, and withdrawal thereof shall be regulated by law made by the appropriate legislature.
🧾 Key Features of Article 284
| Aspect | Details |
|---|---|
| Applies to | Public servants and courts |
| Scope | Any money received in official capacity |
| Deposited in | Public Account of India or State |
| Governance | Subject to parliamentary or state legislation |
| Purpose | Ensures accountability and transparency in public money handling |
💡 Understanding the "Public Account"
Public Account of India/State:
Contains money not belonging to the government, but held by it in trust (e.g., Provident Funds, Small Savings, Court Receipts).
Different from Consolidated Fund:
The Consolidated Fund includes revenues and loans of the government, whereas the Public Account is for non-governmental funds that require no parliamentary approval for withdrawal.
⚖️ Relevant Case Laws on Article 284
Though direct litigation on Article 284 is rare, its principles often surface in cases involving misuse or misappropriation of public funds and fiduciary responsibility of public officials. Key judicial interpretations:
🔹 State of Gujarat v. Hon'ble High Court of Gujarat, (1998) 7 SCC 392
Facts: Concerns over accounting practices of court fees and deposits by judicial officers.
Held:
Public money received by courts must be accounted for and deposited properly as per Article 284.
Court emphasized strict compliance with financial regulations by courts and judicial officers.
Relevance: Reinforced judicial responsibility under Article 284.
🔹 Kuldip Nayar v. Union of India, AIR 2006 SC 3127
Though not directly on Article 284, discussed constitutional obligations of public institutions to handle official matters (including finances) transparently.
🔹 CIT v. Tollygunge Club Ltd., AIR 1977 SC 1201
Context: Discussed how receipts by public bodies (including courts and quasi-judicial entities) are to be treated financially and legally.
Indirect Reference: Underlines Article 284 principles—money held by public bodies is public money, subject to public law.
✅ Conclusion
Article 284 ensures that all funds handled by courts and public servants are treated as public property and are deposited transparently into the Public Account of India or the respective State. It serves as a safeguard against misuse of public funds, reinforcing the principle of accountability in public financial management.
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