State Legislature — Legislative Assembly, Council, Procedure

Articles 168 to 213 of the Constitution build the legislative arm of every State. They begin with the Governor sitting at the apex of the Legislature without being its member, settle the bicameral-versus-unicameral question, distribute composition between direct election and indirect modes, and end with the Governor's parallel ordinance power under Article 213. The architecture deliberately mirrors Parliament under Articles 79 to 122, but it is not a copy — the State scheme has its own distinctive features: a creatable and abolishable upper House, a financially weaker Council, a Speaker who alone certifies a Money Bill, and a Governor who must reserve certain Bills for the President.

For the aspirant the scheme is clean. Articles 168 and 169 settle structure and the creation or abolition of the Legislative Council. Articles 170 and 171 prescribe composition. Articles 172 to 177 cover duration, qualifications, sessions and the Governor's right to address. Articles 178 to 187 set up officers and secretariat. Articles 188 to 195 deal with conduct of business, oath, vacation, disqualifications, and privileges. Articles 196 to 201 prescribe legislative procedure, including the Money Bill route and reservation of Bills. Articles 202 to 207 regulate financial business. Articles 208 to 212 close with rules of procedure, language, restrictions on judges' discussion, and the bar on courts inquiring into legislative procedure. Article 213 — the Governor's ordinance power — sits in the next chapter but completes the picture. The wider parallel with the Union House is taken up in our notes on the Union Legislature.

Article 168 and the bicameral choice

Article 168(1) provides that for every State there shall be a Legislature consisting of the Governor and one or two Houses, depending on the State. Six States have two Houses — Andhra Pradesh, Bihar, Maharashtra, Karnataka, Telangana, Uttar Pradesh — with Madhya Pradesh's bicameral status hanging on a Presidential notification that has never been issued, as Ramdas v. State of M.P., AIR 1959 SC 1149, confirmed. Where there are two Houses, one is the Legislative Assembly (Vidhan Sabha) and the other the Legislative Council (Vidhan Parishad); where there is one, it is the Legislative Assembly.

The Governor's place in the Legislature is the threshold puzzle. Although Article 158(1) bars the Governor from being a member of either House, Article 168(1) makes him a component part of the State Legislature because every Bill needs his assent under Article 200. Union of India v. Valluri Basavaiah Choudhary, AIR 1979 SC 1415, settled that the Governor cannot deliberate, sit or vote — but a resolution by the State Legislature under Article 252(1) or the proviso to Article 368(2) means a resolution of the Houses, without the Governor. The Governor's executive role is taken up separately in our notes on the State Executive.

Article 169 — creating and abolishing the Council

Article 169 makes the Legislative Council a uniquely fragile House. Notwithstanding Article 168, Parliament may by law abolish a Council in a State that has one, or create one in a State that does not, provided the Legislative Assembly of the State first passes a resolution to that effect by a majority of the total membership and a majority of not less than two-thirds of members present and voting. Parliament's law may amend the Constitution as required, but is expressly declared not to be a constitutional amendment for Article 368 purposes. This is the only procedure in the Constitution by which an entire House can be born or killed by an ordinary law.

Composition of the Assembly — Article 170

The Legislative Assembly consists of not more than 500 and not less than 60 members chosen by direct election from territorial constituencies — subject to the seat-reservation regime of Article 333. Each State is divided into constituencies so that the ratio between population and seats is, as far as practicable, the same throughout the State. The 84th Amendment (read with the 87th and successive amendments) has frozen the population reference to the 2001 census until figures from the first census after 2026 are published.

Article 170 incorporates the principle of fair and effective representation, as R.C. Poudyal v. Union of India, (1994) Supp (1) SCC 324, held — one person, one vote is a broad principle but cannot be enforced with arithmetical accuracy. Subrata Acharjee v. Union of India, (2002) 2 SCC 725, treated the words "readjusted by such authority and in such manner as Parliament may by law determine" as an enabling provision permitting Parliament to adjust seats to meet the exigencies of the time. The wider election framework under Articles 324 onwards governs how those constituencies are then contested.

Composition of the Council — Article 171

The Council's strength shall not exceed one-third of the Assembly's strength and in no case be less than forty. The composition is one of the cleverest indirect-election schemes in any modern constitution:

1. One-third elected by electorates of members of municipalities, district boards and other local authorities specified by Parliament;
2. One-twelfth elected by graduates of three years' standing residing in the State;
3. One-twelfth elected by persons of three years' standing in teaching at not below secondary-school level;
4. One-third elected by the members of the Legislative Assembly from amongst persons who are not members of the Assembly;
5. The remainder nominated by the Governor from persons of special knowledge or practical experience in literature, science, art, the cooperative movement, and social service.

Elections under sub-clauses (a) to (d) are held by the system of proportional representation by single transferable vote. The qualifications under sub-clauses (b) and (c) apply only to electors, not to candidates — so a non-graduate or a non-teacher may be elected, as S. Narayanaswami v. G. Panneerselvam, AIR 1972 SC 2284, held. The Governor's nomination under clause (5) is non-justiciable: In re Ramamoorthi, AIR 1952 Mad 492, held that no certiorari lies, and Bimanchandra Bose v. Dr. H.C. Mookherjee, AIR 1952 Cal 799, held that quo warranto does not lie either.

Duration, qualifications and sessions

Article 172 fixes the term of the Assembly at five years from its first meeting, extendable by Parliament during a Proclamation of Emergency by not more than one year at a time and not beyond six months after the Proclamation ceases. The Council, like the Rajya Sabha, is not subject to dissolution; one-third of its members retire every second year.

Article 173 lays down qualifications for membership: citizenship of India and the prescribed oath before a person authorised by the Election Commission, a minimum age of twenty-five for the Assembly and thirty for the Council, and any other qualifications prescribed by Parliament. Rajbala v. State of Haryana, (2016) 2 SCC 445, treated the right to contest elections as a constitutional right by implication, since these very provisions create constitutional limitations on it. Sushil Kumar v. Rakesh Kumar, (2003) 8 SCC 673, set aside an election where the returned candidate was below twenty-five on the date of nomination.

Article 174 vests in the Governor the power to summon, prorogue and dissolve. Six months shall not intervene between the last sitting in one session and the first sitting of the next. The Supreme Court in Raja Ram Pal v. Hon'ble Speaker, Lok Sabha, (2007) 3 SCC 184, located the summoning power in the Governor and not in the House. The six-month rule applies only to a live, functioning Assembly — not to a dissolved one, where the periodicity of fresh elections falls within the exclusive domain of the Election Commission under Article 324. The interplay with Article 356 is more delicate: a House kept in suspended animation under Article 356 can be dissolved before its first meeting.

Articles 175 to 177 give the Governor the right to address either House, send messages, and require attendance. The first session after each general election and the first session of each year must open with the Governor's address. Article 177 lets every Minister and the Advocate-General speak in either House and on any committee, but not vote — a non-member Minister appointed under Article 164(4) can therefore participate without voting, as Har Sharan Verma v. Tribhuvan Narain Singh, AIR 1971 SC 1331, confirmed.

Officers — Speaker, Chairman, and the resolution-for-removal rule

Articles 178 to 181 set up the Speaker and Deputy Speaker of the Assembly; Articles 182 to 185 do the same for the Chairman and Deputy Chairman of the Council. Each is chosen from among the members. Each may resign by writing addressed to the other, and may be removed by a resolution passed by a majority of the then members of the House on fourteen days' notice. Article 179's second proviso protects the Speaker through dissolution — he does not vacate office until immediately before the first meeting of the next Assembly.

Articles 181 and 185 carry an important quirk. While a resolution for his removal is under consideration, the Speaker (or Chairman) shall not preside, but he retains the right to speak and may vote in the first instance — though not in case of equality of votes. This converts the casting vote of Article 189 (which the Speaker normally exercises) into a normal vote during his removal proceedings.

Conduct of business — oath, voting, quorum

Article 188 requires every member to make and subscribe the oath in the Third Schedule before taking his seat, before the Governor or his appointee. Failure to take the oath does not ipso facto vacate the seat — Anand Bihari Mishra v. Ram Sahay, AIR 1953 MB 305, held that the Article 193 penalty is the consequence, and quo warranto does not lie. The member retains some non-legislative capacities — he may, for instance, propose a candidate for a Rajya Sabha election, as Madhukar Jetly v. Union of India, (1997) 11 SCC 111, recognised.

Article 189 says all questions are decided by a majority of votes of members present and voting other than the presiding officer, who has only a casting vote. The House may act notwithstanding vacancies, and proceedings are valid even if it is later discovered that an unauthorised person sat or voted. The quorum is ten members or one-tenth of the House, whichever is greater.

Vacation of seats and disqualifications — Articles 190 to 193

Article 190 prevents a member from sitting in both Houses or in the Legislatures of two States. A seat falls vacant on resignation in writing addressed to the Speaker or Chairman, but the 1974 amendment lets the Speaker decline to accept a resignation that he is satisfied is not voluntary or genuine. Article 190(4) allows the House to declare a seat vacant if the member is absent without permission for sixty days — and as Ansumali Majumdar v. State of W.B., AIR 1952 Cal 632, noted, this absence does not automatically cause a vacancy; the House must so declare it.

Article 191 lists the disqualifications: holding an office of profit under the Government of India or any State (other than one declared by State law not to disqualify), unsoundness of mind declared by a competent court, undischarged insolvency, loss of citizenship or voluntary acquisition of foreign citizenship, and any other disqualification under Parliamentary law — most importantly the Representation of the People Act, 1951. Clause (2) imports the entire Tenth Schedule — the anti-defection law — into the disqualification regime.

The office-of-profit jurisprudence is dense. The Supreme Court in Pradyut Bordoloi v. Swapan Roy, (2001) 2 SCC 19, called the prime test the Government's power to appoint and remove. Satrucharla Chandrasekhar Raju v. Vyricherla Pradeep Kumar Dev, (1992) 4 SCC 404, listed the cumulative tests — degree of control, nature of functions, payment, dependence on Government for finance. Karbhari Bhimaji Rohamare v. Shankar Rao Genuji Kolhe, AIR 1975 SC 575, made clear that no master-servant relationship is needed. Election Commission of India v. Bajrang Bahadur Singh, (2015) 12 SCC 264, held that on incurring a disqualification the seat falls vacant by operation of law. Lily Thomas v. Union of India, (2013) 7 SCC 653, located Parliament's competence to legislate qualifications squarely in Articles 102(1)(e) and 191(1)(e), not in Articles 246 or 248. The full Tenth-Schedule machinery on defection is examined as part of the basic structure debate in our notes on the basic structure doctrine and the amendment framework.

Article 192 routes any post-election disqualification question to the Governor, who must obtain the opinion of the Election Commission and act according to it. Brundaban Nayak v. Election Commission of India, AIR 1965 SC 1892, held the question may arise in any manner — the Governor alone decides and the courts have no jurisdiction. Election Commission of India v. Subramaniam Swamy, (1996) 4 SCC 104, made it clear that the Governor must act on the Commission's opinion alone, even without consulting the Council of Ministers. Kihota Hollohan v. Zachillhu, 1992 Supp (2) SCC 651, however, takes Tenth-Schedule disqualifications out of Article 192 and lodges them with the Speaker, whose decision is itself amenable to limited judicial review.

Privileges of the House — Article 194

Article 194 mirrors Article 105 of the Union framework. Clause (1) guarantees freedom of speech in the Legislature subject to the Constitution and the Rules of Procedure. Clause (2) immunises members from any proceedings in any court in respect of anything said or any vote given in the House or any committee, and protects publication by or under the authority of the House. Clause (3) leaves all other privileges to be defined by State law and, until so defined, to those that subsisted immediately before the commencement of the Forty-fourth Amendment.

Three lines of authority shape this Article. M.S.M. Sharma v. Sri Krishna Sinha, AIR 1959 SC 395 (the Searchlight case), held that the freedom of speech under Article 194(1) is independent of Article 19(1)(a) — a member cannot raise a discussion contrary to Article 211, but the absolute immunity of clause (2) protects him from any legal action for the breach. Tej Kiran Jain v. N. Sanjiva Reddy, AIR 1970 SC 1573, confirmed that anything said during the course of business of the House is immune, regardless of its relevance. Raja Ram Pal v. Hon'ble Speaker, Lok Sabha, (2007) 3 SCC 184, opened a window of judicial review — actions of the House for contempt or expulsion can be examined for substantive illegality, gross irrationality, mala fides or violation of constitutional mandate.

The relationship between privilege and judicial process was crystallised in In re: Powers, Privileges and Immunities of State Legislatures, AIR 1965 SC 745 — the Keshav Singh reference — which authoritatively settled the relationship between the U.P. Legislative Assembly's contempt power and the Allahabad High Court's writ jurisdiction. Amarinder Singh v. Special Committee, Punjab Vidhan Sabha, (2010) 6 SCC 113, restated the principle: privileges exist to protect legislative function, not to displace ordinary courts; expulsion is sustained only where the Member's act has obstructed or threatens to obstruct legislative proceedings.

Legislative procedure — Articles 196 to 201

Article 196 governs introduction and passage. Subject to the Money Bill rules, a Bill may originate in either House of a bicameral State Legislature, and is deemed passed only when both Houses agree to it with or without amendments. Three lapse rules follow: a Bill pending in the Legislature does not lapse on prorogation; a Bill pending in the Council that has not been passed by the Assembly does not lapse on dissolution; but a Bill pending in the Assembly, or passed by the Assembly and pending in the Council, lapses on dissolution.

Article 197 captures the asymmetry between the two Houses. If the Council rejects an Assembly Bill, lets three months elapse, or amends it in a form the Assembly will not accept, the Assembly may pass it again in the same or a subsequent session. If the Council rejects the Bill the second time, lets one month elapse, or amends it unacceptably, the Bill is deemed passed by both Houses — in the form passed by the Assembly the second time, with whatever amendments the Council suggested and the Assembly accepted. There is no joint sitting at the State level. The Assembly's will, after this delay, simply prevails. Article 197(3) makes clear that this procedure does not apply to a Money Bill.

Money Bills — Articles 198 and 199

A Money Bill is the State Legislature's most asymmetric instrument. Article 198 forbids its introduction in the Council. After being passed by the Assembly, it is transmitted to the Council for recommendations, which the Council must return within fourteen days. The Assembly may accept or reject all or any of the recommendations. If the Assembly accepts a recommendation, the Bill is deemed passed by both Houses with that amendment; if it does not, it is deemed passed in the form the Assembly originally adopted; if the Council returns nothing within fourteen days, the Bill is again deemed passed in the Assembly's form.

Article 199 defines a Money Bill exhaustively. The Bill must contain only provisions dealing with imposition or alteration of any tax, regulation of State borrowing or guarantees, custody of the Consolidated or Contingency Fund of the State, appropriation out of the Consolidated Fund, declaration of expenditure as charged on the Fund, receipt or custody of money on the public account, or any matter incidental to the foregoing. A Bill is not a Money Bill merely because it imposes fines or pecuniary penalties, levies fees for licences or services, or authorises a local authority to impose a tax for local purposes. The Speaker of the Legislative Assembly is the sole arbiter of whether a Bill is a Money Bill, and his certificate is endorsed when the Bill is sent to the Council and to the Governor.

The Supreme Court in Kewal Krishan Puri v. State of Punjab, AIR 1980 SC 1008, drew the line cleanly: an imposition of a tax falls under Article 199(1); an imposition of a fee falls outside it. Corporation of Calcutta v. Liberty Cinema, AIR 1965 SC 1107, confirmed that municipal taxation is outside the Money Bill definition. The Speaker's certification is itself protected from judicial review under Article 212's bar on inquiring into legislative procedure — most recently confirmed in Yogendra Kumar Jaiswal v. State of Bihar, (2016) 3 SCC 183.

Assent — Articles 200 and 201

Article 200 places the Bill before the Governor with three options — assent, withholding of assent, or reservation for the President's consideration. The first proviso lets the Governor return a non-Money Bill with a message; if the House passes it again, with or without amendment, the Governor shall not withhold assent. The second proviso compels reservation of any Bill that, in the Governor's opinion, would so derogate from the powers of the High Court as to endanger the constitutional position the Court is designed to fill. The link with the State Judiciary chapter is direct — this is the Constitution's structural protection of the High Court.

Reservation is an alternative to assent, not a sequel to it, as State of Bihar v. Kameshwar Singh, AIR 1952 SC 252, held. The President may, on reference under Article 143, take the Supreme Court's opinion before assenting — as he did in In re Kerala Education Bill, AIR 1958 SC 956. The propriety of the Governor's reservation, and of the President's assent, is non-justiciable: Hoechst Pharmaceuticals Ltd v. State of Bihar, AIR 1983 SC 1019, settled the point. Article 201 then provides that the President shall declare assent or withhold it; for non-Money Bills, he may direct return for reconsideration within six months.

The Constitution sets no time limit. Purushothaman Nambudiri v. State of Kerala, AIR 1962 SC 694, held that the dissolution of the Assembly does not prevent the exercise of powers under Articles 200 and 201 over a Bill already presented. The interaction between the Centre and the State at this point is part of the broader pattern of Centre-State legislative relations.

Financial procedure — Articles 202 to 207

Article 202 requires the Governor to lay before the House every financial year an annual financial statement — the State budget. The estimates distinguish charged expenditure (Governor's emoluments, Speaker and Deputy Speaker salaries, judges' salaries, debt charges, decree satisfactions, and any other items declared charged by the Constitution or State law) from voted expenditure. Article 203 then sends the voted demands for grants to the Legislative Assembly alone — the Council has no role — on the recommendation of the Governor. Article 204 authorises the Appropriation Bill, after which no money may be withdrawn from the State Consolidated Fund. Articles 205 and 206 cover supplementary, additional, excess, and exceptional grants and votes on account. Article 207 forbids the introduction of financial Bills in the Council and requires the Governor's recommendation for those involving expenditure from the Consolidated Fund.

The financial framework reads with the larger pattern of Centre-State financial relations — the State's revenue base is shaped by Articles 264 onwards, but its appropriation discipline is governed here.

Procedure generally — Articles 208 to 212

Article 208 lets each House make rules for its procedure subject to the Constitution. State of Punjab v. Satya Pal Dang, AIR 1969 SC 903, held that Rules of the House cannot add a clause to the Constitution or condition the Governor's constitutional powers; in case of conflict, the Constitution prevails. Article 209 lets the State Legislature regulate financial business by law; such law overrides any inconsistent rule of the House. Article 210 prescribes the language of business — the official language of the State, Hindi, or English — with extended timeframes for certain States and a power in the Speaker to allow a member to use his mother-tongue when he cannot adequately express himself in the listed languages. Article 211 prohibits any discussion of the conduct of a Supreme Court or High Court Judge in the Legislature.

Article 212 is the constitutional firewall around the legislative process. Its first clause makes the validity of any proceedings in the Legislature unchallengeable on the ground of irregularity of procedure. Its second clause immunises any officer or member exercising powers for procedure or order from any court's jurisdiction. The Court has held that the bar covers irregularities, not substantive illegalities. As long as the Speaker has endorsed a Bill as passed, the courts will not look behind the endorsement — but if the Legislature defies a mandatory provision of the Constitution, or exercises powers it does not possess, the immunity falls away. The certification of a Bill as a Money Bill, as Yogendra Kumar Jaiswal held, is treated as an irregularity rather than a substantive question — and is therefore protected.

Article 213 — the Governor's ordinance power

Article 213 mirrors Article 123 of the Union framework. When the Assembly (or both Houses, in a bicameral State) is not in session, and the Governor is satisfied that circumstances render immediate action necessary, he may promulgate an ordinance. The proviso requires the President's prior instructions for ordinances on matters where a Bill would have needed Presidential sanction or reservation, or where a State Act would have been invalid without Presidential assent. The ordinance has the same force and effect as a State Act assented to by the Governor, but must be laid before the Legislature on reassembly and ceases to operate at the expiration of six weeks from reassembly — sooner, if disapproved by resolution.

The leading authority is the Constitution Bench in Krishna Kumar Singh v. State of Bihar, (2017) 3 SCC 1. The Court held that the Governor's satisfaction is justiciable for relevance of material, fraud on power, and oblique motive — though not for sufficiency of material. The requirement to lay the ordinance is mandatory, not directory. The Court overruled the older State of Orissa v. Bhupendra Kumar Bose, AIR 1962 SC 945, and T. Venkata Reddy v. State of Andhra Pradesh, (1985) 3 SCC 198, on the doctrine of enduring rights — rights, privileges, obligations, and liabilities created under an ordinance survive only by application of a public-interest and constitutional-necessity test, on a case-by-case basis.

Re-promulgation without placing the ordinance before the Legislature is a fraud on the Constitution. D.C. Wadhwa v. State of Bihar, AIR 1987 SC 579, struck at the Bihar practice of routine re-promulgation; Krishna Kumar Singh entrenched the principle. An ordinance may, however, exercise the full legislative power of the State Legislature, including amending or repealing existing laws and operating retrospectively, as State of Orissa v. Bhupendra Kumar Bose recognised on that limited point. Article 213 must be read with Article 174 — a Governor cannot ward off the Legislature beyond six months because Article 174(1) compels it to be summoned. The wider doctrines on legislative power are developed in our chapter on the distribution of legislative powers.

Why this chapter sits at the centre of state-level constitutional law

The Constitution of India distributes legislative power between the Union and the States, but the engine that converts that power into law in each State is built here. The Vidhan Sabha is the only directly elected representative chamber in the State, the Council is the constitutional reserve seat for expertise and indirect representation, the Money Bill is the procedural lever that gives the Assembly its primacy, and Article 213 is the Governor's safety valve. Reading Articles 168 to 213 together — and reading them next to Articles 79 to 122 of the Union framework — gives the aspirant the full structural map of representative government under the Constitution.

Frequently asked questions

Which States have a Legislative Council and how is one created or abolished?

Six States currently have a Legislative Council — Andhra Pradesh, Bihar, Maharashtra, Karnataka, Telangana and Uttar Pradesh. Madhya Pradesh's bicameral status under the Seventh Amendment depends on a Presidential notification that has never been issued, as Ramdas v. State of M.P. (AIR 1959) confirmed. Under Article 169, Parliament may create or abolish a Council by ordinary law, but only after the State Legislative Assembly first passes a resolution by a majority of total membership and a two-thirds majority of members present and voting. Such a law is expressly declared not to be a constitutional amendment for Article 368.

How does a Money Bill move differently in a State Legislature than an ordinary Bill?

Under Article 198, a Money Bill cannot be introduced in the Legislative Council; it must originate in the Legislative Assembly. Once passed by the Assembly, it is transmitted to the Council for recommendations only, which the Council must return within fourteen days. The Assembly may accept or reject those recommendations. If the Council fails to return the Bill within fourteen days, it is deemed passed by both Houses in the Assembly's form. Article 199 defines a Money Bill exhaustively, and the Speaker of the Assembly alone certifies the Bill — and his certificate is final.

Can a court question the Speaker's certificate that a Bill is a Money Bill?

Generally no. Article 199(3) makes the Speaker's decision final, and Article 212 bars any court from inquiring into the validity of legislative proceedings on the ground of irregularity of procedure. The Supreme Court in Yogendra Kumar Jaiswal v. State of Bihar (2016) treated the Money Bill certification as an irregularity rather than a substantive question, and therefore protected. Judicial review remains available only on the narrowest of grounds — substantive illegality, defiance of mandatory constitutional provisions, or actions outside the Legislature's power.

Who decides a question of disqualification of a sitting State legislator?

Under Article 192, where a question arises whether a member has become subject to any of the Article 191(1) disqualifications, it is referred to the Governor, who must obtain the opinion of the Election Commission and act according to that opinion. Brundaban Nayak v. Election Commission of India (AIR 1965) settled that the Governor alone decides — courts have no jurisdiction. For Tenth-Schedule defection cases, however, Article 191(2) routes the question to the Speaker of the House, whose decision is open to limited judicial review under Kihota Hollohan v. Zachillhu (1992).

What is the scope of legislative privilege under Article 194 — can a member be sued for what he says?

No. Article 194(2) creates absolute immunity for members from any proceedings in any court in respect of anything said or any vote given in the Legislature or its committees. Tej Kiran Jain v. N. Sanjiva Reddy (AIR 1970) held that anything said during the business of the House is immune, regardless of relevance. Article 194(1)'s freedom of speech is, however, subject to other constitutional provisions like Article 211 (no discussion of judges' conduct) and to the Rules of Procedure. The remedy for an Article 211 breach is action by the House itself, not in any court.

When can the Governor promulgate an ordinance under Article 213, and how long does it last?

Under Article 213, the Governor may promulgate an ordinance only when the Assembly (or, in a bicameral State, both Houses) is not in session, and only when satisfied that circumstances render immediate action necessary. The President's prior instructions are required where a Bill would have needed Presidential sanction or reservation. The ordinance has the same force as a State Act, but must be laid before the Legislature on reassembly and ceases to operate at the expiration of six weeks from reassembly, or earlier on a disapproving resolution. Re-promulgation as a routine practice is a fraud on the Constitution, as Krishna Kumar Singh v. State of Bihar (2017) held.