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Understanding Parliamentary Privileges: Safeguarding Democracy and Legislative Authority
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- UPSCgeeks
Understanding Parliamentary Privileges: Safeguarding Democracy and Legislative Authority
1. Introduction
Parliamentary privileges are the special rights, immunities, and exemptions enjoyed by each House of Parliament and State Legislatures, their committees, and their members collectively and individually. Defined as a cornerstone of representative democracy, these privileges ensure that legislators can perform their constitutional duties effectively, fearlessly, and without external interference or intimidation.
The primary objective of these privileges is not to place lawmakers above the ordinary law of the land, but to preserve the dignity, authority, and independence of the legislative organ of the state. In a parliamentary democracy governed by the Rule of Law and the Separation of Powers, these immunities prevent the executive or the judiciary from encroaching upon the legislative domain, thereby safeguarding democratic deliberation.
+-------------------------------------------+
| PARLIAMENTARY PRIVILEGES |
+-------------------------------------------+
|
+------------------+------------------+
| |
v v
+--------------------------+ +--------------------------+
| COLLECTIVE PRIVILEGES | | INDIVIDUAL PRIVILEGES |
| (Enjoyed by the House | | (Enjoyed by individual |
| as a whole) | | lawmakers) |
+--------------------------+ +--------------------------+
2. Historical and Constitutional Background
British Origins
The concept of parliamentary privilege originated in the British House of Commons. Historically, these privileges were secured after a prolonged struggle between the British Crown and Parliament. The Bill of Rights 1689 firmly established that "freedom of speech and debates or proceedings in Parliament ought not to be impeached or questioned in any court or place out of Parliament."
Pre-Constitutional Evolution in India
In India, the evolution of legislative privileges began with the gradual introduction of representative elements under British rule:
- The Indian Councils Act, 1861 & 1892: Provided minimal freedom of discussion but no statutory immunities.
- Government of India Act, 1919: For the first time, statutory protection was granted to members of the Indian legislature against civil or criminal action in court regarding their speech or votes in the chamber.
- Government of India Act, 1935: Expanded these provisions and laid the groundwork for modern legislative immunities, which were subsequently adapted by the framers of the Indian Constitution.
Constituent Assembly Debates
During the drafting of the Constitution, the scope and phrasing of parliamentary privileges were debated in detail. Two major perspectives emerged:
- The Codification School: Some members argued that privileges should be comprehensively codified and listed within the Constitution to prevent arbitrariness and ensure clarity.
- The Pragmatic School (Led by Dr. B.R. Ambedkar): Dr. Ambedkar and others argued that listing all privileges would make the Constitution overly bulky and rigid. It was difficult to anticipate all possible situations where a legislature’s dignity might be threatened. Consequently, they decided to provisionally link Indian legislative privileges to those of the British House of Commons until the Indian Parliament chose to enact its own comprehensive law.
3. Key Provisions & Constitutional Articles
The constitutional architecture of legislative privileges in India is divided between the Union Parliament and State Legislatures.
UNION PARLIAMENT STATE LEGISLATURES
(Article 105) (Article 194)
+--------------------------+ +--------------------------+
| (1) Freedom of Speech | | (1) Freedom of Speech |
| (2) Legal Immunity | | (2) Legal Immunity |
| (3) Uncodified Scope | | (3) Uncodified Scope |
| (4) Extends to Ministers/| | (4) Extends to Advocate |
| Attorney General | | General / Ministers |
+--------------------------+ +--------------------------+
Analysis of Article 105
- Article 105(1): Subject to the provisions of the Constitution and the rules and standing orders regulating the procedure of Parliament, there shall be freedom of speech in Parliament.
- Article 105(2): No member of Parliament shall be liable to any proceedings in any court in respect of anything said or any vote given by them in Parliament or any committee thereof. Furthermore, no person shall be liable in respect of the publication by or under the authority of either House of Parliament of any report, paper, votes, or proceedings.
- Article 105(3): In other respects, the powers, privileges, and immunities of each House, and of the members and the committees of each House, shall be such as may from time to time be defined by Parliament by law. Until so defined, they shall be those of that House and of its members and committees immediately before the coming into force of Section 15 of the 44th Constitutional Amendment Act, 1978 (which substituted the original reference to the British House of Commons with a reference to the status quo as of 1978).
- Article 105(4): Extends the application of these privileges to persons who, by virtue of the Constitution, have the right to speak and otherwise take part in proceedings of a House of Parliament or any committee thereof (e.g., Union Ministers and the Attorney General of India), even if they are not voting members of that specific House.
Analysis of Article 194
Article 194 is a mirror provision of Article 105, extending identical powers, privileges, and immunities to the State Legislatures, their committees, and their members (including State Ministers and the Advocate General of the State).
4. Institutional Framework & Classification of Privileges
Privileges are divided into two categories: Collective Privileges (vested in the House as a whole) and Individual Privileges (vested in individual members).
Collective Privileges of the House
| Privilege | Constitutional & Practical Significance |
|---|---|
| Right to Publish Debates and Proceedings | The House has the right to publish its reports, debates, and proceedings, and to prohibit others from publishing them. Under the Parliamentary Proceedings (Protection of Publication) Act, 1977, truthful reporting of parliamentary proceedings is protected, but the House retains the power to prohibit publication of expunged or secret sessions. |
| Right to Exclude Strangers | To ensure undisturbed debates, the House can exclude strangers and non-members from the galleries, and hold secret sittings to discuss sensitive matters. |
| Right to Regulate Internal Affairs | Each House has the exclusive right to regulate its own procedure and conduct of business (Articles 118 and 208). The courts cannot inquire into the validity of any proceedings in Parliament on the ground of an alleged irregularity of procedure (Articles 122 and 212). |
| Power to Punish for Breach of Privilege or Contempt | The House is empowered to punish both members and outsiders for breach of privilege or contempt of the House. Punishments can range from admonition and reprimand to suspension, expulsion, or imprisonment. |
Individual Privileges of Members
- Freedom of Speech: Members enjoy absolute freedom of speech on the floor of the House. They cannot be sued for defamation or prosecuted for any statement made during debates or votes cast in the House or its committees.
- Freedom from Arrest:
- In civil cases, a member cannot be arrested during a session of Parliament, and 40 days before its commencement and 40 days after its conclusion.
- This privilege is not available in criminal cases, preventive detention, or cases involving national security. However, if a member is arrested or detained on criminal charges, the arresting authority must immediately inform the Speaker or Chairman of the reason and place of detention.
- Exemption from Jury Service: Members are exempt from attending court as witnesses or jurors when Parliament is in session, allowing them to perform their legislative duties without judicial distractions.
5. Breach of Privilege vs. Contempt of the House
While often used interchangeably, there is a conceptual distinction between a "Breach of Privilege" and "Contempt of the House":
BREACH OF PRIVILEGE CONTEMPT OF THE HOUSE
+------------------------+ +--------------------------+
| Violation of a specific| | Any act that obstructs |
| recognized privilege | =================> | or impedes the House, |
| (e.g., arresting a | (Broad category) | its officers, or members |
| member in a civil case | | in their duties |
| during session) | | (e.g., shouting in court)|
+------------------------+ +--------------------------+
The Procedural Mechanics of a Privilege Motion
A privilege motion is a procedural tool used by members to raise a question of breach of privilege or contempt. The following flowchart maps the procedural journey of a privilege motion:
[ Alleged Breach / Contempt Occurs ]
|
v
[ Member Files Notice ]
(Submitted to the Speaker or Chairman)
|
v
[ Scrutiny by Presiding Officer ]
(Checks for Prima Facie case)
|
+-------------------+-------------------+
| |
(Consent Denied) (Consent Granted)
| |
v v
[Matter Drops] [ Referred to House ]
|
+-------------------+-------------------+
| |
(House decides directly) (Referred to Committee)
| |
| v
| [ Committee of Privileges ]
| (Investigates & reports)
| |
+-------------------+-------------------+
|
v
[ Final Debate & Vote ]
|
+-------------------+-------------------+
| |
(Accused Cleared) (Guilty Verdict)
| |
v v
[Case Closed] [Punishment Awarded]
(Reprimand / Suspension
/ Imprisonment)
6. Landmark Judicial Decisions
The judiciary has played a critical role in balancing legislative privilege with fundamental rights, the rule of law, and clean governance.
1. MSM Sharma v. Sri Krishna Sinha (Searchlight Case, 1959)
- Context: An editor of the journal Searchlight published portions of a speech made in the Bihar Legislative Assembly that had been ordered to be expunged by the Speaker.
- Ruling: The Supreme Court held that the House’s power to prohibit the publication of its debates is part of its privileges. More importantly, it ruled that uncodified parliamentary privileges under Article 194(3) are not subject to the freedom of speech and expression guaranteed under Article 19(1)(a). However, the Court indicated that privileges must not violate Article 21 (Right to Life and Personal Liberty).
2. Powers, Privileges, and Immunities of State Legislatures (Keshav Singh Case, 1965)
- Context: Keshav Singh was imprisoned by the Uttar Pradesh Legislative Assembly for contempt of the House. He filed a habeas corpus petition under Article 226 before the High Court, which granted him bail. The Assembly then issued arrest warrants for the High Court judges and the advocate who filed the petition.
- Ruling: A special reference was made to the Supreme Court under Article 143. The Court held that legislatures do not possess absolute, unreviewable powers of commitment for contempt. The judiciary has the authority to review detention orders issued by the House to ensure they do not violate Article 21 or the fundamental rights of citizens. The House cannot assume the status of a sovereign "High Court" in the British sense.
3. Raja Ram Pal v. Hon’ble Speaker, Lok Sabha (2007)
- Context: 11 Members of Parliament were expelled following a sting operation ("Cash-for-Query") that caught them accepting money to ask questions in Parliament. The MPs challenged their expulsion in court.
- Ruling: The Supreme Court upheld the power of Parliament to expel its members for conduct unbecoming of a legislator. However, it held that parliamentary proceedings are subject to judicial review if they are marred by gross illegality, unconstitutionality, or a clear violation of natural justice.
4. Sita Soren v. Union of India (2024) — The Landmark Shift
P.V. NARASIMHA RAO CASE (1998)
[ Majority granted immunity to bribe-takers ]
|
v (Overruled)
SITA SOREN CASE (2024)
[ No immunity for bribery; established 2-fold test ]
- Context: Sita Soren, a member of the Jharkhand Legislative Assembly, was accused of accepting a bribe to vote for an independent candidate in the 2012 Rajya Sabha elections. She claimed immunity from criminal prosecution under Article 194(2), relying on the 5-judge bench decision in P.V. Narasimha Rao v. State (1998). In Narasimha Rao, the majority had held that lawmakers enjoy absolute immunity against bribery charges if they actually fulfill their end of the bargain by voting or speaking in the House in accordance with the bribe.
- Ruling: A unanimous 7-judge Constitution Bench led by Chief Justice D.Y. Chandrachud overruled the P.V. Narasimha Rao judgment. The Court held that:
- Bribery is not protected: The offense of bribery is complete the moment the bribe is accepted, irrespective of whether the legislator later votes or speaks in the House. It is not "in respect of" or "tethered to" the legislative vote.
- The Two-Fold Test of Immunity: To claim immunity under Article 105(2) or 194(2), a claim must satisfy two conditions:
- Test 1 (Tethering): The privilege must be closely tethered to the collective, deliberative functioning of the House.
- Test 2 (Functional Necessity): The privilege must be essential to allow the legislator to discharge their duties. Bribery is destructive of legislative integrity and cannot be deemed necessary to the legislative process.
- No Dual Shield: Parliament's internal authority to discipline members for breach of privilege operates in a separate sphere from the jurisdiction of ordinary criminal courts prosecuting bribery under the Prevention of Corruption Act, 1988.
7. The Codification Debate
The question of whether India should codify its parliamentary privileges under a statutory law remains a topic of constitutional debate.
Arguments FOR Codification
- Enhancing Free Speech of Citizens: In the absence of codification, the vague boundaries of "contempt of the House" can sometimes stifle legitimate journalistic criticism of politicians. Codification would provide clear limits.
- Harmonizing with Fundamental Rights: If codified by an Act of Parliament, the law would constitute "ordinary law" and would therefore be subject to judicial review under Article 13. This would ensure that privileges do not violate Part III of the Constitution (Fundamental Rights).
- Eliminating Arbitrariness: Clear rules would replace the reliance on pre-1978 British conventions, giving citizens and lawmakers a clear understanding of what constitutes a breach.
Arguments AGAINST Codification
- Loss of Legislative Flexibility: Codifying privileges might restrict the House’s ability to handle novel, unforeseen situations that threaten its authority or disrupt its proceedings.
- Judicial Encroachment: Codification would bring the entire domain of privileges under the purview of judicial review, potentially compromising the separation of powers by allowing courts to scrutinize the internal disciplinary measures of the legislature.
- Functional Autonomy: The current uncodified nature allows the presiding officers of the legislature to maintain order and protect the independence of the house from executive pressure.
8. Comparative Perspective
Understanding how India's model of legislative immunity compares with other democratic systems highlights its unique constitutional balance.
| Feature | India | United Kingdom | United States |
|---|---|---|---|
| Source of Privilege | Written Constitution (Articles 105 and 194). | Unwritten conventions, historical common law, and statutes. | US Constitution (Article I, Section 6 - Speech or Debate Clause). |
| Judicial Review | Highly active; subject to constitutional limitations (especially Art 21 and the Sita Soren 2024 ruling). | Highly limited; courts generally do not interfere with the internal affairs of the Westminster Parliament. | Strictly hands-off regarding the "Speech or Debate" clause, but courts can review actions affecting outsiders. |
| Scope of Immunity for Bribery | No immunity; criminal courts can prosecute lawmakers for taking bribes (Sita Soren, 2024). | Subject to ordinary criminal prosecution under the Bribery Act 2010. | No immunity; lawmakers can be prosecuted under criminal statutes (e.g., US v. Brewster). |
| Power to Commit Outsiders | Exists, but subject to judicial review under Article 21 (Keshav Singh case). | Exists; historically absolute as the "High Court of Parliament". | Extremely limited; only what is necessary to perform congressional duties. |
9. Visual Summaries & Comparative Tables
Individual vs. Collective Privileges
+---------------------------------------------------------------------------------+
| PRIVILEGES MAP |
+---------------------------------------+-----------------------------------------+
| INDIVIDUAL PRIVILEGES | COLLECTIVE PRIVILEGES |
+---------------------------------------+-----------------------------------------+
| • Freedom of Speech on the floor | • Right to publish debates/reports |
| • Civil Immunity from arrest | • Right to exclude strangers |
| • Exemption from witness duty | • Right to regulate internal procedures |
| • Immunity from court actions for | • Power to punish for contempt/breach |
| speech or voting decisions | • Power to suspend or expel members |
+---------------------------------------+-----------------------------------------+
Key Shift: P.V. Narasimha Rao (1998) vs. Sita Soren (2024)
| Parameter | P.V. Narasimha Rao Case (1998) | Sita Soren Case (2024) |
|---|---|---|
| Benchmark Idea | Immunity protected those who voted or spoke in accordance with the bribe. | Bribery is an independent criminal offense completed outside the House; no immunity exists. |
| Functional Justification | To enable lawmakers to speak and vote fearlessly. | Privileges cannot shield corruption; bribery undermines deliberative democracy. |
| The Offense Timeline | The act of voting/speaking in the House was considered the central point. | The offense of bribery is complete the moment the bribe is accepted. |
| Immunity Test | Broad interpretation of "in respect of". | Strict, narrow two-fold "essentiality" and "tethering" test. |
10. Interactive Q&A and Practice-Based Learning
Section A: Multiple-Choice Questions (MCQs)
Q1. Consider the following statements regarding the 44th Constitutional Amendment Act, 1978:
- It codified all parliamentary privileges into a comprehensive statutory code.
- It removed the explicit reference to the "House of Commons" in Article 105(3). Which of the statements given above is/are correct? A) 1 only
B) 2 only
C) Both 1 and 2
D) Neither 1 nor 2
Answer: B
Explanation: The 44th Amendment Act did not codify the privileges; it merely removed the explicit reference to the "British House of Commons" in Article 105(3) and replaced it with a reference to the privileges existing immediately before the amendment came into effect. Privileges remain largely uncodified in India.
Q2. In the landmark judgment of Sita Soren v. Union of India (2024), the Supreme Court established which of the following tests to determine whether a legislative action enjoys immunity under Article 105 or 194? A) Test of Legislative Proportionality
B) Two-fold test of "Tethering" and "Functional Necessity"
C) Test of Sovereign Immunity
D) Test of Procedural Propriety
Answer: B
Explanation: The 7-judge Constitution Bench formulated a two-fold test: (1) the privilege must be closely tethered to the collective, deliberative functioning of the House, and (2) it must be essential to the discharge of the legislative duties of a member.
Q3. Under individual parliamentary privileges, a member of Parliament is immune from arrest in civil cases during which of the following periods? A) Only while the House is in active session.
B) 40 days before and 40 days after the session.
C) 14 days before and 14 days after the session.
D) Throughout their entire five-year term, regardless of sessions.
Answer: B
Explanation: Individual privileges protect members from civil arrest during a session of Parliament, and for 40 days before its commencement and 40 days after its conclusion.
Q4. Which of the following statements is correct regarding the scope of individual immunity from prosecution under Article 105(2)? A) An MP enjoys immunity for criminal acts committed inside the Parliament building.
B) An MP enjoys immunity for any speech made on the floor of the House, but this immunity can be waived by a court of law.
C) An MP enjoys complete immunity from legal proceedings in respect of any speech made or vote cast in the House or its committees.
D) Immunity is only applicable to members of the ruling party.
Answer: C
Explanation: Article 105(2) provides absolute immunity from court proceedings for anything said or any vote given by a member of Parliament in the House or its committees. This immunity is a constitutional right and cannot be unilaterally waived by a court of law.
Q5. In which of the following cases did the Supreme Court rule that the uncodified privileges of the legislature are subject to the fundamental rights guaranteed under Article 21? A) MSM Sharma (Searchlight) Case
B) Keshav Singh Case
C) Raja Ram Pal Case
D) Sita Soren Case
Answer: B
Explanation: In the Keshav Singh Case (1965), the Supreme Court clarified that any commitment for contempt or breach of privilege made by the legislature is subject to judicial review, particularly if it violates the fundamental right to life and personal liberty under Article 21.
Section B: Scenario-Based Analysis
Scenario 1: Arrest of an MLA During Assembly Session
Scenario: An MLA from State X is accused of being the mastermind behind a major financial scam. While the State Legislative Assembly is in active session, a team from the state police arrests the MLA in their official quarters to prevent them from fleeing. The Speaker of the Assembly objects, claiming a breach of parliamentary privilege on the grounds that the MLA was arrested during a live session without the Speaker’s prior permission.
Analyze the situation. Has a breach of privilege occurred?
- Ideal Answer Analysis:
- Core Issue: Does the individual privilege of freedom from arrest apply to criminal allegations while the house is in session?
- Constitutional Provisions: Under Article 194, MLAs enjoy freedom from arrest in civil cases during the session and 40 days before and after. However, this privilege does not extend to criminal matters, preventive detention, or national security issues.
- Application: The MLA is accused of a financial scam, which is a criminal offense. Therefore, the MLA does not enjoy immunity from arrest.
- Procedural Requirement: While the arrest is legal, the arresting authority is constitutionally and procedurally obligated to immediately inform the Speaker of the Legislative Assembly regarding the reasons for the arrest, the charges, and the place of detention.
- Conclusion: No breach of privilege has occurred regarding the arrest itself, provided the police immediately complied with the procedural requirement of informing the Speaker.
Scenario 2: Publication of Expunged Debates
Scenario: During a heated debate in the Lok Sabha, an MP makes highly defamatory and unparliamentary statements against a private citizen. The Speaker immediately expunges those remarks from the official record of the House. However, a local newspaper publishes the entire speech, including the expunged portion, the next morning. The MP claims protection under Article 105(2), while the citizen files a defamation suit against both the MP and the newspaper editor.
Analyze the liabilities of the MP and the Newspaper Editor.
- Ideal Answer Analysis:
- MP’s Liability: Under Article 105(2), the MP enjoys absolute immunity from legal proceedings for anything said on the floor of the House. Even though the remarks were defamatory and expunged, the MP cannot be sued in a court of law. Their conduct can only be disciplined internally by the Speaker.
- Newspaper’s Liability: While the Parliamentary Proceedings (Protection of Publication) Act, 1977 protects truthful reporting of parliamentary proceedings, this protection does not apply to expunged portions of a speech. By publishing remarks that the Speaker ordered to be expunged, the newspaper editor has violated the collective privilege of the House (the right to control its own proceedings and publications).
- Conclusion: The MP is protected by absolute constitutional immunity. The newspaper editor, however, is liable for both a breach of parliamentary privilege (for publishing expunged proceedings) and an ordinary civil/criminal defamation lawsuit by the private citizen, as the protection of publication does not extend to expunged content.
Section C: Match the Following / Chronology Exercise
Match the cases in Column A with their primary legal holdings in Column B:
| Column A (Case) | Column B (Primary Legal Holding) |
|---|---|
| 1. MSM Sharma Case (1959) | A. Redefined Article 105(2)/194(2) by establishing a two-fold test and declaring bribery as unprotected by legislative immunity. |
| 2. Keshav Singh Case (1965) | B. Upheld the power of the House to expel its members for misconduct but affirmed that legislative proceedings are subject to judicial review for gross illegality. |
| 3. Raja Ram Pal Case (2007) | C. Held that uncodified privileges are not subject to Article 19(1)(a) but must respect the fundamental rights under Article 21. |
| 4. Sita Soren Case (2024) | D. Clarified that legislative contempt power is subject to judicial review and cannot override the writ jurisdiction under Article 226/32 or Article 21. |
Correct Match:
1 -> C
2 -> D
3 -> B
4 -> A
Section D: Diagram-Based/Case-Based Reasoning
[ Allegation of Bribery Against a Lawmaker ]
|
v
[ Lawmaker claims Article 105(2) Immunity ]
|
v
[ Apply the Sita Soren Two-Fold Test ]
|
+------------------+------------------+
| |
[ Test 1: Is it closely [ Test 2: Is it essential for ]
tethered to the collective discharging the lawmaker's ]
functioning of the House? ] legislative duties? ]
| |
+------------------+------------------+
|
v
[ Answer to both: "NO" ]
|
v
[ Result: IMMUNITY IS DENIED BY THE COURT ]
[ Court trial under Prevention of Corruption Act ]
Reasoning Exercise:
Based on the flowchart above, explain why a legislator who accepts money to cross-vote in a Rajya Sabha election cannot claim immunity, even if they argue that the vote was cast inside the legislative chamber.
- Analysis:
Although the physical act of voting takes place inside the chamber, the 2024 Sita Soren ruling clarifies that the offense of bribery is completed outside the House the moment the bribe is accepted. Bribery is not essential to the performance of legislative duties, nor is it tethered to the collective functioning of the chamber. It fails both prongs of the test, meaning the court can prosecute the lawmaker under anti-corruption laws.
11. Conclusion & Key Takeaways
+----------------------------------------------------------------------------------+
| KEY TAKEAWAYS |
+----------------------------------------------------------------------------------+
| • Constitutional Pillars: Articles 105 and 194 establish legislative |
| privileges at the Union and State levels, respectively. |
| |
| • Functional Necessity: Privileges are meant to protect the independence of |
| the legislature, not to place individual lawmakers above ordinary laws.|
| |
| • Absolute Free Speech: Lawmakers enjoy complete immunity for their statements |
| and votes in the House, protecting them from civil or criminal lawsuits.|
| |
| • Limits of Immunity: Freedom from arrest is restricted to civil cases and is |
| not available for criminal offenses or preventive detention. |
| |
| • Sita Soren (2024) Ruling: The Supreme Court overruled the Narasimha Rao |
| precedent, holding that legislative immunity does not cover bribery. |
| Bribery is prosecuted under ordinary criminal law. |
| |
| • Judicial Review: Legislative actions and contempt orders are subject to |
| judicial review to prevent gross illegality and protect Article 21 rights. |
+----------------------------------------------------------------------------------+
Parliamentary privileges are a key element of India's constitutional design, balancing the functional independence of the legislature with the rule of law. While uncodified privileges provide the flexibility needed to protect legislative authority from executive overreach, they are not absolute. Through landmark rulings, culminating in the 2024 Sita Soren decision, the judiciary has consistently maintained that these immunities cannot be used to shield corrupt activities or violate fundamental constitutional rights. This ongoing balance helps ensure that legislative bodies remain representative, transparent, and accountable.
Recommended Books
You can explore these highly recommended resources for a deeper understanding.
- Indian Polity (English) by M Laxmikanth for UPSC CSE 2025 | 7th edition (latest) | Civil Services Exam - Prelims, Mains and Interview | State PSCs exams/ PCS exams - by M Laxmikanth
- Oswaal NCERT One For All Book for UPSC & State PSCs | Indian Polity Classes 6-12 - by Oswaal Editorial Board
- Bharat Ki Rajvyavastha (भारत की राजव्यवस्था) - M Laxmikanth for UPSC CSE
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