Vaishno Devi Shrine Board not “State” under Art. 12 Despite Statutory Status; Lacks Governmental Control: J&K and Ladakh HC
“The guiding factor is the nature of duty imposed upon the person or body against whom a writ is being sought. If the nature of duty imposed on a body is public in nature, it is amenable to writ jurisdiction under Article 226 of the Constitution but if the rights sought to be enforced are purely of a private character, a writ cannot be issued against such body.”

