The Ravi Khokhar & Ors v. Union of India & Ors., decided by the Supreme Court of India, expanded the scope of Article 12 by holding that the Air Force Group Insurance Society (AFGIS) qualifies as “State.” The dispute arose when AFGIS employees challenged the Society’s decision to delink its pay structure from Central Pay Commission recommendations. While the Delhi High Court treated AFGIS as a private welfare body, the Supreme Court adopted a functional approach rather than a formal ownership test. The Court applied the public function, instrumentality, and deep and pervasive control tests, observing that AFGIS performs welfare functions closely connected to sovereign duties of the armed forces. Its establishment with presidential sanction, compulsory membership for Air Force personnel, and administration by serving officers demonstrated strong governmental integration and control. Holding that performance of public duties outweighs funding structure, the Court ruled that AFGIS is amenable to writ jurisdiction. The High Court’s judgment was set aside, and writ petitions were directed to be heard on merits, reinforcing accountability of quasi-governmental bodies.