State of Tamil Nadu v. Junglee Games India Pvt. Ltd. 2026 INSC 594 - Online Rummy & Poker - TN & Karnataka Laws
Constitution of India - Article 19- Entry 34 List II ; Tamil Nadu Prohibition of Online Gambling and Regulation of Online Gaming Act, 2022/2023 - Tamil Nadu Gaming and Police Laws (Amendment) Act, 2021 -Karnataka Police (Amendment) Act, 2021 - States empowered to regulate and even prohibit betting on all games, including games of skill, when played for stakes, and the Entry is not confined to “betting on gambling” (chance‑based games only)- While playing a game of skill per se is protected under Article 19(1)(g), staking money on the uncertain outcome of any game amounts to betting/gambling, which is res extra commercium and therefore not a protected business, and also that public‑order and public‑health entries support such legislation given the documented harms of online money gaming. [Context: Supreme Court upholds Constitutional validity of the Tamil Nadu and Karnataka amendments, and parts of the TN Online Gambling Act 2022/23]
Constitution of India -Entry 1 - Public Order - A state of tranquility prevailing amongst members of a political society as a result of internal regulations enforced by the Government; The absence of disorder; A positive condition of peaceful, ordered social existence enabling normal civic life; Public order denotes an orderly state of society and community in which citizens may peacefully pursue their normal activities of life; Public order is reflected in the “even tempo” of life in a locality. Therefore, conduct that maintains or secures this even tempo falls within the realm of public order regulation; Public safety or interest may, depending upon context, be legitimately invoked in its relation to the maintenance of public order to support legislative action preserving public order; Public order occupies a constitutional position between the widest circle of “law and order” and the narrowest circle of “security of the State”, signifying a broader societal impact rather than individual disturbances but less in magnitude when compared to threats to security of the State.- Correspondingly, disruption or disturbance of public order public order arises in the following situations: a) An act disturbs public order when it affects the current or even tempo of the life of the community, rather than merely injuring an individual; b) When repercussions of an act extend to large sections of the community, inciting further breaches of law and order or provoking communal passions, public order is subverted; c) Activities that impair public health or constitute a manifest nuisance fall squarely within the State’s competence under public order; d) Activities that cause detriment of health, tranquility and comfort of others; e) If something disturbs the current of the life of the community, and does not merely affect an individual; f) Conduct which induces fear or panic in the community such that ordinary pursuits of life are abandoned becomes a matter of public order even if the immediate act is aimed at a particular individual; g) Disturbances in the social or economic spheres that shake the orderly functioning of society, including largescale financial defaults undermining public confidence, may also constitute breach of public order.(Para 359)
