Article 12 of the Indian Constitution defines โStateโ. In the initial years of Indiaโs independence, the notion of โstateโ was defined quite narrowly by the Supreme Court of India. It was only later that the Courts took a liberal view while interpreting โStateโ. Due to privatisation, there are more private organisations and corporations than ever before. It is essential that they fall under the definition of โStateโ in order to enforce fundamental rights against them and devolve liability in a way that escorts the devolvement of power and authority from traditional bases like governmental organs to private players. This article examines the evolving interpretation of the term โStateโ in the Indian Constitution in light of increasing privatization. It emphasizes the importance of safeguarding fundamental rights and explains how courts have expanded the definition of โStateโ to hold private entities accountable.