SG: State of Karnataka written and oral submissions say governor is bound by ministerial advice, and Article 163 requires Governor to act by and under discretion only under certain circumstances. They treat these instances as exhausted.

I have already told that all these judgments are illustrative and not exhaustive. But it was sought to be read as exhaustive.

no mandamus can be issued to Governor- direct judgment in AK Roy- three categories of cases when Governor power is concerned- purely executive. Mylords have said that even in cases of A. 365 and in pardon, judicial review is read but very restrictively.

Second is legislative power like Article 200-the issue of justiciability of Governor's function must receive a nuanced interpretation...the question of denial assent or reserve is not akin to executive power. The following factors need to be considered, prescription of timelines, quashing of reference to President, quashing of decision to refer to resort to first proviso, direction to withdraw the reference.

AK Roy judgment read: Bill became Act but central government did not notify, therefore, a writ was filed to bring the law in force.