According to article 12 which of the following can be termed as State?...
States include:
(a) Government and Parliament of India, that is executive and legislative organs of the Union government.
(b) Government and legislature of states, that is, executive and legislative organs of state government.
(c) All local authorities, that is, municipalities, panchayats, district boards, improvement trusts, etc.
(d) All other authorities, that is, statutory or nonstatutory authorities like LIC, ONGC, SAIL, etc.
Thus, the State has been defined in a wider sense to include all its agencies. It is the actions of these agencies that can be challenged in the courts as violating the Fundamental Rights. According to the Supreme Court, even a private body or an agency working as an instrument of the State falls within the meaning of State Article 12.