Correct Option (D):
Following the provincial elections of 1937, conducted under the provisions of the Government of India Act, 1935, the Indian National Congress did not form a ministry in Punjab. In Punjab, the Unionist Party, led by Sir Sikandar Hayat Khan, formed the government with the support of the Muslim League and Akalis.
Incorrect Options:
The Indian National Congress formed ministries in Bihar, Madras, and Orissa after securing a majority or forming a coalition in the 1937 provincial elections. These provinces were among the eight where Congress ministries were established, reflecting their significant electoral performance under the Government of India Act, 1935.