Article 14 of the Indian Constitution with Important Case Laws | Important Acts and Laws for Judiciary Exams PDF Download

Right to Equality in the Indian Constitution

• Article 14 of the Indian Constitution guarantees the right to equality. It prohibits discrimination and ensures equality before the law for all individuals.
• Articles 15 to 18 further elaborate on specific aspects of equality not covered by Article 14, thereby reinforcing the principle of equality.

Equality Before Law and Equal Protection of Laws

• Equality Before Law: This concept ensures that every individual, regardless of their status or position, is subject to the same laws. No one is exempt from legal provisions.
• Equal Protection of Laws: It mandates that similar cases should be treated alike, emphasizing fairness and consistency in the application of laws. Individuals in similar circumstances should receive similar treatment under the law.

Illustrative Examples

• Equality Before Law Example: If a wealthy individual commits a crime, they are subject to the same legal process as any other citizen. Their financial status does not grant them immunity.
• Equal Protection of Laws Example: In a workplace, all employees should be entitled to the same rights and protections regardless of their background or characteristics. Discrimination based on irrelevant factors like gender or race is not permissible.

Understanding Reasonable Classification under Article 14

Article 14 of the Indian Constitution and Class Legislation

• The Indian Constitution, through Article 14, prohibits class legislation.
• However, it allows for reasonable classification of individuals, objects, or transactions by the Legislature to achieve specific goals.

Criteria for Reasonable Classification

• The classification should not be arbitrary, artificial, or evasive.
• It must be based on intelligible differentia, indicating a real and substantial distinction between the grouped entities and those excluded.
• The classification based on differentia should have a rational or reasonable connection with the objective intended by the relevant statute.

Example to Illustrate Reasonable Classification

• Consider a law that provides benefits to senior citizens but not to individuals below a certain age threshold.
• Here, the classification is based on age, a valid differentia, with a rational nexus to the goal of supporting the elderly.

Landmark Judgements

• Chiranjit Lal Chowdhury v Union of India: The case involved a challenge to the constitutionality of the Sholapur Spinning and Weaving Company (Emergency Provisions) Ordinance, 1950, which allowed the government to take over a company's management. The court ruled that laws can be applied to specific individuals or groups if there is a valid reason for such application.
• Basis of Classification: Classifications must be based on intelligible differentia, such as geographical area, sex, financial status, nature of offense, or disabilities, to be considered reasonable.
• Dharmendra Kirthal v State Of UP: This case upheld the classification of trying accused individuals under the Uttar Pradesh Gangsters and Anti-Social Activities (Prevention) Act, 1986, in a Special Court, emphasizing the need for stringent measures against organized crime.
• Baburao v Bombay Housing Board: The court validated a provision exempting lands or buildings belonging to the Bombay Housing Board from certain regulations, stating that treating the State differently from individuals does not violate equal protection under Article 14.
• Javed v. State of Haryana: The case upheld a provision disqualifying individuals with more than two children from contesting Panchayat elections, deeming it non-discriminatory due to its connection to the promotion of family planning.
• India Council of Legal Aid and Advice v Bar Council of India: The Supreme Court struck down a rule barring individuals above 45 years from applying for advocate enrollment, ruling it discriminatory as it lacked a reasonable nexus and violated the right to equality.
• Caterpillar India (P) Ltd. v. Western Coalfields Ltd: The court criticized a preference policy favoring Public Sector Enterprises in tenders, highlighting that classifications should not be based on minor differences and must be reasonable.
• LIC of India v. M.V. Valliapan: The Supreme Court cautioned against excessive focus on classification, emphasizing that equity under Article 14 should not be eroded by overemphasis on classification.

Concept of Arbitrariness

• E.P. Royappa v State of Tamil Nadu and Anr.: The court emphasized that Article 14 guards against arbitrariness, stating that arbitrary actions violate equality principles enshrined in the Constitution.
• R.D. Shetty v. International Airport Authority: The court found the actions of the International Airport Authority discriminatory for awarding a contract based on unjust conditions, denying equal opportunities to similarly qualified contractors.
• Air India v. Nergesh Meerza: Regulations requiring the retirement of air hostesses upon pregnancy were deemed discriminatory, as they presented unreasonable grounds for termination not aligned with Article 14.
• D.S. Nakara v. Union of India: Rule 34 of the Central Services rules was struck down for irrational classification between pensioners retiring before and after a specific date, highlighting the need for reasonable and non-arbitrary classifications.

These landmark judgements and interpretations of Article 14 by the Indian judiciary aim to eliminate arbitrariness in state actions and broaden the understanding of equality under the law.