Article 14 of Indian Constitution
Article 14 of the Indian Constitution: Equality Before Law
Text of Article 14:
"The State shall not deny to any person equality before the law or the equal protection of the laws within the territory of India."
What does Article 14 mean?
Article 14 guarantees two essential concepts:
Equality Before the Law:
This is a negative concept which means that no person is above the law and everyone, whether rich or poor, is equal in the eyes of the law.
Equal Protection of the Laws:
This is a positive concept meaning that the state must apply the laws equally and impartially to all persons similarly placed.
Key Principles
No Arbitrary Discrimination:
The state cannot treat people arbitrarily or unfairly.
Reasonable Classification:
Article 14 does not mean absolute equality but equality in relevant and similar circumstances. Reasonable classification is permitted, provided:
The classification is based on an intelligible differentia (clear distinguishing feature).
The differentia has a rational relation to the object of the law.
Judicial Interpretation & Landmark Case Laws
State of West Bengal v. Anwar Ali Sarkar (1952) AIR 75
Facts: The West Bengal government enacted a law to close certain mills and exempted others arbitrarily.
Holding: The Supreme Court struck down the law as violating Article 14 because the classification was arbitrary and had no reasonable basis.
Significance: Introduced the doctrine that the classification must have a "reasonable relation to the object of the Act."
E.P. Royappa v. State of Tamil Nadu (1974) 4 SCC 3
Facts: The case dealt with the dismissal of a government servant on alleged misconduct.
Holding: The Supreme Court expanded the concept of equality to include the absence of arbitrariness. Arbitrariness is against Article 14.
Famous Statement: "Equality is a dynamic concept with many aspects and shades."
Maneka Gandhi v. Union of India (1978) AIR 597
Facts: Maneka Gandhi’s passport was impounded without providing reasons.
Holding: The Court held that Article 14 applies to all laws including those affecting personal liberty under Article 21.
Significance: It merged Articles 14, 19, and 21 to ensure fairness and reasonableness in all laws.
Jai Ram Reddy v. The State of Fiji (1985) (Foreign Case but influential)
Emphasized that Article 14 prohibits laws that are arbitrary, discriminatory, or unfair.
Indra Sawhney v. Union of India (1992) 3 SCC 217 (Mandal Case)
The Supreme Court allowed reservation for backward classes but stressed that classification must not be arbitrary or unreasonable.
The Court laid down guidelines on classification and reservations under Article 14.
Reasonable Classification and Exceptions
Article 14 allows the state to classify people into groups if the classification:
Is not arbitrary,
Has an intelligible differentia,
Has a rational nexus with the object of the statute.
For example, laws that provide different benefits to children and adults, or impose different taxes on different goods, are examples of reasonable classification.
Difference Between Equality Before Law and Equal Protection of Laws
Equality Before Law:
Everyone is subject to the same law irrespective of their status.
Equal Protection of Laws:
Equal laws are applied equally without discrimination.
Summary
Article 14 is a fundamental right protecting against unfair discrimination.
Absolute equality is not required; rather, reasonable and justifiable classification is allowed.
The Constitution prohibits arbitrariness and mandates fairness in lawmaking and enforcement.
Over the years, the Supreme Court has expanded and clarified the scope of Article 14, emphasizing fairness and reasonableness as integral parts of equality.
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