Case Brief: E.P Royappa v. State of Tamil Nadu and Anr
Case Brief: E.P. Royappa v. State of Tamil Nadu and Anr
Citation: AIR 1974 SC 555
Court: Supreme Court of India
Year: 1974
Facts:
E.P. Royappa, a government servant, was suspended by the State of Tamil Nadu without following the principles of natural justice properly. He challenged the suspension order in court, arguing that it was arbitrary and violated his fundamental rights.
Issues:
Whether the suspension order was arbitrary and violative of Article 14 of the Constitution of India (Right to Equality).
The scope and meaning of "arbitrariness" under Article 14.
Judgment:
The Supreme Court held that the suspension order was arbitrary and thus violated Article 14. The Court emphasized that arbitrariness is opposed to the rule of law and the equality clause under the Constitution.
Key Points / Ratio Decidendi:
Arbitrariness violates Article 14: The Court stated that Article 14 not only prohibits classification without reasonable basis but also prohibits arbitrary state action.
Equality under law means absence of arbitrariness: The judgment highlighted that equality is a dynamic concept and arbitrariness is the antithesis of equality.
Rule of Law: The Court underscored that the rule of law means governance according to law, excluding arbitrariness or whim.
Natural Justice: Administrative actions must be fair, just, and reasonable.
Significance:
This case expanded the interpretation of Article 14 by emphasizing the prohibition of arbitrary action by the state.
It reinforced the principle that state power must be exercised reasonably, fairly, and within the limits of law.
E.P. Royappa is a landmark judgment that shaped the Indian judiciary's approach to arbitrariness and equality.
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