Class Legislation
1. Meaning of Class Legislation
Class Legislation refers to laws or rules that target a particular class of people, granting them special privileges or imposing burdens that do not apply to others in similar situations.
Such legislation is discriminatory if the classification is arbitrary and not based on intelligible differentia.
Essentially, it violates the principle of equality before law enshrined in Article 14 of the Indian Constitution.
2. Characteristics of Class Legislation
Classification:
The law distinguishes between different groups of people or property.
Purpose:
The law either confers benefits or imposes restrictions on a specific class.
Arbitrariness Test:
Classification is constitutionally valid only if:
It is based on intelligible differentia.
There is rational nexus between classification and objective of law.
Violation of Equality:
If classification serves no rational purpose or arbitrarily targets a group, it is unconstitutional class legislation.
3. Constitutional Provision
Article 14 – Equality Before Law:
“The State shall not deny to any person equality before the law or equal protection of the laws within the territory of India.”
Class legislation violates Article 14 if it discriminates without rational basis.
4. Legal Test for Class Legislation
Two-Part Test (from State of West Bengal v. Anwar Ali Sarkar):
Intelligible Differentia: Classification must distinguish persons or things that are really different.
Rational Nexus: Classification must have nexus with the object of the law.
If either part fails, the legislation is invalid as class legislation.
5. Important Case Laws
1. State of West Bengal v. Anwar Ali Sarkar (1952) AIR 1952 SC 75
Facts:
West Bengal passed a law imposing restrictions only on banks of a certain size, allowing others to operate freely.
Held:
Court struck down the law as class legislation, stating:
Classification had no rational nexus to the objective.
Law arbitrarily discriminated against a particular class.
2. E.P. Royappa v. State of Tamil Nadu (1974) 4 SCC 3
Significance:
Reinforced that arbitrariness is the antithesis of equality.
Any law arbitrary in classification or action is violative of Article 14.
3. Maneka Gandhi v. Union of India (1978) 1 SCC 248
Significance:
Strengthened the principle that laws must not be arbitrary, even in procedural matters.
4. State of Karnataka v. Umadevi (2006) 4 SCC 1
Significance:
Government policy favoring a particular group in employment appointments challenged.
Court held classification must have rational basis, else it amounts to class legislation.
6. Key Principles
| Principle | Explanation |
|---|---|
| Intelligible Differentia | Classification must distinguish real differences between classes |
| Rational Nexus | Classification must relate to the object of the legislation |
| No Arbitrary Discrimination | Law cannot favor or burden a class without reason |
| Equality Before Law | Article 14 prohibits class legislation lacking rational basis |
7. Conclusion
Class legislation is legislation that arbitrarily discriminates between classes of people, violating Article 14.
Valid classification requires:
Intelligible differentia between classes.
Rational nexus with legislative objective.
Key takeaway: All laws must treat equals equally and unequals unequally, in accordance with reason and justice.
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