Article 14 As an Ingredient of Principles of Natural Justice
✅ What is Article 14?
Article 14 guarantees equality before the law and equal protection of the laws.
In simple terms, it means:
The state cannot treat people unequally or act arbitrarily.
Every individual must be treated fairly and without discrimination.
✅ What are Principles of Natural Justice?
These are basic legal principles to ensure fairness in legal and administrative actions. The two main principles are:
"Audi Alteram Partem" – Right to a fair hearing (hear the other side).
"Nemo Judex in Causa Sua" – No one should be a judge in their own case (impartiality).
Now, let’s connect the dots.
🔗 How is Article 14 an Ingredient of Natural Justice?
Article 14 and natural justice both aim to prevent arbitrary, biased, or unfair decisions.
Here's how Article 14 supports Natural Justice:
| Article 14 Focus | Natural Justice Focus | Connection |
|---|---|---|
| No arbitrary action | Right to be heard | Ensures decisions are not one-sided |
| Equal treatment | Impartial decision-makers | Avoids bias and favoritism |
| Fairness in state actions | Procedural fairness | Protects individual rights from abuse |
🧑⚖️ Key Case Law: Article 14 & Natural Justice
1. Maneka Gandhi v. Union of India
Facts: Maneka Gandhi’s passport was impounded without giving her a chance to be heard.
Issue: Was it fair to take such action without hearing her?
Held: The court said Article 14 includes a guarantee against arbitrary state action. It also linked this to natural justice, especially the right to be heard.
Principle: Any action that affects rights must follow fair procedure — combining Article 14 with natural justice.
2. E.P. Royappa v. State of Tamil Nadu
Facts: A civil servant was transferred in a seemingly unfair way.
Held: The court said equality (Article 14) is violated if state action is arbitrary, and arbitrariness is the enemy of equality.
Principle: Any unfair, biased, or non-transparent process violates Article 14 and natural justice.
3. A.K. Kraipak v. Union of India
Facts: A person was selected for a public job, but one of the selectors had a personal interest.
Held: Fairness and absence of bias are essential, even in administrative decisions.
Principle: Natural justice applies even in non-judicial actions, and Article 14 supports this by requiring fairness and equality.
🧠 In Simple Words:
Think of Article 14 as the constitutional foundation for all fair treatment.
If natural justice says:
“You must be heard, and decisions must be fair,”
Then Article 14 says:
“The government must always be fair and treat everyone equally — even in small decisions.”
So, when a government officer acts unfairly, or if someone is punished without hearing, both Article 14 and Natural Justice are violated.
📝 Summary:
Article 14 ensures no arbitrary action by the state.
Principles of natural justice ensure fair procedure and no bias.
Courts have repeatedly said that fairness and non-arbitrariness (Article 14) are essential parts of natural justice.
Key cases: Maneka Gandhi, Royappa, Kraipak.
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