Exceptions to Article 14 of the Indian Constitution
Article 14 of the Indian Constitution: Right to Equality
Article 14 states:
"The State shall not deny to any person equality before the law or the equal protection of the laws within the territory of India."
In simple terms, Article 14 guarantees equality and prohibits arbitrary discrimination by the State.
Meaning of Article 14
Equality before the law: Equal treatment for all persons in similar circumstances, with no one above the law.
Equal protection of the laws: Equal application of laws to all persons similarly situated.
Are there exceptions to Article 14?
Yes. Article 14 prohibits arbitrariness and unreasonable discrimination, but it does not forbid classification or reasonable differentiation. Some exceptions allow reasonable classifications if they fulfill the following conditions:
Intelligible Differentia:
The classification must be based on an intelligible or rational difference that distinguishes persons or things grouped together from others left out of the group.
Rational Nexus:
The classification must have a rational relation or nexus with the object or purpose of the legislation.
This means classifications that are reasonable and serve a legitimate state objective are allowed, and do not violate Article 14.
Exceptions/Permitted Classifications under Article 14
1. Reasonable Classification
The law can differentiate between groups, provided the classification is reasonable and serves a legitimate purpose.
Example: Different tax rates for different income groups.
2. Special Provisions for Backward Classes
The Constitution permits special treatment for socially and educationally backward classes under Articles 15(4) and 16(4). These are affirmative action measures and are exceptions to strict equality.
3. Classification Based on State Interest
Certain classifications are allowed for administrative convenience, such as distinctions in government jobs, educational quotas, etc.
4. Emergency Provisions
During emergencies, certain fundamental rights can be suspended or restricted, but with judicial oversight.
5. Protective Discrimination
For example, laws protecting Scheduled Castes, Scheduled Tribes, and minorities from discrimination or providing benefits.
Important Case Laws on Exceptions to Article 14
1. State of West Bengal v. Anwar Ali Sarkar (1952)
The Court struck down a law which allowed the government to detain persons involved in strikes without trial.
The law was held arbitrary and violative of Article 14.
This case established that arbitrariness violates Article 14.
2. E.P. Royappa v. State of Tamil Nadu (1974)
The Supreme Court held that arbitrariness is the negation of equality.
Any law or state action must pass the test of reasonableness and non-arbitrariness.
3. Ram Krishna Dalmia v. Justice S.R. Tendolkar (1958)
The Court stated that Article 14 does not mean "that every person must be treated in the same way," but that no person shall be treated differently without reasonable justification.
4. Maneka Gandhi v. Union of India (1978)
The Court expanded the scope of Article 14 and held that procedure established by law must be just, fair and reasonable, and any arbitrary procedure would violate Article 14.
5. Krishna Ramachandra v. Union of India (1966)
The Court upheld different classes of employment (permanent vs. temporary) and said such classification is permissible if it is reasonable.
6. State of Kerala v. N.M. Thomas (1976)
Affirmed that classification for affirmative action (reservations) is valid and does not violate Article 14.
7. Indra Sawhney v. Union of India (1992)
The Supreme Court upheld reservations for backward classes but ruled that classification must be based on objective criteria and must not be arbitrary.
Summary: When is Classification under Article 14 Valid?
| Requirement | Explanation |
|---|---|
| Intelligible Differentia | There must be a clear and understandable basis for classifying people or things into groups. |
| Rational Nexus | The classification must be logically connected to the objective of the law or policy. |
| Non-Arbitrariness | The classification should not be arbitrary, whimsical, or discriminatory without basis. |
What is NOT Allowed?
Arbitrariness or capriciousness in classification.
Classifications based on irrelevant or extraneous considerations.
Discrimination that violates fundamental rights without reasonable justification.
Conclusion
Article 14 ensures equality before law but does not prohibit reasonable classification for achieving legitimate state goals. The courts have emphasized that arbitrariness is the real enemy of equality.
Reasonable classification is a recognized exception to Article 14, provided it passes the twin tests of intelligible differentia and rational nexus.
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