“A law may be constitutional even though it relates to a single individual if, on account of some special circumstances or reasons applicable to him and not applicable to others, that single individual may be treated as a class by himself.”. Explain the valid test of reasonable classification under Article 14 of the Constitution Chiranjeet Lal Chaudhari v. Union of India and evaluate the Supreme Court decisions dealing with laws made for single individuals and those creating Special Courts.

Question: “A law may be constitutional even though it relates to a single individual if, on account of some special circumstances or reasons applicable to him and not applicable to others, that single individual may be treated as a class by himself.”. Explain the valid tests of reasonable classification under Article 14 of the Constitution Chiranjeet Lal Chaudhari v. Union of India and evaluate the Supreme Court decisions dealing with laws made for single individuals and those creating Special Courts. [BJS 1986]

Find the answer to the mains question only on Legal Bites. [Explain the valid test of reasonable classification under Article 14 of the Constitution Chiranjeet Lal Chaudhari v. Union of India and evaluate the Supreme Court decisions dealing with laws made for single individuals and those creating Special Courts. [BJS 1986]

Answer

Article 14 of the Indian Constitution reads as the state shall not deny to any person equality before the law or the equal protection of the laws within the territory of India. This article has two limbs –

1. equality before the law
2. equal protection of the law.

For society to progress a reasonable classification is not only permitted but also necessary and in that regard, Article 14 supports reasonable classifications and forbids class legislation.

The article applies on a reasonable basis, equals are treated differently and do not apply where unequal and equals are given different treatments. Conferring particular privileges upon a class of persons, class legislation makes improper discrimination by selecting a large number of persons arbitrarily. No reasonable or substantial difference can be found in justifying the exclusion of the one and the inclusion of the other from such privilege.

The provision guarantees equal protection of laws and this was elaborately explained in the case of Chiranjeet Lal Chaudhari v. Union of India (1950 SCR 869) and R. K Dalmia v. Tendolkar (1958 AIR 538). These cases explain the true scope and meaning of the right to equality and hold a valid classification by laying down the following propositions:

1. Even though relating to an individual person, a law would be constitutional if on account of some reasons or special circumstances is applicable to him and not applicable to others. The individual person can be treated as a class.
2. There is a dependable assumption in favour of the constitutionality of a rule and the burden is upon him who attacks it to demonstrate that there has been a reasonable transgression of established constitutional standards.
3. The assumption might be disproved in specific cases by showing that on the fact of the statute, there is no order and no distinction peculiar to any individual or class and not applicable to any other individual or class, and yet the law hits a specific individual or class.
4. It must be assumed that the legislature accurately acknowledges and comprehends the need of its own people that its law is directed to the problem made manifest by involvement and that its discrimination is based on satisfactory grounds.
5. So as to continue the assumption of constitutionality the court may take into consideration matters of basic knowledge, matters of the report, the historical backdrop of the times and may expect each condition of facts which can be conceived existing at the time of the enactment.
6. Thus the legislation is allowed to perceive degrees of harm and may confine its limitation to those situations where the need is considered to be the clearest.
7. While good faith and knowledge of the current conditions with respect to a legislature are to be assumed, if there is nothing on the substance of the law or the surrounding conditions brought to the notice of the court on which the classification may reasonably be viewed as biased, the assumption of constitutionality can’t be conveyed to the degree dependably that there must be some undisclosed and obscure explanation behind exposing certain people or organization to be unfriendly or discriminating legislation.

In essence, classification to be reasonable must fulfil the following two conditions:

• Firstly, the classification must be founded on the intelligible differentia which distinguishes persons or thing that are grouped together from others left out of the group
• Secondly, the differentia must have a rational relation to the object sought to be achieved by the act.

The differentia which is the basis of the classification and the object of the act are two distinct things. It is necessary that there must be nexus between the basis of classification and the object of the act which makes the classification. It is only when there is no reasonable basis for a classification that legislation making such classification may be declared discriminatory.

This can be understood by the case of Sanaboina Satyanarayan v. Govt. of A.P. In this case, the state of Andhra Pradesh formulated a scheme for the prevention of crime against women. In prisons also prisoners were classified into two categories first Prisoners guilty of a crime against women and second prisoners who are not guilty of a crime against women. Prisoners who are guilty of a crime against women challenge the court saying that their right to equality is deprived. Court held that there is reasonable classification to achieve some objective.

Similarly, the Karnataka High Court in K. Veeresh Babu v. UOI (1994), the case held that a provision exempting Sikhs from compulsorily wearing a Helmet, when riding a motorcycle, is not violative of Article 14 of the Constitution. Thus, what Article 14 prohibits is class legislation and not a classification for the purpose of the legislation.

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Important Mains Questions Series for Judiciary, APO & University Exams

1. Constitutional Law Mains Questions Series Part-I
2. Constitutional Law Mains Questions Series Part-I
3. Constitutional Law Mains Questions Series Part-II
4. Constitutional Law Mains Questions Series Part-IV
5. Constitutional Law Mains Questions Series Part-V
6. Constitutional Law Mains Questions Series Part-VI
7. Constitutional Law Mains Questions Series Part-VII
8. Constitutional Law Mains Questions Series Part-VIII
9. Constitutional Law Mains Questions Series Part-IX
10. Constitutional Law Mains Questions Series Part-X