Reasonable Classification

Notes

Art. 14 forbids class legislation (arbitrary discrimination) but permits reasonable classification for legislative purposes. Treating all people identically would itself be unequal, because people differ in circumstances.

Twin tests (State of West Bengal v Anwar Ali Sarkar, 1952; Budhan Choudhary v State of Bihar, 1955):

Intelligible differentia: the classification must rest on a clear basis that distinguishes the group from those left out.
Rational nexus: the differentia must have a rational relation to the object sought to be achieved by the law.

Landmark cases

Anwar Ali Sarkar (1952): a law letting the government send selected cases to special courts with different procedure, without guidelines, was struck down as discriminatory.
Ram Krishna Dalmia v Justice Tendolkar (1958): a law is presumed constitutional; the burden is on the challenger. The legislature understands the needs of its people. A single individual or company can be a class if special circumstances apply.
Budhan Choudhary (1955): laid down the classic twin tests.
In re Special Courts Bill (1979): classification need not be scientifically perfect or logically complete.
Royappa (1974) and Maneka Gandhi (1978) added the arbitrariness test beyond classification.

Permissible grounds (examples): age, sex, geographical location, nature of business, profession, educational qualification, economic condition, income-tax slabs, State and Union territory distinctions.

Impermissible: classification that is purely arbitrary, based on whim or without any object, or is vague and gives uncontrolled discretion to officers.

Related ideas

Positive discrimination (reservation) is permitted because the Constitution itself provides for it (Art. 15(3), 15(4), 16(4)).
Equals must be treated alike, unequals unequally.
Over-inclusion and under-inclusion do not by themselves invalidate a law.

Key Points

Two tests: intelligible differentia and rational nexus.
Class legislation is banned; reasonable classification is allowed.
Presumption of constitutionality of statutes (Dalmia).
Arbitrariness is a second, independent ground of attack.
Anwar Ali Sarkar (1952) is the leading case on special courts.

MCQs

Q1. The tests of reasonable classification under Art. 14 are:
(a) Compelling interest and strict scrutiny
(b) Intelligible differentia and rational nexus
(c) Clear and present danger
(d) Basic structure and essential features
Ans: (b).

Q2. Which case laid down that there is a presumption of constitutionality of a statute under Art. 14?
(a) Ram Krishna Dalmia v Tendolkar
(b) Kesavananda Bharati
(c) Minerva Mills
(d) Shreya Singhal
Ans: (a). Ram Krishna Dalmia (1958).

Q3. Consider: (1) Art. 14 prohibits class legislation. (2) Art. 14 permits reasonable classification. Which is correct?
(a) 1 only
(b) 2 only
(c) Both 1 and 2
(d) Neither
Ans: (c).