STATE OF MADRAS V. CHAMPAKAM DORAIRAJAN (1951)

 

STATE OF MADRAS V. CHAMPAKAM DORAIRAJAN (1951)

State of Madras v. Champakam Dorairajan, AIR (1951) SSC 226.

Landmark case on Indian Constitutional Law.

 

This case analysis is written by - Imra Fatima, B.A.LL.B (H),S.S Khanna Girls' Degree College, University of Allahabad.

Judgement delivered by- S.R. Das

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ABSTRACT

The case, State of Madras v. Champakam Dorairajan, is a landmark case which involved the conflict between Fundamental Rights guaranteed to the citizens in the Constitution and the Directive Principles of State Policy which are the guidelines for the states. This case led to the first ever Constitutional amendment in the history of the Republic of India. In this case the petitioner filed a petition in the High Court of Madras to challenge the state of Madras for denying her admission in medical college due to the State's reservation policy. This reservation policy existed before independence, issued under Communal Government Order (GO), under Madras Presidency Act, in 1927. The case involved Articles 15(1) , 29(2) and 46 of the Indian Constitution. The Supreme Court gave an important ruling that the Directive Principles of State Policy (DPSP) cannot override Fundamental Rights. The judgment of this case has also moulded the country's future reservation policies and provisions. The decision of the case led to the country's very first amendment act in 1951 which added Clause (4) to Article 15 of the Constitution.

 

PRIMARY DETAILS OF THE CASE

Case name	State of Madras v. Champakam Dorairajan
Case brought by	Writ Petition
Writ petition number	5255 and 5340 of 1950
Petitioner	Champakam Dorairajan
Respondent	State of Madras
Jurisdiction involved	Supreme Court of India
Authority	Appellate Jurisdiction
Legal aspects involved	Article 15(4), 29(2) and 46 of the Constitution
Date of judgment	9th April, 1951
Area of Law	Constitutional law
Amendment	Added Clause (4) to Article 15
Bench	Hiralal J. Kania, Saiyid Fazal Ali, Mehr Chand Mahajan, Vivian Bose, B.K. Mukherjea
Significance	Shaped the Country's future reservation policy

  

BRIEF FACTS OF THE CASE 

During the pre-independence period, the State of Madras issued the Communal Government Order under the Madras Presidency Act, 1927. The order executed the first ever reservation policy based on religion and caste. This reservation applied to a certain number of government engineering colleges and four government medical colleges within Madras. It had its own criteria for allotting seats based on reservation rather than an entrance exam. The seats were allotted in the following manner out of every fourteen seats available:

 

Non- Brahmins	6
Backward castes	2
Brahmins	2
Harijans	2
Anglo-Indians	1
Muslims	1

This reservation system was followed for admitting people into government universities and in the matters of public employment. This is also known as Collective Government Order. Due to this reservation policy, a meritorious student in 1950 named Shrimati Champakam Dorairajan was denied admission in a government medical college. Therefore she filed a petition under Article 226 of the Constitution in the High Court of Madras challenging the Constitutional validity of this Government Order(GO). She filed this petition on the ground that her constitutional rights were violated which is guaranteed under Article 15(1) and 29(2) of the Constitution.

The State of Madras in the High Court of Madras presented that such a reservation policy was implemented keeping in mind Article 46 of DPSP which is to promote the educational interests of Scheduled Castes, Scheduled Tribes and other weaker sections of the society. But the High Court struck down this GO and further the case was brought before the Apex Court by the State of Madras challenging the decision of the High Court.

ISSUES INVOLVED IN THE CASE

 Following were the issues involved in the case:

 

1)     The major issue involved in the case of State of Madras v. Champakam Dorairajan was to maintain harmony between Fundamental Rights and the Directive Principles of State Policy. The Court decision must be held as a strong precedence to take reference for future cases and conflicts.

2)     Another issue was to decide the Constitutional validity of the Communal Government Order. Such a provision must be in execution even after the enforcement of the Constitutional provisions was an essential question that demanded attention.

3)     The last issue was to rule on the violation of rights of equality and non- discrimination as mentioned in the Constitution, which was faced by the petitioner.

 

 

ARGUMENTS OF THE PARTIES

ARGUMENTS RAISED BY THE APPELLANT

 The arguments of the appellant centered on Article 46 of the Constitution. According to the appellant, it is the duty of the state to ensure social justice to all its citizens. Also, it is the duty of the state to look upon the interests of the weaker sections of the society as well so that they are not deprived of their interests. Therefore, Communal Government Order that was issued by the state of Madras is parallel to the provisions of the Constitution as in Article 46, the Constitution mandates that it is the duty of the state to promote educational and economic interests of the weaker sections of the society particularly the Scheduled Castes and the Scheduled Tribes so that they do not face social injustice and discrimination. Hence, this order was necessary to promote the interests of the weaker classes.

 They further contended that the Directive Principles of State Policy supersedes the Fundamental Rights of the Constitution. Therefore there is no violation of any Constitutional right particularly Article 15(1) and 29(2) of the Constitution because it was essential to implement Article 46 to promote interests of the weaker classes and this GO was aimed at broader social objectives.

 

ARGUMENTS RAISED BY THE RESPONDENT

 The arguments of the respondent circumscribe the Communal Government Order and the infringement of the Fundamental Rights due to its enforcement. The respondent contended that such a system of allotting seats based on reserving the seats for SCs, STs and other economically weaker classes is against the principle of social justice, indiscrimination and has deprived her of the right to equality, especially the violation of Article 15(1) of the Constitution the says “The State shall not discriminate against any citizen on the grounds only of religion, race, caste, sex, place of birth or any one of them.”

The respondent further contended that she has been denied the right of equal education opportunities guaranteed under Article 29(2) which says that “No citizen shall be denied admission into any educational institution maintained by the State or receiving aid out of State funds on grounds only of religion, race, caste, language or any of them.”

 

LEGAL ASPECTS INVOLVED IN THE CASE

The following Articles of the Constitution were in question in the case of State of Madras v. Champakam Dorairajan-

 

1)     Article 13- Article 13 of the Constitution states that all the laws inconsistent or in derogation with the Fundamental Rights must be void to the extent of that inconsistency.

2)     Article 14- This Article provides for equality before law or the equal protection of laws within the territory of India.

3)     Article 15(1)- This Article states that the State shall not discriminate against any citizen on the grounds of caste, sex, race, religion, place of birth or any one of them.

4)     Article 16(4)- This Article authorizes the State to make provisions for reservation for backward classes of citizens in matters of public employment who are not adequately represented.

5)     Article 29(2)- This Article prohibits discrimination of any type for admission into educational institutions maintained by state or receiving aid out of state funds.

6)     Article 46- This Article is under Part 4 of the Constitution (DPSP) which places a duty on the state to promote interests of the weaker section of the people.

 

 JUDGMENT OF THE CASE

The verdict was delivered by Justice S.R. Das who upheld the decision of the Madras High Court and regarded this Communal Government Order as unconstitutional and violating the Fundamental Rights of the citizens. The Court held the importance of Article 29(2) and stated that no discrimination can be made in matters of educational interests.

The Supreme Court upheld that the Fundamental Rights takes precedence and the reservation policy violated the fundamental rights of the citizens particularly Article 15(1) and 29(2) of the Constitution. Further the Court stated that the Directive Principles of State Policy cannot override or supersede the Constitutional provisions under the head of Fundamental Rights. The Court said that the directive principles are ancillary or supplementary to the fundamental rights. The Court referred to the Article 37 under DPSP which states that DPSP is not enforceable but crucial for ensuring welfare of the society and it is the duty of the state to apply them to benefit the citizens.

The Court decided for a Constitutional Amendment that added a Clause (4) in Article 15 which authorizes the state to make special provisions for socially and educationally backward classes of citizens or SCs and STs. This added the very first reservation policy in the Constitution.

 IMPACT AND SIGNIFICANCE

 The case: State of Madras v. Champakam Dorairajan holds special importance in the history of Indian Judiciary due to its significant constitutional amendment in 1951. The amendment added Clause (4) in Article 15 which provided for India's first ever reservation policy. This reservation policy was aimed at making special provisions for reservations for the advancement of socially and educationally backward groups of citizens and the scheduled castes and scheduled tribes. It was a sort of duty on the State to work on the interests of the weaker sections to promote their welfare. This amendment was in accordance with Article 46 of the Constitution. This amendment has provided a Constitutional basis for reservation in educational institutions.

 Another significance of the case was that it is considered as an important precedent that will be considered in all future cases and judicial interpretations that involve any kind of dispute between the directive principles and the fundamental rights. It has positively impacted the conditions of the marginalized communities in contemporary times.

 

CONCLUSION

The State of Madras v. Champakam Dorairajan is one of the most significant cases in Indian Constitutional Law. It has proved its importance in all the conflicts arising between the Fundamental Rights and Directive Principles of State Policy. The most important aspects of the case in the first constitutional amendment in 1951 and provision for a reservation policy in the interests of the weaker sections to promote their welfare and the burden of its implementation is on the shoulders of the State.

The case became a turning point in the history of Indian Constitution law by pronouncing a landmark judgment based on the supremacy of Fundamental Rights over DPSP. In the case, the courts emphasized the protection of the Right to Equality, Right against discrimination and the Right to Freedom.

However this case is most often cited in many debates, discussions and constructive criticisms to catch hold of the negative impacts of the reservation policy yet this remains a significant ruling on the part of Supreme Court to protect and protect the economic, social and educational interests of weaker sections of the society including the Scheduled Castes, Scheduled Tribes and other backward classes of citizens. The pronouncement of this decision has shaped many reservation policies.

 REFERENCES:

 1)     Constitution of India, 1950

2)     indiankanoon.org

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