The seminal ruling in champakam dorairajan vs state of madras (AIR 1951 SC 226) is a product of the Indian Supreme Court. The First Amendment to the Indian Constitution was added as a result of this ruling. It was the first significant reservation decision made by the Republic of India. The Government Order (G.O.) issued in the [Madras Presidency] in 1927 was overturned by the Madras High Court, and this result was upheld by the Supreme Court.
champakam dorairajan case summary
Champakam Dorairajan Case Facts:
- In 1950, there existed a quota system for college admission in Madras. The state-funded four medical facilities and four engineering colleges. Out of the fourteen seats that were available, six were given to non-Brahmins, two to Brahmins, two to Harijans, one to Anglo-Indians and Indian Christians, and one to Muslims.
- This was based on the 1927, shortly before independence, Communal Government Order (Communal G. O.) issued by the Province of Madras or Madras Presidency. Caste-based reservations were utilized to determine admission to government jobs and universities.
- The State of Madras contended that since the Communal Government Order was created in accordance with Article 46 of the Directive Principles of State Policy to advance the educational interests of SC, ST, and other marginalized groups in society, they were entitled to maintain and uphold it.
- A Brahmin named Shrimathi Champakam Dorairajan filed a lawsuit in the Madras High Court under Article 226, claiming that her fundamental right to college entrance had been infringed. She claimed that even with her strong academic record, she was turned down for admission to the Medical College.
Champakam Dorairajan Case Issues:
- When there is a disagreement between Directive Principles of State Policy and Fundamental Rights, which takes priority?
- Whether or not the Indian Constitution is in conflict with the Communal Government Order of 1927, and if it should remain in force after it was adopted?
Contentions raised by the Petitioner:
- According to Champakam Dorairajan, the Indian Constitution’s Article 15(1) guarantees her fundamental rights, which were violated by the reservation policy.
- She argued that the policy was unlawful since it discriminated against her just because of her caste.
- asserted as well that residents were treated unfairly because of the reservation policy on the basis of caste. She maintained that all people ought to be treated equally in the eyes of the law and that it was improper to classify people purely on the basis of their caste or religion.
- The petitioner contended that although Article 15(4) permitted the government to establish special measures for the less fortunate classes, it did not permit caste-based classification. She argued that the reservation policy should be reevaluated because it went beyond the parameters of Article 15(4).
Contentions raised by the Defendant:
- Maintaining social justice, the State of Madras contended that the quota policy was required to remedy the past injustices that some castes and groups had to endure. Its goals were to advance social fairness and improve the less fortunate social and educational strata.
- The argument put forth was that the policy would guarantee their fair representation in academic establishments.
- The State further contended that Article 15(4) of the Indian Constitution, which gives the government the authority to create special arrangements for the benefit of socially and educationally disadvantaged people, made the reservation decrees lawful. It insisted that the directives were intended to guarantee every person equal chances.
champakam dorairajan case judgment:
- The decision ofchampakam dorairajan case year is 9th April, 1951 having a 5-judge bench comprising of Justice Hiralal J. Kania, Justice Saiyid Fazal Ali, Justice Mehr Chand Mahajan, Justice Vivian Bose and Justice B.K. Mukherjea.
- It declared the contentious Communal Government Order, which supported a caste-based quota system, to be unconstitutional because it violated the Indian Constitution.
- The Court emphasized that fundamental rights are more valuable and have the highest priority. These Fundamental Rights are the cornerstone of the Constitution; no legislative or executive decree can supersede them, with the exception of those explicitly delimited by the relevant articles included in Part III of the Constitution.
- The Indian Constitution’s Fundamental Rights must not be violated, and the State must take care when enacting laws and regulations.
- The Court emphasized that although the Directive Principles of State Policy are significant, they cannot take the place of or supplant the Fundamental Rights. The Fundamental Rights are supplemented or augmented by these Directive Principles.
- The Supreme Court cited Article 37 of the Indian Constitution, which makes it clear that the Directive Principles of State Policy and other sections in Part IV are unenforceable in court. Nonetheless, these ideas are essential to society’s well-being, and states have an obligation to implement them for the good of their populace.
- Article 37 is important because it shows that, even while Directive Principles of State Policy are important, they cannot be used as a justification for violating the Fundamental Rights guaranteed by the Indian Constitution.
- The Court decided that the State cannot use the provisions of Article 46 to supersede or go beyond Article 29(2), which forbids discrimination in educational institutions.
- The Court also observed that she did not submit an application to the State’s medical college. She didn’t apply since she thought she wouldn’t be accepted as a Brahmin. Nevertheless, no one objected to her not applying, and following the Court’s ruling, the State promised to hold a place for her should she apply.
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