The Case of Pramati Educational and Cultural Trust vs Union of India (2014)

July 25, 2024

The courts have had to deal with conflicts arising from individual rights as well as conflicts of laws on multiple occasions. The Supreme Court of India has examined a number of these conflicts of rights in this specific case. The two primary amendments that give one community rights are what make the case so intriguing; these amendments do not get along well. In contrast to Article 21A and Article 15(5), it is article 19(1) (g) of indian constitution. This is the case, to put it briefly.

pramati educational and cultural trust vs union of india Case Facts

  • According to the case’s facts, a three-judge bench in society for unaided private schools in Rajasthan v. Union of India & another issued a referral order that called upon a constitution bench made up of five judges.
  • In this case, the ninety-third amendment act of 2002 added clause 5 of Article 15 to the Indian Constitution, and the three-judge bench referred the case for a determination on its constitutionality.
  • It was also requested to investigate any potential amendments to Article 21A, which was added to the Constitution through the Eighty-sixth Amendment Act of 2002. The following are the issues that are in front of us.

Pramati Educational and Cultural Trust vs Union of India Issues

  • Does the Parliament have changed the Constitution’s framework or basic structure, for example, by adding clause (5) to Article 15?
  • Has the basic structure or framework of the Constitution been modified by the Parliament, either through the addition of article 21of indian constitution?

Contentions by the Parties

Petitioner:

  • The petitioner claimed that Article 14 and Article 19(1)(g) (freedom to do business) are violated by the three clauses listed in the facts.
  • The petitioner further claimed that the fundamental elements of the constitution had been destroyed by Article 15(5).

Respondent:

  • According to the respondents, petitioners in this particular case, who are entitled to operate their own educational institutions under article 19(1)(g), should not be negatively impacted by giving them a reduced share of seats in such an educational institution.
  • He claims that rather than being a command upon the state, Article 15(5) is an enabling clause. Instead, he cites the Supreme Court’s ruling in the Islamic Academy of Education case, which established that a predetermined proportion of seats in non-minority institutions should be occupied by underprivileged and underprivileged individuals.

Pramati Educational and Cultural Trust vs Union of India Judgment

  • The court determined that the primary goal of clause (5) of Article 15 was to grant the State the authority to guarantee the economically and socially disadvantaged segments of society equal access to education by allocating seats in all educational institutions, with the exception of minority educational institutions.
  • Clause (5) has been inserted to guarantee the provisions outlined in Article 15 and to guarantee equal access to educational institutions.
  • The court cited the ruling in the State of Kerala and Others vs. N.M. Thomas and Others case, which determined that Article 16’s clause (4), which is essentially the same as Article 15’s clause (5), is not a proviso or exception to the Article but rather an aim to provide equal opportunities to all parties seeking public employment. This ruling was also made in the Indra Sawhney & Others. v. Union of India & Others case.
  • The petitioners’ argument that the addition of clause (5) to Article 15 violated Article 19(1)(g) for the establishment and management of private educational institutions was rejected by the court, indicating that the petitioners’ ability to exercise their right is unhindered by the distribution of a small portion of the seats.
  • The court also made a distinction between educational universities that are privately aided and those that are privately unaided, noting that the former receive funding from the State while the latter do not.
  • The court held that the amendment was made to give the State new power to ensure the establishment of article 21 of indian constitution, which provides free and compulsory education to children of age six to fourteen, since this goal had not been achieved for fifty years.
  • The second issue was whether an addition of Article 21 (A), which provides free and compulsory education to the backward classes of society, violates the basic structure of the Constitution. As a result, the court determined that the addition of Article 15 and Article 21A’s clause (5) was constitutionally permissible.

The aforementioned ruling makes it abundantly evident that, so long as the State’s authority does not conflict with that granted by article 45 of the indian constitution, Article 21A supersedes article 19(1)(g) of indian constitution. If this isn’t done well, courts may not recognize this kind of supremacy.

With the goal of giving students the best coaching available for law entrance exams including the CLAT, AILET, and various other numerous state judiciary exams, Jyoti Judiciary Coaching, India’s Finest educational Platform, was established. Come enrol now with Jyoti Judiciary!

For any latest news, legal topics, judiciary exams notifications, patterns, etc watch Jyoti Judiciary’s YouTube channel for legal videos for any updates at https://youtube.com/@jyotijudiciarycoaching4852?si=2cwubh9d2A9urwJf

Leave a Comment