The Indian Constitution’s Article 14 establishes the right to equality and provides equal protection under the law within Indian territory. This right is based on two tests: reasonable connection and intelligible differentia. Since the early 1970s, equality under Article 14 has expanded and taken on new dimensions as a result of the ruling in EP Royappa vs State of Tamil Nadu. Prior to this, an act had to pass acceptable categorization standards in order to meet Article 14 requirements.
The well-known case of E.P. Royappa v State of Tamil Nadu AIR 1974 SCC 555 established the new dimension and its guarantee against the arbitrariness of Article 14. In the Royappa case, the Supreme Court revealed a new aspect of Article 14, which had hitherto served as a safeguard against arbitrariness.
ep royappa case summary
ep royappa case facts:
- The ep royappa case citation is AIR 1974 SC 555.
- E.P. Royappa, the petitioner, was a member of the Indian administrative service in Tamil Nadu. He was elected to the position of chief secretary and subsequently elevated to it; however, his position was temporarily changed to that of an officer on special duty.
- The petitioner filed a writ petition for mandamus and other suitable writs under Article 32 of the Constitution.
- First, the petitioner argues that Rule 4 of the Indian Administrative Service (Cadet) Rules, 1954 does not legitimately constitute the post designated for the petitioner, the Office of Special Duty.
- Second, no post may be appointed until it is specified in schedule III under rule 9 of the Indian Administrative Service (Pay) Rules, 1954, unless the concerned authority, that is, the state or federal government, makes a declaration that the post in question is equivalent in status and responsibility to a post specified. This is the situation with the petitioner, as the concerned authority made no declaration for the cadre post holder.
- Thirdly, the petitioner’s position violates Article 14 and Article 16 of the Indian constitution because it has less authority and dignity than the chief secretary’s.
- Fourthly, the petitioner’s irritation with the second respondent and desire for him to move aside motivated the formation, appointment, and transfer of the post, not the legitimate exercise of power resulting from administrative or public service requirements.
EP Royappa Case Issues:
- Was it against the Indian Administrative Services Pay Rules, 1954 and the Indian Administrative Services (Cadre) Rules, 1954?
- Did it violate the Indian Constitution’s Articles 14 and 16?
- Was there a dishonest use of authority and misuse of judgment?
ep royappa case judgment:
The decision rendered by the honourable justices in this case is still regarded as a valid legal ruling, making it applicable. In the annals of Indian jurisprudence, the judgment rendered in this case regarding Articles 14 and 16 of the Constitution of India, as well as the opinions of the justices, have a very distinctive and significant place.
- The EP Royappa case judgment was delivered by Chief Justice A.N. Ray, Justice D.G. Palekar, Justice V.Y. Chandrachud, Justice P.N. Bhagwati and Justice R. Krishnaiyer in 23 November 1973.
- The Supreme Court ruled that the two positions should not be regarded as any less responsible than the top cadre positions, for which the petitioner was chosen, because they were designed to carry out duties requiring extremely high calibre and specialized knowledge. Because of the petitioner’s extensive experience in the field of commercial taxation, the government appointed him to the position of Officer on Special Duty.
- The affidavit evidence showed that the government always followed the petitioner’s advice.
- The petitioner’s claims were unfounded because it is impossible to claim that the chief minister engages in violent or intimidating behaviour.
- As a result, the state of Tamil Nadu was unable to add the positions of deputy chairman, state planning commission, and officer on special duty according to the second provision because they were not included in the cadre that the central government had established. As a result, the challenge based on this provision was unsuccessful.
- Since rule 9, sub-rule (1) was not followed, the petitioner’s appointment to the position of officer on special duty could have been declared invalid for violating the sub-rule. However, since this rule does not violate any fundamental rights, no remedy is available.
- As a result, the petition was denied without a cost order.
In this case, Article 14 is thoroughly examined and is a delicate classification. The two key ideas in this article are the reasonable connection and the intelligible differential. Therefore, this test incorporates both the rationality norm and a moral principle.
The basic structure doctrine may offer an objective standard for assessing arbitrariness and employ it under Article 14 to check the constitutionality of any act descending under equality before the law; as a result, the court’s decision was correct and constitutional. The doctrine of arbitrariness and the right to equality have two different scopes, making it extra-constitutional.
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