Article 14 of Indian Constitution

Article 14 of the Indian Constitution: A Comprehensive Analysis with Landmark Judgments

Introduction

The Indian Constitution guarantees certain fundamental rights to its citizens, among which Article 14 is the cornerstone of equality before the law and equal protection of laws. It upholds the principle that every individual is entitled to equality, ensuring that the state does not discriminate among its citizens arbitrarily.

Understanding Article 14

Article 14 has two key aspects:

1. Equality Before Law: This ensures that no individual is above the law and that the law treats every person equally.
2. Equal Protection of Laws: This concept, borrowed from the American Constitution, mandates that laws must be applied fairly and without discrimination.

These two principles work together to prevent arbitrary classification and uphold fairness in governance.

Scope and Applicability

1. Universal Application: Article 14 applies to all persons, including citizens and non-citizens.
2. State Action: It applies to laws made by the government as well as administrative actions taken by public authorities.
3. Judicial Review: The Supreme Court and High Courts have the power to strike down laws and actions that violate Article 14.

Doctrine of Reasonable Classification

While Article 14 promotes equality, it does not imply that all laws must treat everyone identically. The Supreme Court has upheld that classification is permissible if it meets the following conditions:

1. Intelligible Differentia: The classification must distinguish between groups based on reasonable and identifiable differences.
2. Rational Nexus: The differentiation must have a rational connection to the objective sought to be achieved by the law.

In Landmark Case of State of West Bengal v. Anwar Ali Sarkar (1952), a special court was set up under the West Bengal Special Courts Act, 1950, to expedite certain criminal cases. The Supreme Court held that the classification was arbitrary as there was no rational basis for selecting particular cases for special treatment.

Doctrine of Arbitrariness

To further strengthen Article 14, the Doctrine of Arbitrariness was evolved, stating that if a law is arbitrary, it violates the right to equality. In Landmark Case of E.P. Royappa v. State of Tamil Nadu (1974), This case expanded the interpretation of equality by introducing arbitrariness as a ground for challenging laws and state actions.

Judicial Activism and Expanding Horizons

The judiciary has continuously expanded the meaning of Article 14 through various rulings. Some key cases include:

1. Maneka Gandhi v. Union of India (1978)

This case reinforced the interconnection between Articles 14, 19, and 21, establishing that any law affecting personal liberty must be fair, just, and reasonable.

2. Shayara Bano v. Union of India (2017)

In this case, the Supreme Court struck down the practice of Triple Talaq, declaring it unconstitutional as it violated Article 14 by being arbitrary and discriminatory against Muslim women.

3. Navtej Singh Johar v. Union of India (2018)

The Supreme Court decriminalized Section 377 of the Indian Penal Code, ruling that discrimination based on sexual orientation violated Article 14.

Also read :  Salient-Features-Of-Indian-Constitution

Exceptions to Article 14

Despite its broad application, Article 14 has certain exceptions:

1. Reasonable Classification: As discussed, laws can classify people into groups based on rational criteria.
2. Special Laws for Certain Groups: The Constitution permits special provisions for Scheduled Castes (SCs), Scheduled Tribes (STs), women, children, and backward classes.
3. Doctrine of Necessary Discrimination: Certain laws may provide special treatment to specific categories to achieve socio-economic equality.
4. Privileges of the President and Governors: Under Article 361, the President and Governors enjoy immunity from legal proceedings during their tenure.

Also read :  Preamble-Of-The-Indian-Constitution

Impact of Article 14 on Indian Society

1. Ensuring Social Justice: The judiciary has used Article 14 to eliminate discrimination in employment, education, and access to public services.
2. Strengthening Democracy: By preventing arbitrary state action, Article 14 upholds the rule of law.
3. Empowering Marginalized Groups: Cases like Shayara Bano and Navtej Singh Johar have empowered minorities and vulnerable communities.
4. Regulating Government Policies: Several government actions and laws have been challenged and struck down for violating Article 14.

Conclusion

Article 14 is a pillar of Indian democracy, ensuring that equality remains the fundamental principle guiding governance. While it allows reasonable classification, it prohibits arbitrariness in law-making and execution. Through landmark judgments, the judiciary has continuously expanded its scope, making it a powerful tool for social justice and fairness.

Thus, Article 14 is not just a legal provision but a beacon of hope that safeguards individual dignity and prevents discrimination in the world’s largest democracy.

Also Read :- 

1. 1. 1. judicial-review
      2. fundamental-rights-of-india
      3. fundamental-duties-of-indian-constitution
      4. writ-certiorari
      5. writ-of-mandamus
      6. directive-principles-of-state-policy-notes
      7. doctrine-of-waiver-indian-constitution
      8. doctrine-of-eclipse
      9. doctrine-of-severability-with-case-laws