Article 14 Constitution of India

Introduction

Article 14, located under Part III of the Indian Constitution, enshrines the principle of equality, one of the most fundamental aspects of a democratic society. This provision applies to both citizens and non-citizens, ensuring that no one is above the law and that the State must not enact laws or perform actions that are arbitrary, discriminatory, or unjust.

The concept behind Article 14 draws heavily from the American Constitution’s “equal protection clause” and the British principle of “equality before the law.” It reflects India’s commitment to treating all persons fairly and equitably in every aspect of governance, legislation, and justice delivery.

Text of Article 14

“The State shall not deny to any person equality before the law or the equal protection of the laws within the territory of India.”

Key Components of Article 14

1. Equality Before Law:

   • This concept is borrowed from British Common Law.

   • It implies the absence of any special privilege in favour of any individual.

   • Every person, regardless of their status, wealth, or power, is subject to the same legal authority and treated equally by the law.

2. Equal Protection of Laws:

   • This concept is taken from the 14th Amendment of the U.S. Constitution.

   • It means that everyone in similar circumstances must be treated equally and without discrimination.

   • However, it also allows for reasonable classification based on intelligible differentia.

Reasonable Classification vs. Discrimination

Article 14 does not prohibit classification, but it prohibits arbitrary discrimination. The Supreme Court of India has held that “equality before law” means like should be treated alike, and it allows for reasonable classification based on intelligible criteria.

Conditions for Reasonable Classification:

• The classification must be based on an intelligible differentia (a clear and distinct basis).

• The differentia must have a rational nexus (logical connection) with the objective of the law.

For example:

• Giving reservations to economically weaker sections or socially backward classes is reasonable classification, not discrimination.

• Creating laws that favour a specific individual or group without valid reasoning would be arbitrary and against Article 14.

Significance of Article 14

1. Foundation of Rule of Law:

   • Article 14 is the bedrock of rule of law in India.

   • It ensures that no one is above the law, and all laws are applied uniformly.

2. Protection Against Arbitrary Actions:

   • The State cannot take arbitrary actions.

   • If any government action or law is discriminatory or unreasonable, it can be challenged in court under Article 14.

3. Judicial Review and Enforcement:

   • The Supreme Court and High Courts have the power to strike down laws or government actions that violate Article 14.

   • It has empowered the judiciary to ensure fair governance and equal treatment.

4. Promotes Social Justice:

   • By allowing reasonable classification, Article 14 helps in making laws that are aimed at uplifting the underprivileged and ensuring equitable distribution of resources.

Landmark Judgments on Article 14

1. State of West Bengal v. Anwar Ali Sarkar (1952):

   • The Supreme Court struck down a law that allowed for discriminatory treatment in criminal trials as it lacked a reasonable classification and violated Article 14.

2. E.P. Royappa v. State of Tamil Nadu (1974):

   • The Court ruled that arbitrariness is the antithesis of equality, and any arbitrary action by the State would be violative of Article 14.

3. Maneka Gandhi v. Union of India (1978):

   • This case expanded the interpretation of Article 14.

   • The Court held that laws must be fair, just, and reasonable, and any procedure which is arbitrary or oppressive violates Article 14.

4. Indra Sawhney v. Union of India (1992):

   • The Court upheld the principle of reservation for Other Backward Classes (OBCs), stating it as reasonable classification under Article 14.

Limitations of Article 14

• Article 14 does not apply to private actions or individuals, but only to actions of the State and State authorities as defined under Article 12.

• It allows for reasonable restrictions and classifications, which means not all different treatment is illegal.

• Positive discrimination (like reservations) is allowed under the doctrine of reasonable classification.

Conclusion

Article 14 of the Indian Constitution is one of the most powerful tools in the hands of citizens to fight injustice, discrimination, and arbitrary governance. It ensures that every person, regardless of their background, has equal access to justice and is treated fairly under the law.

By embedding the principles of equality before law and equal protection of laws, Article 14 serves as the foundation of Indian democracy and the rule of law. It strikes a balance between absolute equality and social justice by allowing for reasonable classification in favor of the disadvantaged and marginalized. Its dynamic interpretation by Indian courts continues to protect the constitutional promise of equality for every individual.