State of Madras vs Champakam Dorairajan (1951)

Citation: 1951 AIR 226, 1951 SCR 525

Case Type: Public Interest Litigation

Name of the petitioner: The State of Madras

Name of the respondent: Champakam Dorairajan

Jurisdiction: Supreme Court of India

Composition of the Bench: The judgment in the present case was delivered by a 7-judge bench

which was composed of Hiralal J. Kania, Saiyid Fazal Ali, Mehr Chand Mahajan, and Vivian

Bose, B.K. Mukherjea, Sudhi Ranjan Das and M. Patanjali Shastri.

Background :

India’s first revision to its reservation regulations was prompted by this historic ruling pertaining to fundamental rights and guiding principles of state policy. The enforceability of Directive Principles of State Policy and their tendency to take precedence over fundamental rights was the focus of this case. This case led to the addition of Article 15(4) to Part III of the Constitution. The validity of the Communal Government Order was called up for debate in this case. This order, which was in place even before the constitution was drafted, allowed state-run colleges to institute caste-based quota policies.

Facts :

From the Madras state, Smt. Champakam Dorairajan was a girl of Brahmin origin. Despite achieving sufficient grades in 1951 because of a Communal Government Order (G.O.), she was unable to get entrance to a medical college. The state of Madras maintains four medical institutions, with only 330 seats accessible for students. Out of these 330 seats, 17 seats are designated for students from outside the state, 12 seats are reserved for the state’s discretionary allocation, and the remaining seats are dividedamong four geographical districts in the state. Similar to this, solely 395 seats are available for students at the engineering institutes that the state of Madras supports. Out of the 21 seats intended for students from outside the state, 12 are reserved for the state’s discretionary allotment, while the remaining seats are divided among the same four regional districts. A communal government order (G.O.) used to specify the exact proportions by which seats in medical and engineering colleges were to be filled, and this practice continued for many years prior to the Constitution’s adoption. The seats were divided among the four different district groups.^[1]

The goal of the order was to guarantee that communities that are neglected and vulnerable insociety was given fair opportunities to participate in public education. The selection committee used to strictly choose candidates based on the following criteria for each of the 14 seats that needed to be filled: 6 Non-Brahmin (Hindus), 2 Backward Hindus, 2 Brahmins, 2 Harijans, 1 Anglo-Indians and Indian Christians and 1 For Muslims.

A Brahmin lady named Dorairajan submitted an application to get admitted to a Madras state medical college. She fulfilled the academic requirements, but the reservations made under the communal G.O. prevented her from being admitted. As per the state’s reservation policy, the seats she was eligible to hold were set aside for candidates from different communities.

So, she appealed to the Madras High Court under Article 226 referring to the contravention of her fundamental right of not getting into the medical college. And she also claimed a breach of her fundamental rights under Article 15 (1) and Article 29 (2) and asked the court to repeal the Communal Government Order, by a mandamus writ. C. R. Srinivasan also appealed a petition in the Madras High Court which included her not getting into an Engineering College in spite of her eligibility.

Issues Raised :

• In State of Madras v. Champakam Dorairajan, the main question was whether the State of Madras’ Government Order, which reserved seats in educational institutions based on caste, infringed on the right to equality protected by Articles 15(1) and 29(2) of the Constitution.

• Can the fundamental rights mentioned in section III of the Constitution be superseded by the directive principle of state policy?

Provisions Addressed in State of Madras vs Champakam Dorairajan:

Key constitutional clauses, including Articles 15(1), 29(2), and 46, were to be thoroughly

examined in light of the State of Madras v. Champakam Dorairajan case.

➔ Article 15(1): Prohibition of Discrimination

• Relevance to the Case : Among other reasons, this article was pertinent to the State of Madras v. Champakam Dorairajan case because it dealt with caste-basedreservations in educational institutions. The petition claimed that because this entrenched caste-based discrimination, there was a clear violation of Article 15(1).

➔ Article 29(2): Right to Education without Discrimination

• Relevance in the Case : The State of Madras versus Champakam Dorairajan case demonstrated a straightforward interpretation of Article 29(2). Champakam Dorairajan was denied entrance because of a policy that assigned seats by caste, which might be construed as violating Article 29(2)’s explicit provision that no person be denied entry based on caste^[2].

➔ Article 46: Promotion of Educational and Economic Interests

• Relevance to the Case : According to the State of Madras, the reservation policy aims to promote educational opportunities for historically underprivileged groups in order to comply with Article 46’s command. The main legal issue was whether the Directive Principles could justify the violation of the enforceable fundamental rights outlined in Articles 15(1) and 29(2), since the Directive Principles are not enforceable by the courts.

Findings of the Supreme Court :

The Supreme Court pointed out that Article 29(2) states that no citizen may be refused admission to any state-run educational institution or assistance funded by state funds on the sole basis of their race, religion, caste, language, or any combination of these. An individual citizen, and not a member of a community or class of citizens, has the right to be admitted into educational institutions of the type specified in clause (2). The right cannot be denied solely because of religion, race, caste, language, or any combination of the above. If a person has the necessary academic qualifications but is denied due to religion, race, caste, language, or any combination of these factors, there has been a clear violation of a fundamental right. State argued that Article 46 obligates the State to advance special education and care for the underprivileged, especially Scheduled Castes and Scheduled Tribes. The argument put up was that Article 46 would supersede Article 29 (2). The Supreme Court fully rejected State’s argument. The Supreme Court ruled that Directive Principles are unenforceable by the Court and cannot override provisions under Part III (Fundamental Rights) that have been specifically declared enforceable by the State. The Directive Principles of State Policy must be consistent with and run alongside the Chapter of Fundamental Rights^[3]. As long as no Fundamental Rights are violated, there is no reason for recourse to the State operating in conformity with the Directive Principles of State Policy. The Supreme Court stated that Article 16 (4) of the Constitution aimed to provide provisions in support of the backward class of citizens who are underrepresented in services, but there are no such provisions in respect of college admission. The Supreme Court ruled that the Communal G.O is unlawful under Article 13 because it violates the stipulations of Article 29 (2) in Part III of the constitution.

RATIO DECIDENDI :

The Supreme Court invalidated the Communal Government Order (G.O.), declaring it unconstitutional. The Court ruled that the G.O. violated Article 29(2) of the Constitution because it denied students admission to educational institutions solely based on their caste or religion.

The Court clarified that while Directive Principles (like Article 46), which guide governance, are important, they are not legally enforceable and cannot override Fundamental Rights. It emphasized that Part IV of the Constitution (Directive Principles) must be subordinate to Part III (Fundamental Rights).

The judgment also highlighted that Article 16(4), which allows for reservations in public employment, applies exclusively to jobs. The Court inferred that the inclusion of this provision for employment, but not for educational admissions in Article 29, indicated an intentional decision to exclude similar communal considerations from admissions.

Finally, the Court stated that any order using community-based quotas as the only criterion for denying access to education is void under Article 13, as it conflicts with Fundamental Rights. The ruling stressed that merit and academic performance should be the primary criteria for admission, asserting that no communal classification, regardless of its history or social intent, can stand if it infringes upon individual constitutional rights.

Analysis :

The Indian Parliament replied to the case’s ruling by proposing to change and alter legislation that were in impending dispute with the DPSPs, in addition to securing and safeguarding the citizens of India’s fundamental rights. The First Amendment to the Indian Constitution was influenced by this case. Clause 4 of Article 15 was included with the approval of the First Constitutional Amendment Act of 1951. The constitution was used to implement Article 15(4). Therefore, to provide the state permission to establish any special requirements for improving the backward classes. Additionally, under Article 15(4), the government may assign seats to candidates from underprivileged groups in government-run institutions or organizations receiving state assistance. However, it denies the state the authority to set quotas for private organizations. Additionally, changes were connected to the freedom of speech guaranteed by Article 19(1)(g), the land reform initiatives, and the freedom of trade and enterprise. Reasonable limitations that the state may impose on matters pertaining to the public are the subject of Article 19(1)(g). It is therefore inherently lawful. There existed an inherent conflict between DPSPs and Fundamental Rights prior to this case since it was unclear which would prevail in the event of a dispute: DPSPs or Fundamental Rights. However, following this instance, an explanation states that “DPSPs are subordinate to Fundamental Rights.” It is a landmark case that helped amend Article 15 of the Indian Constitution and established the policy that prohibits discrimination against applicants on the grounds of constitutionality in all educational institutions. The Supreme Court’s decision resulted in a significant overhaul of India’s reservation system.

^[1] https://www.juscorpus.com/state-of-madras-vs-smt-champakam-dorairajan/

^[2] https://www.benchnotes.in/post/champakam-dorairajan-vs-state-of-madras-case-summary-air1951mad120

^[3] https://ghconline.gov.in/VernacularJudgments/English/CA-270-271-1951_Eng.pdf