Published On: January 5th 2026
Authored By: Dhanya Bhargava
NMIMS, Indore
- Title: State of Madras v Champakam Dorairajan
- Citation: 1951 AIR 226, 1951 SCR 525
- Court: Supreme Court of India
- Bench: 7 Judge bench; B.K Mukherjea, Hiralal J. Kania, Mehr Chand Mahajan, Vivan Bose, Saijid Fazal Ali, Sudhi Ranjan Das and M. Patanjali Shastri.
- Date of Judgement: 09th April, 1951
- Relevant Statutes/Key Provision: Article 13, Article 15(1), Article 16(4), Article 29(2) and Article 46 of Constitution of India, 1950.
Brief Facts
The Madras Presidency enacted the Communal Government Order in 1927, and it remained valid after the commencement of the Constitution of India in 1950. The goal of this decree was to support educational interests for marginalized communities, but it ended up preventing entry based on caste identification.
According to the Communal Government Order, state run four Medical and four Engineering colleges must have reservations.
Non- Brahmin Hindus- 2 Seats
Brahmin- 2 Seats
Backward Hindu- 2 Seats
Harijan- 2 Seats
Anglo-Indian and Indian Christian- 1 Seat
Muslim- 1 Seat,
has been reserved. Due to this reservation policy, Smt. Champakam Dorairajan was unable to secure a seat in the college. She filed a case under Article 226 of Indian Constitution, 1950 in Madras High Court alleging that her basic right to admission to the college had been violated by that order. The Madras High Court give decision in the favour of Champakam Dorairajan and the appellant then filed an appeal in the Supreme Court.
Issues Involved
- Whether in case of dispute between Fundamental Rights and Directive Principle State Policy, which should prevail?
- Whether after the commencement of Indian Constitution, the Communal Government Order should be in effect?
- Whether Communal Government Order of 1927 contradicts with the Indian Constitution of 1950?
Arguments
Petitioner’s Arguments
The state’s Advocate General argued that Article 29 of the Constitution of India must be read harmoniously with other Articles. He added that the state has an obligation to safeguard members of marginalized groups, particularly those who belong to Scheduled Castes and Scheduled Tribes, from social injustice and all forms of exploitation, as well as to advance their economic and educational interests. He said that this clause is essential to the nation’s governance even though it is a part of the directive principles of state policy. He claimed that the state must uphold Communal Government Order and allocate seats proportionately for all communities in accordance with Article 46, and that if the petitioner is denied admission to the college as a result of that order, her fundamental rights are not being violated. They contended that Article 46 of Indian Constitution prevails over Article 29(2) of the Indian Constitution.
Respondent’s Arguments
In this case, the defendant argued that the Communal Government Order, which was implemented in accordance with Article 46 of the Indian Constitution, violated fundamental rights.
However, the respondent said that the Communal Government Order is fundamentally founded on a caste-based system, which upholds social inequality and discrimination. They contended that qualified students should not be denied admission to a college that is supported and run by the State of Madras based on their caste.
In addition, the respondent argued in State of Madras vs. Champakam Dorairajan that the reservation system created by the Communal Government Order violates Article 16(1) of the Indian Constitution since it perpetuates caste discrimination. Furthermore, they contend that the Communal Government Order, which has been in effect in the State of Madras for a considerable amount of time, also violates Articles 15(1) and 29(2).
Judgement
In the case of State of Madras v. Champakam Dorairajan, the Supreme Court cited Article 37 of the Indian Constitution, which expressly declares that the Directive Principles of State Policy and other articles in Part IV is unenforceable in a court of law. But these values are essential to the well-being of society, and it is the responsibility of the states to implement them for the good of their inhabitants.
Article 37 of Indian Constitution is important in situations where Fundamental Rights and Directive Principles of State Policy clash because it shows that although Directive Principles are important, they cannot infringe upon the Indian Constitution’s Fundamental Rights.
Also in order to justify the communal reservation, the State of Madras invoked Article 46 of Indain Constitution, a Directive Principle of State Policy. The Court gave this argument some thought as well. Under Article 46, the State is obligated to promote the educational and economic interests of the underprivileged, particularly Scheduled Tribes and Scheduled Castes. Despite their importance in administration, the Supreme Court has said unequivocally that Directive Principles cannot take precedence over the enforceable Fundamental Rights guaranteed by Part III of the Constitution. Instead of providing legal rights or protecting against violations of fundamental rights, the Directive Principles are meant to guide legislative and executive policies.
According to Article 13 of the Constitution, the Supreme Court ruled that the Communal Government Order of 1927 was invalid because it violated the fundamental right that Article 29(2) of the Constitution guarantees Indian citizens.
The Court determined that the caste, race, and religion-based classification system used by the aforementioned Communal G.O. was unconstitutional and explicitly infringed on the fundamental rights guaranteed to citizens by Article 29(2) and Article 15(1) of Indian Constitution.
The Court ruled that the communal government order was unlawful and emphasized the importance of the principles of equality before the law and non-discrimination found in the Indian Constitution. It emphasized that merit and fair treatment must be the guiding principles in state-administered education, unless otherwise allowed by valid constitutional procedures. However, this landmark ruling sparked strong social and political reactions across the country. Therefore, in order to enable affirmative action without violating fundamental rights, the Parliament passed the First Constitutional Amendment in 1951, introducing Article 15(4), which allowed the State to make special provisions for the advancement of SC/STs and socially and educationally backward classes. Consequently, even while the decision maintained constitutional supremacy, it also resulted in a required constitutional and legal amendment to take social justice into account.
Ratio Decidendi
The ruling resulted in the Constitution’s First Amendment. The ratio appears to have been attained by taking the relevant provisions literally. Article 29(2) of the Indian Constitution is violated by the educational institution’s provision of reservations under the Communal Government Order on the basis of caste, religion, and other factors, according to the ruling of the respected Supreme Court. The Court further underlined the importance of peacefully interpreting the constitution to ensure that state laws do not restrict fundamental rights and that the Directive Principle always complies with and operates in accordance with them.
Obiter Dicta
The Honourable Supreme Court dismissed the respondent’s arguments and held that the Directive Principles of State Policy cannot supersede the fundamental rights enshrined in Article 37 of the Constitution of India and are not enforceable by a court. Furthermore, it was believed that no act or order of the legislative or executive branch could infringe upon or restrict the fundamental rights guaranteed by the Constitution. If the state is acting in accordance with the Directive Principles of State Policy, there can be no challenges to its activities if there is no violation of fundamental rights. Their authority is, nevertheless, constrained by various provisions of the Constitution.
The Court believed that Article 16(4) of Indian Constitution would become superfluous and useless if the respondent’s claims regarding Article 46 of Indian Constitution were granted. “The Constitution does not intend to introduce communal considerations with regard to admissions in state-run educational institutions,” the Court said. In order to protect the underprivileged classes, the state has been granted the authority to make reservations, and members of these classes must be nominated to governmental positions. When it comes to entrance to educational institutions, this is not required, though. This serves as justification for leaving out a similar provision in Article 29 as it does in Article 16(4).
Regarding C.R. Srinivasan’s case, it was believed that despite receiving significantly higher scores than many non-Brahmin applicants, he would not be admitted; instead, non-Brahmin applicants with lower scores would be admitted before him. He is a Brahmin and not a non-Brahmin candidate, which is the only justification that comes to mind for denying him entrance. It is stated that caste is the only reason for this type of rejection. Therefore, the petitioners’ fundamental rights are violated because the classification in the communal government decree is based on caste, religion, and race.
Final Decision
This is a landmark judgement in reservation by 7 judge bench. The Supreme Court held that the Communal Government Order was unconstitutional. It states that caste-based discrimination is against Article 15(1) of the Indian Constitution and is insufficient justification for educational reservation. It failed the Intelligible Differentia test i.e., there should be rationale for classification. In this case classification in only based upon the caste and religion for admission in the college so it is not reasonable but an arbitrary act of Government.
It was the first amendment to the Indian Constitution which addressed the country’s reservation policy and Article 15(4) was added in the Indian Constitution after this judgement.
