Champakam Dorairajan vs State of Madras
AIR1951MAD120
Case Summary
FACTS:
In 1950, there existed a quota system for college admission in Madras. The state-funded four medical facilities and four engineering colleges. Out of the fourteen seats that were available, six were given to non-Brahmins, two to Brahmins, two to Harijans, one to Anglo-Indians and Indian Christians, and one to Muslims.
This was based on the 1927, shortly before independence, Communal Government Order (Communal G. O.) issued by the Province of Madras or Madras Presidency. Caste-based reservations were utilized to determine admission to government jobs and universities. The State of Madras contended that since the Communal Government Order was created in accordance with Article 46 of the Directive Principles of State Policy to advance the educational interests of SC, ST, and other marginalized groups in society, they were entitled to maintain and uphold it.
A Brahmin named Shrimathi Champakam Dorairajan filed a lawsuit in the Madras High Court under Article 226, claiming that her fundamental right to college entrance had been infringed. She claimed that even with her strong academic record, she was turned down for admission to the Medical College.
ISSUE:
When there is a disagreement between Directive Principles of State Policy and Fundamental Rights, which takes priority?
Whether or not the Indian Constitution is in conflict with the Communal Government Order of 1927, and if it should remain in force after it was adopted?
RELEVANT PROVISION:
Article 15(1)
Article 15(1) prohibits discrimination by the State on the grounds of religion, race, caste, sex, or place of birth. It ensures that all citizens are treated equally by the government and protects individuals from unjust treatment. This provision is a fundamental right aimed at promoting equality in the eyes of the State.
Article 29(2)
Article 29(2) protects the rights of citizens, especially minorities, from being denied admission to state-funded educational institutions based on their religion, race, caste, or language. It ensures equal access to education for all, irrespective of these factors. The article upholds the principle of non-discrimination in the field of education.
Article 46
Article 46 directs the State to promote the educational and economic interests of the Scheduled Castes, Scheduled Tribes, and other backward classes. It emphasizes the need for special measures to improve their status in society. This provision is aimed at achieving social justice by uplifting historically marginalized communities.
JUDGEMENT:
The decision of champakam dorairajan case year is 9th April, 1951 having a 5-judge bench comprising of Justice Hiralal J. Kania, Justice Saiyid Fazal Ali, Justice Mehr Chand Mahajan, Justice Vivian Bose and Justice B.K. Mukherjea. It declared the contentious Communal Government Order, which supported a caste-based quota system, to be unconstitutional because it violated the Indian Constitution. The Court emphasized that fundamental rights are more valuable and have the highest priority. These Fundamental Rights are the cornerstone of the Constitution; no legislative or executive decree can supersede them, with the exception of those explicitly delimited by the relevant articles included in Part III of the Constitution.
The Indian Constitution’s Fundamental Rights must not be violated, and the State must take care when enacting laws and regulations.
The Court emphasized that although the Directive Principles of State Policy are significant, they cannot take the place of or supplant the Fundamental Rights. The Fundamental Rights are supplemented or augmented by these Directive Principles. The Supreme Court cited Article 37 of the Indian Constitution, which makes it clear that the Directive Principles of State Policy and other sections in Part IV are unenforceable in court. Nonetheless, these ideas are essential to society’s well-being, and states have an obligation to implement them for the good of their populace.
Article 37 is important because it shows that, even while Directive Principles of State Policy are important, they cannot be used as a justification for violating the Fundamental Rights guaranteed by the Indian Constitution. The Court decided that the State cannot use the provisions of Article 46 to supersede or go beyond Article 29(2), which forbids discrimination in educational institutions. The Court also observed that she did not submit an application to the State’s medical college. She didn’t apply since she thought she wouldn’t be accepted as a Brahmin. Nevertheless, no one objected to her not applying, and following the Court’s ruling, the State promised to hold a place for her should she apply.
Comments