Article 14 of Constitution of India & Doctrine of Reasonable Classification

Article 14 says that State shall not deny to any person equality before the law or the equal protection of the laws within the territory of India. Equality before law as provided in the Article 14 of our constitution provides that no one is above the law of the land. Rule of the Law is an inference derived from Article 14 of the constitution. The article 14 aims to establish the “Equality of Status and Opportunity” as embodied in the Preamble of the Constitution.

However, Article 14 does not mean that all laws must be general in character or that the same laws should apply to all persons or that every law must have universal application. This is because all persons are not, by nature, attainment or circumstances in the same positions.

Thus, the State can treat different persons in differently if circumstances justify such treatment. Further, the identical treatment in unequal circumstances would amount to inequality.

Thus, there is a necessity of the “reasonable classification” for the society to progress. The Supreme Court has maintained that Article 14 permits reasonable classification of persons, objects, transactions by the State for the purpose of achieving specific ends that help in the development of the society. However, Article 14 forbids “class legislation”. Class legislation makes an improper discrimination by conferring particular privileges upon a class of persons.

However, some argue that the extensive use of device of “reasonable classification” by State and its approval by the Supreme Court has rendered the guarantee of ‘fair and equitable” treatment under Article 14 illusory. Here comes the role of “Test of reasonable classification”. The Test of Reasonable Classification says that the classification must be based upon intelligible differentia that distinguishes persons or things that are grouped from others that are left out of the group. This differentia must have a rational relation to the object of classification. There should be a relation between the differentiations to the object of the classification. If there are no such relations, the reasonable classification would fail.

For example denial of grant to a private college teaching law while giving grant to other private colleges teaching other subjects is not permissible. However, reduction of age from 58 years to 55 years is permissible.