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Case Brief: State of Madras v/s Champakam Dorairajan (1951 AIR 226)

By Harsh Warwandkar | Views 26228

Name of Case: The State of Madras vs Srimathi Champakam Dorairajan 1951 AIR 226, 1951 SCR 525
Composition of the Bench: The Supreme Court of India - Constitution Bench (7 judges)
Name of Judges: Das, Sudhi Ranjan Kania, Hiralal J. (Cj) Fazal Ali, Saiyid Sastri, M. Patanjali Mahajan, Mehr Chand Bose, Vivian Mukherjea, B.K.
Area of Law: Constitutional Law
Brief Facts of the Case:
The main issue in the current dispute is whether the designation made in the communal G.O. regarding the reservation in educational institutions is still legitimate. Despite having received enough grades, Smt. Champakam Dorairajan, a Brahmin woman from the state of Madras, was denied admittance to the medical school in 1951 despite her qualifications. This was because of a collective GO issued by the government.

When compared to the current scenario, the quota system in the state of Madras was radically different. The Madras State government operated four medical colleges, with 17 seats designated for students from outside the state, 12 seats allocated at the state's discretion, and the remaining seats allocated among four diverse groups in the district.
For the Admission of the people in the Medical college the Madras government issued an order named Collective Go which stated that the seat of the college should be filled by the selection committee solely on the provided basis mentioned as:
1. 6 were to be allotted to Non-Brahmin (Hindus),
2. to Backward Hindus,
3. to Brahmins,
4. to Harijans.
5. to Anglo-Indians and Indian Christians
6. to Muslims[1].
She was turned away because there were fewer seats earmarked for members of the community she belonged to (Brahmin). Champakam Dorairajan won a decision from the Madras High Court. The Hon. Supreme Court of India is currently hearing the appeal to decide the case.
Jurisdiction:
The Supreme Court has got the jurisdiction over the matter by way of its Appellate Jurisdiction. The appeal is made before the Hon'ble Apex Court after being decided upon by the Madras High Court.
Question of Law:
Regarding India's reservation system, the case raises two significant issues.
1. Firstly- which should be prioritised: Directive Principles or Fundamental Rights.
2. Second- whether to reach the judgement by applying a literal reading to the disputed sections or by using another method.
Legal Issues for Determination:
1. Issue 1- whether the classification mentioned in Communal G.O regarding reservation in educational institutes of Madras are violative of the fundamental right guaranteed to the citizens of India by Art. 29 (2) of the Constitution?
2. Issue 2- Whether the directive principle of state policy can override the fundamental rights mentioned in part III of the Constitution?
The learned counsel appearing for the State of Madras contended that Art. 46 gives the State the power to promote with special care the educational and economic interests of the weaker sections of the population, especially of the Scheduled Castes and the Scheduled Tribes, and to protect them from social injustice and all forms of exploitation.

He also said that provisions of Art. 46 supersede the provision of Art. 29. He continued by saying that the provisions of Art. 29 must be read in conjunction with other articles in the Constitution (2). Additionally, the Communal G.O. assigning proportionate seats for various classes is allowed to be maintained by the State under article 46, so it is legal and does not violate the petitioners' fundamental rights.

The experienced counsel representing the Respondents argued that the Communal G.O. violates their fundamental rights protected by Articles 13, 16(4), and 29(2). As a result, she pleaded for the issuance of a writ of mandamus or other suitable prerogative writ prohibiting the State of Madras and all of its officers and employees from enforcing, observing, maintaining, or following or requiring the enforcement, observance, maintenance, or
Methodology of Judging the Issues Involved:
The verdict seems to have been given by way of literal interpretation of provisions like Article 37, 46 and 29(2), 16(2). The Court also emphasized on harmonious interpretation to show that directive principles cannot override Fundamental rights and that fundamental rights cannot be abridged[2].
Opinion of the Court:
The Supreme Court reached a unified conclusion. Hon. Justice Das J. delivered the aforementioned decision. The court found that the Communal G.O. did not comply with Article 29's provision (2). Additionally, the fundamental rights must not be restricted, thus the directive principles must also be in accordance with them.
Reasoning of the court:
The judgement of the court was set forth by Hon'ble Justice Das J. The main provision of law discussed in this particular case was article 29(2) which talks about not denying admission on ground of religion, race, caste, language or any of them[3]. This is the fundamental right which is enjoyed by individuals not as a member of any particular religion or caste but as a citizen of the country. The Court completely rejected the contention that "Article 46 can override the provision of Article 29(2)".

Article 46 comes under directive principles[4].It was contemplated that Directive Principles of State Policy has been expressly made unenforceable by way of Article 37.[5] He observed that the Fundamental Rights are sacrosanct and can never be abridged by any act or order passed by legislatives or executives, except to the extent mentioned under Part III of the constitution. It was set forth that Directive Principles shall run as subsidiary to the Fundamental rights. This shows that in case of conflict between the two then fundamental rights shall be placed above or considered superior to the directive principles.

It was noticed that the petitioner was denied admission into the educational institution only on the ground of he being a Brahmin and does not belong to the community having lot of reservations. In view of the apex court, the Communal G.O. entails classification on the basis of religion& caste and therefore opposed to the very fundamental provision of the Constitution. If the discrimination were only on ground of merits then there would be no breach of rights, but here the Communal G.O. was inconsistent with the very provision of article 29(2) and so shall be void under Article 13 of the constitution[6].
Ratio-Decidendi:
The judgement led to the First Amendment of the Constitution. The ratio seems to have achieved by way of literal interpretation of the provisions in question. The verdict of Hon'ble Supreme Court set forth that the reservations provided by the educational institution under Communal G.O.on grounds of religion, caste, etc is violative of Article 29(2) of the Indian Constitution. Also, the Court emphasized on interpreting the constitution in harmonious way so that the Directive Principle shall always conform to and run subsidiary to the Fundamental Rights and that the state laws do not abridge the fundamental rights.
New Rulings or Principles:
Clause 4 was inserted to Article 15 of the Constitution by this significant decision. The State shall not be restrained from providing for the advancement of any socially or educationally disadvantaged class, or for SC and ST under Article 15 or Article 29. (2). A question about what should be considered superior, fundamental rights or directive principles has also been resolved by this judgement.
Present Status of Ruling:
Numerous lawsuits have made reference to the judgement. When state policy's guiding ideas ran counter to the fundamental rights, it was brought up. This case has been cited since 1951 to demonstrate the superiority of fundamental rights and the impossibility of limiting them. This decision is also cited when the reservation system is in dispute because it established the legal precedent for prohibiting admissions discrimination.
Aim of the Judgement:
The main aim of the verdict was to enable clarity pertaining to the Reservation system in India. So that all citizens who deserves being admitted shall never be denied admission on ground of he/she being the member of a particular community.
Remarks:
Unquestionably, this decision has set the stage for combating unfair achievements made by educational institutions through reservations for a certain community or caste. And as a result of the language inserted to Article 15, the State was permitted to make particular arrangements for the socially and educationally disadvantaged class. However, because the judgement only applied to government-funded or supported universities and jobs, no determination was reached addressing reservation policies in private institutions.

However, a different situation raised the same issue. The Fundamental Right will always take precedence over all other rights and guiding principles, according to the most significant lesson this case taught. The ambiguity with regard to the two was so resolved. Each and every statement in the judgement was very clear and correct that it got never challenged or overruled, since 1951.

End-Notes:

The State of Madras vs Srimathi Champakam Dorairajan 1951 AIR 226, 1951 SCR 525
Parochial Attitude of Judiciary in the Interpretation of the Principles, Shodhganga, 232 source
Indian Constitution, art. 29, cl. 2. Which reads as "No citizen shall be denied admission into any educational institution maintained by the State or receiving aid out of State funds on grounds only of religion, race, caste, language or any of them".
Indian Constitution, art. 46.
Indian Constitution, art. 37.
Indian Constitution, art. 13.