The concept of “Reasonable Classification” as a limitation to the Right to Equality (Article 14) was established in which case?
- (a)Kesavananda Bharati v. State of Kerala
- (b)State of West Bengal v. Anwar Ali Sarkar
- (c)Maneka Gandhi v. Union of India
- (d)Golaknath Case v. State of Punjab & Anrs.
Answer
Why
Correct — B. Article 14 does not stop a law from treating groups differently. It forbids unreasonable classification.
In State of West Bengal v. Anwar Ali Sarkar (1952) the Supreme Court applied the test. A classification must rest on an intelligible differentia, and that differentia must have a rational nexus with the law's object.
The Court held part of the West Bengal Special Courts Act, 1950 void because it let the State send cases to a special court with no principle of selection → option (b).
Why the others are wrong
- (a)Kesavananda Bharati v. State of Kerala — Kesavananda Bharati (1973) gave the basic structure doctrine: Parliament may amend the Constitution but cannot destroy its basic features. It is not about classification under Article 14.
- (c)Maneka Gandhi v. Union of India — Maneka Gandhi (1978) is an Article 21 case: a procedure depriving personal liberty must be just, fair and reasonable. It read Articles 14, 19 and 21 together but did not lay down the classification test.
- (d)Golaknath Case v. State of Punjab & Anrs. — Golaknath (1967) held that Parliament could not amend Fundamental Rights. It concerns the amending power under Article 368, not classification under Article 14.
Concept
Article 14 guarantees equality before the law and the equal protection of the laws. Equal protection does not mean identical treatment: people in different situations may be treated differently, if the line is drawn reasonably.
The twin test asks two questions. Is there a real, understandable difference between the groups? Is that difference connected to what the law is trying to achieve? A classification that fails either is struck down.
From the 1970s, beginning with E. P. Royappa, the Court added a second strand: arbitrary state action also violates Article 14. Maneka Gandhi built on it, which is why that option tempts. For classification, the case among these four is Anwar Ali Sarkar.
Key facts
- Article 14: the State shall not deny to any person equality before the law or the equal protection of the laws within the territory of India.
- Reasonable classification needs an intelligible differentia with a rational nexus to the object of the law.
- State of West Bengal v. Anwar Ali Sarkar was decided in 1952.
- Kesavananda Bharati (1973) laid down the basic structure doctrine.
Study next
Common traps
- Picking Maneka Gandhi because it discusses Article 14: its core ruling is on Article 21 and fair procedure.
- Mixing Kesavananda Bharati and Golaknath, which are amendment-power cases, with Article 14 equality cases.
Landmark cases are also asked at 17 Sep 2025, 16:00, GA Q.24, which puts the Berubari Union, Kesavananda Bharati and S. R. Bommai cases in chronological order.
Related PYQs
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