8 Landmark Judgments on Article 15 of the Indian Constitution

The article '8 Landmark Judgments on Article 15 of the Indian Constitution' collectively affirms the principles of non-discrimination and social justice embedded in Article 15 of the Indian Constitution, progressively expanding its scope to encompass various facets of societal inequalities.

Introduction

Article 15 forbids discrimination based only on religion, race, caste, sex, place of birth or any of them. The Constitution of India prohibits any type of constraint, disability, or conditions from obtaining entry to public parks, commerce, hotels, and restaurants.

In the face of immense variety, sexism, and racism, Article 15 has permitted Indian society to stand high and proud. It is a defender of the oppressed and a barrier against discrimination. Despite a rigorous caste structure, it has historically influenced India’s cohesiveness and equality and will continue to do so. Article 15 was constantly going above and beyond to help individuals in genuine need. 

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1. State of Madras v. Champakam Dorairajan, AIR 1951 SC 226 | Validation of Reservation in Educational Institution

The major constitutional decision in this case opened the path for the Indian Constitution’s first amendment. By adding clause 4 under Article 15 to the Constitution, the Constitution’s First Amendment provides for the insertion of a reservation policy. Clause 4 under Article 15 of the Constitution, as it currently stands, provides the state with the power to advocate for Scheduled Castes and Scheduled Tribe via educational and other socially beneficial initiatives. 

It was the first choice to resolve the mismatch between fundamental rights & governing principles. The Supreme Court held in this landmark decision that the government’s edict reserving seats in schooling institutions solely based on caste and religion is unconstitutional. The decision established the idea of “reasonable classification,” highlighting that affirming measures and reservation must be determined by valid standards to redress social and educational disadvantage instead of religious or caste reasons.

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2. Yusuf Abdul Aziz v. State of Bombay, AIR 321 SC 930 | Does Section 497 of the IPC contradict Articles 14 and 15?

The fundamental issue in the present case was is section 497 of the Indian Penal Code, 1860 conflicts with Articles 14 and 15. The argument in this case was that Section 497 of the I.P.C, 1860, states that adultery can only be committed by men and that women cannot even be prosecuted as abettors. As a result of this debate, there was some disagreement about whether this was in breach of Article 15, which limits gender discrimination. However, Clause (3) of Article 15 explicitly indicates that nothing in Article 15 restricts the state’s right to establish specific provisions for women and children. The Court said,

“We are not unable to read any such restriction into the clause; nor are we able to agree that a provision which prohibits punishment is tantamount to a license to commit the offence of which punishment has been prohibited”.

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3. Paramjit Singh v. State of Punjab, (2009) 1 P&H 355 | Reservation for SC and ST in Election

The Petitioner was appointed to serve as Panch for a special seat reserved solely for Scheduled Caste women. The petitioner objected to respondent no. 5’s election as Sarpanch because she was ineligible to run for Sarpanch, which was reserved for Scheduled Castes and not Scheduled Castes (Women), as the respondent was appointed as Panch for Gram Panchayat only, and this was a reserved seat for Scheduled Castes (Women). It was decided that if the village’s Sarpanch seat had been reserved for those from Scheduled Castes, subsequently both men and women associated with these categories were eligible to compete for the Sarpanch’s post because their qualifications were belonging to a Scheduled Caste and expressing the region as Panch.

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4. DP Joshi v. State of Madhya Bharat, 1955 SCR (1)1215 | Article 15(1) prohibits discrimination based on place of birth but not residence

The rule of State Medical College permitted only non-residents to pay a capitation fee for admission to medical college while residents of MP were exempted.

The constitutionality of the reservation order offering seats at medical for applicants from backward classes was argued against in the landmark case of DP Joshi v. State of Madhya Bharat under Article 15(1) of the Indian Constitution, which restricts prejudice on different grounds. The reservation decision was maintained by the Supreme Court, which stated that Article 15(1) does not prohibit the state from creating specific arrangements for the improvement of backwards in terms of education and society sections.

The Court stated that such provisions must promote educational advancement and be based on objective factors such as social and educational backwardness, instead of simply caste considerations. Furthermore, the Court emphasized the significance of a flexible reservation system that responds to altering economic and social circumstances in society.

The Court pointed out that residence and place of birth are "two distinct conceptions with different connotations both in law and in fact".

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5. Janhit Abhiyan v. Union of India, Writ Petition (Civil) 55 Of 2019 | Reservation for Economically Weaker Sections

This case has had a significant impact since it has ensured that individuals who live in economically disadvantaged sectors of society are provided with equal opportunities in their educational and professional lives. The EWS reservation is an empowering clause that allows the state to offer special accommodations in educational institutions and career prospects for economically disadvantaged sections of society. The Supreme Court of India upheld the Constitution (103rd Amendment) Act, 2019, and the reservation for economically weaker sections (EWS) in this case.

Because of the EWS reservation, people from economically disadvantaged families now have new opportunities to obtain excellent educations and stable employment. Concerns have been expressed about the potential impact of reservations for Economically Weaker Sections (EWS) on current reservations for SCs, STs, and OBCs. It is critical to avoid dilution of current reservations and to keep the total reservation rate under 50%. Despite these reservations, the case’s total effect has been favourable, as it strives to uplift economically disadvantaged sectors of India and encourage social and economic equality.

However, careful tracking of the EWS reservation’s execution will be required to verify that it achieves its intended goal while not negatively impacting existing reservations.

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6. State of Madhya Pradesh v. Nivedita Jain, AIR 1981 SC 2045 | Right to make Special Provisions for SCs and STs

The Supreme Court stated the constitutionality of a Madhya Pradesh government executive order that entirely relaxed the standard of minimum scores for applicants from Scheduled Castes and Scheduled Tribes in Pre-Medical Exams.

The court ruled that, in the absence of legislation to the contrary, the government can impose conditions that would make the reservation meaningful for the development of applicants from such classes. The court determined that the presidential order completely reducing the minimum qualifying marks did not violate the Regulation or Article 15 (4) of the Constitution.

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7. State of UP v. Pradeep Tondon, 1975 AIR 563 | Reservation of Seats for the Students of Rural Areas

In this case, the Supreme Court ruled that giving reserved places to students from rural areas is unconstitutional. It cannot be supported by Article 15 Clause (4). In this case, the state of Uttar Pradesh was giving students from rural areas, mountainous regions, and Uttarakhand preference in medical colleges. Reservations for students from hilly areas and Uttarakhand are valid, as determined by the Supreme Court because those who live in these regions are educationally and socially backwards due to a lack of knowledge and insufficient educational facilities. The Court declared that being rural is not indicative of a backward socioeconomic or educational status and that poverty in rural areas does not correspond to backwardness.

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8. M.R. Balaji v. State of Mysore, AIR 1963 S.C. 649 | Special Provisions to Make Rules for Backward Classes

In this case, the government reserved seats in the state’s medical and engineering institutions. It was presented that further clarification for the backward class is as follows backward castes had 28%; other backward groups had 22%; and Scheduled Castes and Tribes had 18%. According to the court, the sub-grouping of backward classes had no justification under Article 15 (4). Backwardness is determined by more than just caste. Reservation of up to 68% is a “constitutional fraud.” Article 15 (4) only authorizes the state to make exceptional provisions for backward castes, not exclusive provisions.

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Conclusion

Article 15 has made a big difference in the lives of the oppressed in India by advocating harmony and minimizing atrocities against the impoverished classes. It forbids discrimination based on religion, race, socioeconomic status, gender or place of birth, to ensure equal opportunity and growth for socially disadvantaged groups.

While reservations have caused controversy, its objective is to help the underprivileged rather than to divide society. The landmark Article 15 cases have played a critical role in establishing equality and social justice in India. The judiciary has established a compromise between the promotion of equal opportunity and the preservation of merit through these verdicts. Article 15 remains a potent tool in the battle against prejudice, and such decisions have considerably aided the country’s development toward a society that is more equitable and inclusive.