CASES UNDER ARTICLE 15 OF CONSTITUTION --PROHIBITION AND DISCRIMINATION

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CASES UNDER ARTICLE 15 OF CONSTITUTION --PROHIBITION AND DISCRIMINATION

1. D.P. Joshi v. State of Madhya Bharat (1955)

This landmark Supreme Court case examined whether charging different tuition fees for residents and non-residents violated Article 15(1) of the Constitution. The petitioner challenged a rule requiring non-resident students to pay higher fees in a medical college. The Court held that “residence” and “place of birth” are distinct concepts. Article 15(1) prohibits discrimination based on place of birth but not necessarily on residence. Therefore, differential fees based on residence were upheld as constitutionally valid. The judgment established that reasonable classification based on residence is permissible under certain circumstances. The case remains important for understanding the scope and limitations of Article 15(1).

2. State of Madras v. Champakam Dorairajan (1951)

This was one of the earliest and most significant constitutional cases relating to equality and reservations. The Government of Madras had issued a Communal Government Order reserving seats in educational institutions based on caste and religion. The Supreme Court struck down the order, holding that it violated Article 15(1) and Article 29(2), which prohibit discrimination in educational admissions. The judgment emphasized equality before law and non-discrimination. In response, Parliament enacted the First Constitutional Amendment, 1951, introducing Article 15(4), which allows special provisions for socially and educationally backward classes. The case fundamentally shaped India's reservation policy and constitutional approach toward affirmative action.

3. M.R. Balaji v. State of Mysore (1963)

The M.R. Balaji case dealt with the extent and basis of reservations under Article 15(4). The State of Mysore reserved nearly 68% of seats in educational institutions for backward classes. The Supreme Court held that caste alone could not be the sole criterion for determining backwardness. The Court also observed that reservations should generally not exceed 50% to maintain a balance between equality and affirmative action. It struck down the classification between “Backward” and “More Backward” classes as unreasonable. This judgment laid the foundation for the 50% reservation ceiling principle and remains a key precedent in reservation jurisprudence.

4. Article 15(1): Prohibition of Discrimination

Article 15(1) prohibits the State from discriminating against any citizen solely on the grounds of religion, race, caste, sex, or place of birth. It is a fundamental guarantee aimed at promoting equality and preventing social exclusion. The provision applies only to State action and seeks to ensure equal treatment in public life. However, it does not prohibit reasonable classification based on objective criteria unrelated to the prohibited grounds. Article 15(1) forms a cornerstone of India's equality code and complements Article 14. It has been instrumental in protecting citizens against arbitrary discrimination and strengthening democratic and constitutional values.

5. Article 15(3): Special Provisions for Women and Children