STATE OF MADRAS v. SRIMATHI CHAMPAKAM DORAIRAJAN

(AIR 1951 SC 226)

Hon’ble Supreme Court Of India


Bench:- Justice Sudhi Ranjan Das, Justice Hiralal Kania, Justice Saiyid Fazal Ali, Justice M. Patanjali Sastri, Justice Mehr Chand Mahajan, Justice Vivian Bose, Justice B.K. Mukherjea

Petitioner- The State of Madras

Respondent- Srimathi Champakam Dorairajan and C.R. Srinivasan


Introduction:

This landmark decision concerning fundamental rights and directive principles of state policy was the reason for India's first amendment to its reservation policies.

The enforceability of Directive Principles of State Policy and their propensity to take precedence over fundamental rights were the subjects of this case. Due to this case, Part III of the Constitution now contains Article 15(4).

The Communal Government Order's legitimacy was an issue in this situation. This order, which was in effect even before the constitution was created, permitted the state-maintained colleges to implement a caste-based reservation policy.


Facts of The Case:

  • Our Constitution, striving for equality for all, establishes fundamental rights to be observed by all individuals in society, and no legislative or executive branch can restrict their observance. Provisions Found and Implemented in Part III in which Fundamental rights are respected, everyone must abide by them, and the principles guiding national policy do not violate them. Your reasoning regarding fundamental rights and their implementation will be treated concerning Article 46 of the Constitution.

  • In this case, the petitioner filed a petition with the Madras High Court stating that the inability to enter medical schools, especially state-run institutes, was a violation of fundamental rights. people say they have the right to an education. This was a serious violation of the fundamental right to admission or place in an educational institution.

  • There are four medical colleges maintained by the State of Madras, with only 330 seats available for student enrollment.

Reservations are also available for these 330 seats. 17 seats were reserved for external students and 12 seats were reserved for students appointed at the national discretion. Like medical colleges, technical colleges are maintained and managed by the state, with a capacity of 394 students. It has a quota of 21 external students and 12 nationally designated students.

  • Before the state constitution, medical and engineering seats were divided among municipal G.Os, with discretionary reservations. The 14 state seats were secured as follows: That is, 6 non-Brahmin seats, 2 backward class seats, 2 Brahmin seats, 2 Harijan seats, Anglo-Indian and Indian Christians 1, and 1 seat for Muslims. The country has established a policy of selecting members based on academic background, regarding student test scores and selection based on merit. The medical school also made provisions to reserve 20% of her seats for women. Not only on January 6, 1950 but even after the Constitution came into force, the principles and concepts that started in the old G.O community prevailed.

  • On June 7, 1950, Srimathi Dorairajan submitted an application from a university applicant to the High Court stating the fact of violation of the fundamental right of admission to medical college. He said he was ineligible for the seat because he belonged to the Brahmin community and the seat was already taken. He said the GO community had received his application from someone else, but his qualifications for university status were better.

According to the declaration, it was a violation of his fundamental rights and, on the contrary, the court found that the applicant was not enrolled in the university and therefore, under Article 29(1), 2 of the Constitution, such Infringement of fundamental rights of the complainant is not available. The High Court also found that if the petitioner had not even applied to the university, such an application would not be admissible in court. The G.O. community system is strictly based on the concept of caste, religion, and race and not on individual wealth, income, and welfare. These are all severe violations of the fundamental rights set out in Article 29 (2) of the Constitution. However, until the issue was fully discussed, no violations of fundamental rights corresponding to Part 3 of the Constitution were identified. No subject is imposed on the State in the form of policy principles by the Constitution or the laws referred to in Part 4, and the State is permitted by the provisions of the Policy Principles on Education, without violating fundamental rights.

Issues Raised:

  1. Whether the Madras State's Communal Government Order (1921) is constitutionally legitimate or not.

  2. Does the State have the authority to create caste- or religion-based reservations for seats in educational institutions?

Judgement:

The infringements concerning Madras v. Srimathi Champakam Dorairajan and Madras v. C.R. The Madras Supreme Court upheld the Municipal G.O. It has been accused of a caste-based, unconstitutional reservation system in India. Both complaints were dealt with under Article 226 of the Constitution, which constitutes a violation of the fundamental right of admission to universities.

The State of Madras then declared the local governments established by the State Government of Madras based on religion, race, and caste G. In clear violation of the Constitution of India, the Constitution guarantees the fundamental rights of citizens Part 3 Section 29 It is also a violation of Article 2.

The Court ruled that, in violation of the provisions of Article 16(2), a State could not reserve a particular seat accepting candidates based on religion, race, or caste. Denial of admission based on caste is a violation of Article 15(1). The provisions of the joint G.O. were declared ambitious and contradictory by the court and declared invalid under Article 13 of the Constitution. The court ruled in favor of Srimati Champakam Dorairajan. But the question arose: "Are all fundamental rights better than the DPSP?" Here the court answered this question by noting that whenever there is an inherent conflict between a fundamental right and DPSP it is a fundamental right".


Contentions of Petitioner:

The claimant stressed that the provision of Article 46 states that the state should promote the educational and economic interests of the vulnerable. It mainly targets SC and ST and protects them from all kinds of social injustice. Article 46 therefore gives the states the right to maintain order in the state government by securing seats in the various state-owned municipalities. Therefore, Municipal G.O. Valid and justified. Therefore, there is no constitutional violation that applicants could not enter their respective universities. At the same time, their fundamental rights have not been violated. In this case, the provisions of Article 46 shall prevail over the provisions of Article 29(2). Article 46 was found to fall under Part 4 of the Indian Constitution. It deals with Policy Principles (DPSP) and Article 37 clearly states: States' obligation to apply these principles in legislation. ”


Contentions of Respondent:

Defendants argued that the local government's Section 46 order was a clear violation of fundamental rights. Defendants added that caste should not be an obstacle for students eligible to enter state-supported universities. Caste-based reservations violate article 16(1). It has been argued that article 29 does not cover admission to educational institutions on the basis of religion, caste or race. Article 15 (1) and 29(2) were also violated when the state discriminated against them on the basis of caste and denied them admission to universities.


Critical Analysis:

The First Amendment was implemented on the Indian reserve as a result of this important decision. The Constitution's Article 15 now has a new clause (4) as a result of this case. Additionally, this was the first instance in which fundamental rights and directive principles clashed. The Court issued this ruling with the utmost equity and without engaging in any form of discrimination against any of the nation's inhabitants. Later, in the case of P.A. Inamdar v. State of Maharashtra, this was upheld. The Court emphasised and recommended specific rules for college admission in addition to the case's circumstances.

The Court stated that candidates with lower marks than those with higher marks shall not fill the seats.

As a result, the decision in this case is very important, sets a precedent for many future instances with a similar issue, and serves as a compromise when a conflict between directive principles and fundamental rights occurs. The Court further demonstrated the supremacy of the Constitution by invalidating the contested order, which continued to adhere to outdated standards and laws long after the Constitution came into effect.


Conclusion:

Since the judges made their judgement reluctantly, it can be inferred that they were aware of the legal flaw. The Honourable Supreme Court has outlined the significance of the citizens' fundamental rights as outlined in the Indian Constitution in the case of Srimathi Champakam Dorairajan v. Madras State. According to the Right to Education, everyone has the right to an education free from discrimination. Understanding our rights to freedoms is essential so that everyone may speak up when they are violated.



This article is written by Guna Sai Venkat Jagatha of Chanderprabhu Jain College of Higher Studies and School of Law.

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