State of Madras v. Champakam Dorairajan

The Supreme Court of India’s landmark judgement is State of Madras v. Champakam Dorairajan (AIR 1951 SC 226). As a result of this decision, India’s Constitution was amended with the First Amendment. It was the Republic of India’s first important ruling on reservations. The Supreme Court affirmed the Madras High Court’s decision, which had knocked down the Government Order (G.O.) issued in the [Madras Presidency] in 1927.

State of madras v. champakam dorairajan citation

This ruling of the Supreme Court proved to be a historic event and decision. It resulted in the 1st Amendment to the Indian Constitution, which addressed the country’s reservation programme. Clause 4 was added to Article 15 as part of the revision. 

The ruling is based on the contested Communal Government Order, which was enacted prior to independence and remained in effect long after the Constitution was enacted. This edict established a quota policy in state-run college institutions based on the caste system. 

The court ruled that the government directive was null and invalid. This decision is significant because it addresses the contradiction between fundamental rights and state policy directive principles.

FACTS

There was a quota system in place for college entrance in Madras in 1950. Four medical institutions and four engineering colleges were supported by the state. Non-Brahmins were allotted six seats for every fourteen seats available, two for backward castes, two for Brahmins, two for Harijans, one for Anglo-Indians and Indian Christians, and one for Muslims. 

This was based on the Communal Government Order issued by the Province of Madras or Madras Presidency in 1927, just before independence (Communal G. O.). Reservations based on a person’s caste were used to admit people to government universities and employment.

The State of Madras claimed that they were allowed to keep and enforce the Communal Government Order because it was established under Article 46 of the Directive Principles of State Policy to promote the educational interests of Scheduled Castes, Scheduled Tribes, and other weaker sections of society.

Shrimathi Champakam Dorairajan, a Brahmin, filed a suit in the Madras High Court under Article 226 alleging that her basic right to admission to the college had been violated. She said that despite her good grades, she was unable to gain entrance to the Medical College.

ANALYSIS 

This is a major constitutional decision that cleared the path for the Indian Constitution’s first amendment. By establishing clause 4 in the Constitution, the 1st Amendment includes the addition of a reservation policy to the Constitution. The state is granted the power to work for the backward classes, or Scheduled Caste and Scheduled Tribe, by provisions that are educationally and socially favourable, according to clause 4 of the Constitution as it exists today. The 1st Amendment to the Constitution was ratified while the Lok Sabha was still being established. It was established in 1952. It was the first decision to overcome the discrepancy between basic rights and state policy direction principles.

Issues Raised: Issues Raised by the Petitioner:

The learned Advocate-General for the State maintains that this article’s provisions must be read in conjunction with the rest of the Constitution. He contends that Article 46 of the Constitution mandates the State to promote the educational and economic interests of the weaker sectors of society, particularly the Scheduled Castes and Scheduled Tribes, and to safeguard them from social injustice and exploitation in all forms.

Although this article is found in Part IV of the Constitution, which lays out certain directive principles of State policy, and while the provisions contained in that Part are not enforceable by any Court, the principles laid out therein are nonetheless fundamental for the country’s governance, and article 37 makes it mandatory for the State to apply those principles in making laws.

1. R. Das J’s decision – This judgement covers both cases No. 270 of 1951 (State of Madras v. Srimathi Champakam Dorairajan) and No. 271 of 1951 (State of Madras v. C. R. Srinivasan), which are appeals from judgments passed by the High Court of Judicature at Madras on 27-7-1950, on two separate apples. under Art. 226 of the Constitution, complaining of a violation of the petitioners’ fundamental rights

The Directive Principles of State Policy

The goal of the Directive Principles of State Policy is to establish social and economic circumstances that allow citizens to live a happy life. They also want to create a welfare state to promote social and economic democracy.

Though the Directive Principles are non-justiciable rights of the people but essential to the country’s government, it is the State’s responsibility to apply them in drafting legislation, as stated in Article 37. Furthermore, these principles should govern the executive agencies of the union and states. Even the judges must consider them while making decisions.

Conclusion:

State of Madras v. Champakam Dorairajan is a historic Supreme Court of India decision (AIR 1951 SC 226). India’s Constitution was altered with the First Amendment as a result of this ruling. It was the Republic of India’s first major reservation decision. The Supreme Court upheld the verdict of the Madras High Court, which overturned a Government Order (G.O.) issued in the [Madras Presidency] in 1927.