3-March -2025-Special-Article

CHAMPAKAM DORAIRAJAN CASE, 1951: A LANDMARK JUDGMENT ON FUNDAMENTAL RIGHTS AND DIRECTIVE PRINCIPLES

The Champakam Dorairajan case (1951) was the first major legal battle between Fundamental Rights (FRs) and Directive Principles of State Policy (DPSPs). It resulted in a Supreme Court ruling that upheld the supremacy of Fundamental Rights over Directive Principles, leading to significant constitutional amendments.

Background of the Case

• In 1948, the Madras government introduced the Communal Government Order (GO), reserving seats in educational institutions based on caste and religion.
• The state justified the policy using Article 46, which directs the government to promote the educational and economic interests of Scheduled Castes (SCs), Scheduled Tribes (STs), and other weaker sections.
• Champakam Dorairajan, a student from Madras, challenged this order in the Madras High Court, arguing that it violated her right to equality under Article 14.

Court Verdicts

Madras High Court (1950)

• The High Court struck down the Communal GO as unconstitutional, ruling that caste- and religion-based reservations were discriminatory.
• The Madras government appealed to the Supreme Court.

Supreme Court Verdict (1951)

• The Supreme Court upheld the High Court’s decision, declaring the Communal GO unconstitutional.
• It ruled that the order violated Article 14 (Right to Equality) and Article 15(1) (Prohibition of Discrimination on Grounds of Religion, Race, Caste, Sex, or Place of Birth).
• The SC established that Fundamental Rights override Directive Principles.
• It allowed Parliament to amend Fundamental Rights through constitutional amendments.

Impact of the Judgment

• The ruling invalidated caste-based reservations in education, as the Constitution (at that time) permitted reservations only in public employment under Article 16(4).
• This led to the 1st Constitutional Amendment Act, 1951, which reinstated education-based reservations.

1st Constitutional Amendment Act, 1951

Key Changes

1. Reservations in Education:
   • Article 15(4) was introduced, enabling special provisions for Socially and Educationally Backward Classes (SEBCs), SCs, and STs.
   • This amendment legally established educational reservations.
2. Changes to Freedom of Speech:
   • Article 19(2) introduced additional reasonable restrictions on free speech, including security concerns and public order.
3. Parliamentary and Legislative Sessions:
   • Articles 85 & 174 mandated that the interval between two sessions of Parliament or State Legislatures should not exceed six months.
   • Articles 87 & 176 reduced the requirement for President/Governor addresses to once after a general election and at the start of the first session each year.
4. Land Reforms:
   • Article 31A protected laws related to land acquisition from challenges under Fundamental Rights.
   • Article 31B created the Ninth Schedule, shielding listed laws from judicial review.
5. Recognition of SCs and STs:
   • The President was given power to specify SCs (Article 341) and STs (Article 342) for each state separately.

Key Constitutional Provisions for Weaker Sections

• Article 15(1): Prohibits discrimination based on religion, race, caste, sex, or place of birth.
• Article 15(4): Allows special provisions for SEBCs, SCs, and STs.
• Article 16(4): Enables reservations in public employment.
• Article 17: Abolishes untouchability.
• Article 46 (DPSP): Directs the state to promote the educational and economic interests of SCs, STs, and weaker sections.

Other Supreme Court Judgments on FRs vs. DPSPs

1. Golaknath Case (1967)

• The Supreme Court overturned the Champakam Dorairajan ruling, stating that Fundamental Rights cannot be amended.
• This ensured absolute protection for Fundamental Rights.

2. Kesavananda Bharati Case (1973)

Background: The 25th Constitutional Amendment Act (1971) introduced Article 31C, which:

• Protected laws implementing Article 39(b) and (c) (resource distribution) from judicial review, even if they violated Articles 14, 19, or 31.
• Prevented courts from questioning the validity of such laws.

Verdict:

• The SC upheld the first provision, validating laws related to economic justice.
• It struck down the second provision, restoring judicial review.
• Introduced the Basic Structure Doctrine, stating that key principles of the Constitution cannot be altered or destroyed.

3. Minerva Mills Case (1980)

Background: The 42nd Constitutional Amendment Act (1976) extended Article 31C’s protection to all DPSPs, making them superior to Articles 14, 19, and 31.

Verdict:

• The SC invalidated this extension, reaffirming the balance between FRs and DPSPs.
• It ruled that DPSPs cannot override Fundamental Rights.

Current Status: FRs vs. DPSPs

• Fundamental Rights take precedence over DPSPs.
• However, Parliament can amend Articles 14 and 19 to implement Articles 39(b) and 39(c) for economic justice.
• Judicial review remains a crucial safeguard.

Conclusion

The Champakam Dorairajan case played a vital role in shaping India’s constitutional framework. It emphasized the supremacy of Fundamental Rights, leading to crucial amendments like the 1st Constitutional Amendment Act, 1951. Subsequent rulings, such as Golaknath, Kesavananda Bharati, and Minerva Mills, refined the relationship between FRs and DPSPs, ensuring a balance between individual freedoms and social justice.

Mains Question:

1. The Champakam Dorairajan case (1951) highlighted the conflict between Fundamental Rights and Directive Principles of State Policy. Discuss its impact on constitutional amendments and judicial interpretations. (150 WORDS)