Article 14 of the Indian Constitution established the doctrine of reasonable categorisation. Every citizen in the country has a fundamental right to equality under Article 14. It is one of the most significant clauses of the constitution since it guarantees equality to all Indian citizens.
It safeguards against discrimination based on religion, caste, ethnicity, gender, or birthplace. Article 14 has two features: equality before the law and equal protection under the law. Previously, a reasonable classification test was undertaken to determine whether the legislation has reasonable classification, i.e., the test was held to determine the constitutionality of the legislation.
According to Article 14 of the Indian Constitution, “no person should be denied equality before the law or equal protection under the law within the territory of India.” This remark implies that no one is above the law of the land, and that the Rule of Law will win since all people are equal in the eyes of the law. However, this rule is not absolute, and there are numerous exceptions.
The Rule of Law cannot prevent a certain group of people from being subjected to special laws; as a result, the State has the authority to enact laws that apply differently to different groups of people while adhering to the principles of civil rights equality and equal protection under the law. This is known as Doctrine of Reasonable Classification.
The Supreme Court declared in Ram Krishna Dalmia v. Justice S.R. Tendolkar, AIR 1958, that while Article 14 prohibits class legislation, it does not prohibit fair classification for legislative reasons. Discrimination is prohibited not only by substantive law but also by procedural law.
As a result, while Article 14 prohibits class legislation, it does not prohibit fair classification. These categories, however, must not be “arbitrary, contrived, or evasive.”
The Supreme Court of India stated the twin test for reasonable classification in the case of State of West Bengal v. Anwar Ali Sarkar, the court decided that two elements must be met for a classification to pass the test: the classification must be based on an intelligible differentia that separates individuals who are grouped together from others, and the differentia must have a reasonable relationship to the Act’s goal.
The Court said that:
The differentia, which serves as the foundation for classification, and the act’s object are two separate entities, and there must be a connection between them, i.e., the law’s object and the grouping.
The theory of reasonable classification is only a judicial test to assess if a state action is arbitrary. If the state action in question fails to pass the doctrine’s test, it is considered arbitrary, and as such, it is illegal under the principles of article 14. This assures that persons in similar situations receive the same treatment.
For the advancement of civilization, a reasonable classification is required. The Supreme Court has ruled that Article 14 allows the government to classify people and things in a reasonable way in order to achieve goals that will benefit society’s growth.
Article 14 does not imply that all laws must be broad or that the same laws apply to all people. Every law cannot be applied universally. This is due to the fact that no two people are alike. There may be a distinction between them due to differences in nature or circumstances. Furthermore, the same treatment in uneven circumstances would be inequitable. For example, the same tax amount cannot be imposed on both rich and poor people, implying that the tax amount must vary depending on their economic standing.
As a result, alternative therapy should be given based on the reasons and reasoning. If the conditions justify it, the state can treat different people differently. As a result, the notion of justifiable classification does not create an exception to the right to equality, but rather defends it.
Thus, the doctrine of reasonable categorization is critical in this regard, but courts and governments must also guarantee that such classification is reasonable and free of arbitrariness.
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