Punjab & Haryana High Court, Chandigarh
CitationAIR 1951 SC 226
CourtSupreme Court of India (Constitution Bench)
Date9 April 1951
Year1951
BenchM.H. Kania CJI, Saiyid Fazl Ali, M. Patanjali Sastri, Mehr Chand Mahajan, B.K. Mukherjea, S.R. Das, Vivian Bose JJ.
Acts/ArticlesArticle 15, Article 29(2), Article 46
CategoryConstitutional Law

Key Principle Established

Communal reservation in educational institutions based on caste/religion violates fundamental right to equality. Fundamental Rights prevail over Directive Principles.

Brief Facts

The State of Madras had fixed proportionate seats for different communities in State medical and engineering colleges. Champakam Dorairajan, a Brahmin, was denied admission despite having higher marks than reserved category candidates.

Ratio Decidendi

The Supreme Court struck down the communal reservation as unconstitutional, holding that Fundamental Rights prevail over Directive Principles. The State cannot abridge fundamental rights under the garb of implementing Directive Principles (Article 46).

Impact & Significance

This was one of the first landmark cases on reservation. It led directly to the First Constitutional Amendment (1951) which inserted Article 15(4), empowering the State to make special provisions for advancement of socially and educationally backward classes — the constitutional basis for reservation in education.

Tags & Related Topics

Constitutional Law Article 15 Article 29(2) Article 46
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Disclaimer

This judgment summary is for educational and research purposes. While care has been taken to accurately represent the ratio and findings, for authoritative reference always consult the original judgment text from official sources (SCC Online, AIR, Manupatra, or court websites).

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