The Right to Equality is one of the most fundamental guarantees under the Indian Constitution. Enshrined in Article 14, it ensures fairness in State action and acts as a constitutional safeguard against arbitrariness. Over the years, the Supreme Court of India has expanded this provision from a formal guarantee of equal treatment to a powerful doctrine governing legislative, executive, and administrative action.
Constitutional Foundation: Article 14 of the Indian Constitution
The Doctrine of Reasonable Classification
Twin Test of Reasonable Classification
1. Intelligible Differentia
2. Rational Nexus with the Object of the Law
Both conditions must be satisfied simultaneously; failure of either renders the classification unconstitutional under Article 14.
Intelligible Differentia Explained
Meaning
Intelligible differentia refers to a clear, logical, and understandable basis on which persons or things are grouped together and distinguished from others.
The basis of classification must not be vague, artificial, or evasive.
Simple Illustration
If a law provides government scholarships only to students whose annual family income is below ₹8 lakh, the classification is based on income:
The criterion is objective It is clearly identifiableIt is capable of uniform application
Thus, the classification satisfies the requirement of intelligible differentia.
Judicial Authority
[Budhan Choudhry v. State of Bihar, 1955, Supreme Court]
The Court held that classification must be founded on an intelligible differentia which distinguishes those included in the group from those excluded.
Rational Nexus Explained
Meaning
Rational nexus requires that the differentia adopted must have a direct and reasonable connection with the objective sought to be achieved by the law.
A valid classification cannot exist merely for the sake of differentiation; it must serve the legislative purpose.
Simple Illustration
- Objective of the law: To promote higher education among economically weaker students
- Basis of classification: Annual family income
Since income directly relates to financial need, the classification bears a rational nexus with the objective of the legislation.
Judicial Authority
[Ram Krishna Dalmia v. Justice Tendolkar, 1959, Supreme Court]
The Court clarified that even if the differentia is intelligible, the classification will fail unless it has a rational relation to the object of the Act.
Combined Application of the Twin Test
Valid Classification Example
A law mandates annual medical fitness tests for commercial drivers above the age of 60.
Intelligible differentia: Age (above 60)
Rational nexus: Ensuring road safety due to increased health risks with age
Such classification is constitutionally valid.
Invalid Classification Example
A rule mandates medical tests only for drivers born on Mondays.
No intelligible differentia
No nexus with road safety
This would clearly violate Article 14.
Equality as Anti-Arbitrariness: The E.P. Royappa Doctrine
A major shift in the interpretation of Article 14 occurred in: [E.P. Royappa v. State of Tamil Nadu, 1974, Supreme Court]
The Court held:
“Equality is antithetic to arbitrariness.”
This judgment transformed Article 14 from a classification-based doctrine to a guarantee against arbitrary State action.
Even where no formal classification exists, State action can be struck down if it is arbitrary, unreasonable, or unfair.
Expansion Through Maneka Gandhi
The doctrine of non-arbitrariness was further strengthened in: [Maneka Gandhi v. Union of India, 1978, Supreme Court]
The Court ruled that any procedure established by law must be fair, just, and reasonable, linking Article 14 with Articles 19 and 21. This decision firmly embedded substantive due process within Indian constitutional law.
Equality in Government Contracts: International Airport Authority Case
Article 14 is not confined to legislation alone. Its reach extends to administrative discretion and government contracts.
[Ramana Dayaram Shetty v. International Airport Authority of India, 1979, Supreme Court]
Key principles laid down:
- The State and its instrumentalities cannot act arbitrarily in contractual matters.
- Any deviation from prescribed eligibility criteria violates Article 14.
- Government action must be transparent, fair, and non-discriminatory.
This case established that even contractual discretion of the State is subject to constitutional scrutiny.
Reasonable Classification vs Arbitrariness
After E.P. Royappa, the focus of Article 14 jurisprudence shifted:
Earlier: Whether classification satisfies the twin test
Later: Whether State action is arbitrary
Today, arbitrariness itself is treated as the antithesis of equality.
Conclusion
Article 14 of the Indian Constitution represents a dynamic and evolving concept of equality. The doctrines of reasonable classification, intelligible differentia, and rational nexus provide flexibility to the State, while landmark judgments such as E.P. Royappa, Maneka Gandhi, and the International Airport Authority case ensure that such flexibility does not degenerate into arbitrariness.
The true essence of equality under Article 14 lies not in mechanical uniformity, but in fairness, reasonableness, and justice in State action. This constitutional balance makes Article 14 one of the most powerful tools for judicial review in Indian constitutional law