Reasonable Classification under Article 14

Article 14 permits the State to treat differently placed persons differently, but only through reasonable classification rather than prohibited class legislation. A statutory classification is valid when it satisfies the cumulative two-part test of intelligible differentia and rational nexus.

Constitutional starting point

Article 14 guarantees equality before the law and equal protection of the laws. It does not require identical treatment regardless of circumstances; it requires similarly situated persons to be treated alike in relation to the law's purpose.

The two-part test

Both requirements must be satisfied for the classification to survive constitutional scrutiny.

• The classification must rest on an intelligible differentia that clearly distinguishes persons or things grouped together from those excluded from the group.
• That differentia must have a rational nexus with the object that the statute seeks to achieve. A discernible difference alone is insufficient if it is unrelated to the statutory purpose.

Judicial application and limits

The classical test was developed through decisions such as State of West Bengal v. Anwar Ali Sarkar (1952) and authoritatively summarised in Ram Krishna Dalmia v. Justice S.R. Tendolkar (1958).

• The court identifies the statute's object and examines whether the inclusion and exclusion of persons or things reasonably advance that object.
• Legislation enjoys a rebuttable presumption of constitutionality and some latitude in drawing categories, but an artificial, evasive or objectless distinction fails Article 14.
• The classification test is not the whole of Article 14 review. Under Shayara Bano v. Union of India (2017), legislation may also be invalidated for manifest arbitrariness.

How UPSC asks this