Reasonable Classification under Article 14

Reasonable classification allows the State to treat differently situated persons differently without violating Article 14. A classification is valid only when it rests on an intelligible basis and that basis has a rational connection with the law's objective.

Constitutional premise

Article 14 guarantees equality before law and equal protection of the laws to every person. It prohibits class legislation, which arbitrarily singles out a group, but permits classification that reflects relevant differences.

• Equality does not require identical treatment regardless of circumstances; persons similarly situated must be treated alike.
• The validity of a classification depends on its substance and relationship with the law's purpose, not merely on the label used.

The two-part test

The Supreme Court stated the settled test in Budhan Choudhry v. State of Bihar (1955) and reiterated it in Ram Krishna Dalmia v. Justice S.R. Tendolkar (1958).

• Intelligible differentia: The classification must be founded on a clear and understandable distinction that separates persons or things included in the group from those excluded.
• Rational nexus: The differentia must have a reasonable connection with the object sought to be achieved by the law or State action.
• Both requirements must be satisfied; a real distinction is insufficient if it is unrelated to the statutory objective.

Scope of judicial review

Courts examine the law's objective, the basis of differentiation and the connection between them. The classification cannot be arbitrary, artificial or evasive; moreover, Article 14 review is not confined entirely to classification, because arbitrary State action may itself offend equality.