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STATE OF MADRAS VS CHAMPAKAM DORAIRAJAN, C.R. SRINIVASAN
(AIR 1951 SC 226)
The Indian Constitution provides for the Directive Principle of State policy to establish a welfare state and promote social and economic democracy. The give landmark judgement is a historic decree that resulted in the 1st Amendment of the Indian Constitution and accordingly Clause 4 was added to Article 15 to allow the State to make special provision for the backward class people for advancement of education. The case evolved around the Communal Government Order which was enacted prior to the introduction of the Constitution and spoke about the quota policy that was applied by the State sponsored institution for admission of students. The Directive Principle are not justiciable rights of the people but it is the State’s responsibility to ensure proper drafting of legislation keeping in mind the principles.
In 1950 the Madras followed the quota system for college entrance and the state financed 4 medical institutions and engineering colleges under this system.
According to this system, six seats out of every fourteen available were assigned to non-Brahmins, while two seats each were reserved for backward castes, Brahmins, and Harijans. Additionally, one seat was allotted for Anglo-Indians and Indian Christians, and one for Muslims.
This segregation was based on the Communal Government Order issued by the Province of Madras or Madras Presidency in 1927 and it completely followed the caste reservation to admit people to government universities and jobs.
The State claimed that they were following the communal order in respect to Article 46 of the Directive Principles of State Policy to promote the educational interests of the Marginalized communities such as Scheduled Tribes and other vulnerable sections of society.
The petitioner filed a suit at the Madras High Court alleging that the basic right to get admission in college was breached despite of the fact that she had good grades but still could not get through the Medical College.
The petitioner alleged that her fundamental rights under Article 15 and Article 29 was infringed and she pleaded to the Court to squash the Communal Order by the Writ of Mandamus.
Similarly another petition C.R.Srinivasan failed to get admission in the engineering college and approached the court for similar reasons .
The main questions that was clarified in this landmark case were -
If the Communal Order 1921 was constitutionally valid or not?
If the State is allowed to makes reservation on the basis of religion and caste in the educational institutions?
Earlier the High Court had quashed the Communal Order , because it provided for the reservation system based on the caste and the religion system .
Later when the state pleaded the Supreme Court, the apex court even held that the order was a complete violation of the constitutional provision
The court held that reservation of seat in educational institute on the basis of religion is against Article 16 and denying of admission was infringement of Article 15.
The court held that the fundamental rights will always prevail over the directive principle and they cannot be ignored.
This landmark case of made a big impact of bring the very first amendment in the Indian Constitution and showing how much importance the constitution provide for securing the fundamental rights of a person. It showed that fundamental rights will prevail over the directive principles and that the caste system reservation was unconstitutional and infringed the basis right of the individuals.
The Indian Constitution has always made sure that every person who are granted with the fundamental rights are not infringed. The Communal Order was considered to be vague because to focused on securing seats for students at the educational institutes on the basis of what religion the student belong to. It used the Communal Order as a shield under directive principles and did not allow the meritious students to get the admission in colleges. Thus apex court took action against the same and made sure that no one is denied of any post because of the religion or caste.