M. Narayanaswamy v. State of Tamil Nadu

Quick Summary

The case questions a narrow rule: only serving or former government employees could be made Special Judicial/Metropolitan Magistrates under Sections 13 and 18 of the CrPC. The Court held this rule violated Article 14 because it drew an arbitrary line. Government service experience may not relate to the skills needed for the post. The offending portion of the sections was struck down; the rest of the framework survived.

Issues

• Does limiting Special Magistrate appointments to current or ex-government employees violate Article 14 (equality)?

Rules

• Appointments confined to government employees under Sections 13(1) and 18(1) CrPC are arbitrary and offend Article 14.
• Classification must have a rational link with the job’s purpose; otherwise, it fails equality review.

Arguments

Judgment

• The High Court declared the “government employees only” condition unconstitutional under Article 14.
• It reasoned that government experience may be unrelated to the role of Special Magistrate.
• Only the offending portion in Sections 13(1) and 18(1) CrPC was struck down; other parts continued.
• On further challenge, the Supreme Court partly allowed the petitions by striking down the same limiting portion and saving the rest of the scheme.

Ratio

A classification that restricts eligibility to government employees for Special Magistrate posts lacks a rational nexus with the job’s purpose and, therefore, violates Article 14. The remedy is to strike only the arbitrary limb, not the entire appointment power.

Why It Matters

• Opens the field to a wider, merit-based pool for Special Magistrates.
• Reinforces that equality review requires a real link between classification and objective.
• Shows how courts tailor relief by severing only the unconstitutional part.

Key Takeaways

• Article 14: No arbitrary eligibility filters.
• Nexus Test: Job requirements must match the classification.
• Severability: Strike only the bad part; keep the workable scheme.

Mnemonic + 3-Step Hook

Mnemonic: “NARA = No Arbitrary Restrictive Appointments.”

1. Spot: Eligibility limited to a narrow class.
2. Test: Ask if the class relates to the job’s purpose.
3. Fix: Sever the arbitrary limb; keep the rest.

IRAC Outline

Glossary

Article 14

Equality before law and equal protection of laws; bars arbitrary classifications.

Classification

Grouping people for a law’s purpose; must have a rational link to that purpose.

Severability

Courts remove only the unconstitutional part and keep the valid remainder.