Equality does not only mean treating similar people alike - it also asks whether the State uses its power fairly.
E.P. Royappa v. State of Tamil Nadu (1973) explained in simple English - Articles 14 and 16. Part 10 of 40 in Law Easy's Constitutional Case Laws series for LL.B., CLAT PG, UGC NET Law and judiciary preparation.
THE FACTS
Royappa was a senior Indian Administrative Service officer who challenged decisions affecting his posting and claimed the State had acted unfairly. The Court examined the complaint under constitutional equality principles and did not accept his challenge on the facts.
THE LEGAL QUESTION
Is Article 14 limited to the test of reasonable classification, or does it also prohibit arbitrary State action?
WHAT THE SUPREME COURT HELD
Although Royappa lost on the facts, the judgment became famous for a wider explanation of Article 14. Justice P. N. Bhagwati described equality and arbitrariness as opposing ideas. Arbitrary action - based on whim rather than fair reasons and legal standards - is contrary to equality. Not every disappointing government decision violates Article 14; a claimant must show a real legal defect.
KEY POINTS TO REMEMBER
- Two parts of Article 14: reasonable classification and the rule against arbitrary State action
- Government action must not be capricious - unpredictable and without a proper basis
- Later judgments, including Maneka Gandhi, developed this idea further
FOR YOUR EXAM
Write both limbs of Article 14 in an answer. Royappa is the standard citation for the 'equality versus arbitrariness' idea.
CONTINUE THE SERIES
Next, Part 11: Indra Sawhney Case Explained (1992) | OBC Reservation, Creamy Layer & 50% Rule
https://youtu.be/tgMVEl71GjE
Related, Part 19: Maneka Gandhi Case Explained (1978) | Article 21 & Fair Procedure
https://youtu.be/pe-D2zyap5A
All 40 Constitutional Case Laws (playlist):
https://www.youtube.com/playlist?list=PLT4r9ZZ3tKLM
Complete lecture, all 40 cases in one video:
https://youtu.be/oUrSfn3wp8s?t=1224 (this case starts at 20:24)
Notes and study material:
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Educational content only, not legal advice. Always read the original judgment and check the latest law before relying on a case in an answer or in practice.
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