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Champakam Dorairajan Case and Evolution of FRs and DPSPs l UPSC CSE Notes

Champakam Dorairajan Case and Evolution of FRs and DPSPs

Introduction

The Champakam Dorairajan Case (1951) was the first instance of conflict between Fundamental Rights (FRs) and Directive Principles of State Policy (DPSPs). This landmark case led to significant constitutional amendments and shaped India's legal framework regarding reservations and equality.

Background of the Case

In 1948, the Madras Government issued a Communal General Order (GO), reserving seats in educational institutions based on caste and religion. The government justified the order by citing Article 46, which mandates the promotion of educational and economic interests of Scheduled Castes (SCs), Scheduled Tribes (STs), and other weaker sections.

However, Champakam Dorairajan, a Brahmin woman, challenged this order in the Madras High Court, arguing that it violated her Right to Equality (Article 14).

Supreme Court Verdict (1951)

A five-judge Supreme Court (SC) bench upheld the Madras High Court’s decision, striking down the Communal GO as unconstitutional. The key takeaways from the ruling:

  • Violation of Fundamental Rights: The SC ruled that caste-based reservations in education violated Article 14 (Right to Equality) and Article 15(1) (Prohibition of Discrimination on Grounds of Religion, Race, Caste, Sex, or Place of Birth).

  • Supremacy of Fundamental Rights: The court held that FRs prevail over DPSPs, meaning any law violating FRs cannot be justified by citing DPSPs.

  • Parliament’s Power to Amend: This case paved the way for Parliament to amend FRs through constitutional amendments.

Impact of the Verdict

The ruling invalidated caste-based reservations in education, as the Constitution only permitted reservations in public employment (Article 16(4)) at that time. To address this, the government enacted the 1st Constitutional Amendment Act, 1951, restoring education-based reservations.

1st Constitutional Amendment Act, 1951

To override the Supreme Court’s ruling, the 1st Constitutional Amendment introduced Article 15(4), allowing the state to make special provisions for Socially and Educationally Backward Classes (SEBCs), SCs, and STs. This amendment laid the constitutional foundation for educational reservations.

Key Constitutional Provisions for Vulnerable Groups

  • Article 15(1): Prohibits discrimination based on religion, race, caste, sex, or place of birth.

  • Article 15(4): Allows special provisions for SEBCs, SCs, and STs, enabling educational reservations.

  • Article 16(4): Permits reservations in public employment for backward classes.

  • Article 17: Abolishes untouchability.

  • Article 46 (DPSP): Directs the state to promote the educational and economic interests of SCs, STs, and weaker sections.

Other Key Judgments on FRs vs. DPSPs

Golaknath Case (1967)

  • The SC overturned Champakam Dorairajan’s ruling, stating that Parliament cannot amend Fundamental Rights.

  • This decision led to the 24th Constitutional Amendment Act, 1971, restoring Parliament’s power to amend FRs.

Kesavananda Bharati Case (1973)

  • The 25th Constitutional Amendment Act, 1971 introduced Article 31C, which protected laws implementing Article 39(b) & (c) from judicial review.

  • The SC upheld this provision but introduced the Basic Structure Doctrine, stating that Parliament cannot alter the Constitution’s fundamental principles, including judicial review.

Minerva Mills Case (1980)

  • The 42nd Constitutional Amendment Act, 1976 extended Article 31C to all DPSPs, prioritizing them over FRs.

  • The SC struck down this expansion, emphasizing a harmonious balance between FRs and DPSPs.

Current Status

Fundamental Rights generally take precedence over DPSPs, but Parliament can amend Articles 14 and 19 to implement Article 39(b) and 39(c).

Conclusion

The Champakam Dorairajan Case reaffirmed the supremacy of Fundamental Rights over DPSPs, influencing constitutional amendments and judicial interpretations. The evolution through Golaknath, Kesavananda Bharati, and Minerva Mills cases ensured a balance between social justice and individual liberties while preserving judicial review as a constitutional safeguard.

MCQs for UPSC CSE

1. What was the key ruling of the Champakam Dorairajan Case (1951)?

(a) Parliament cannot amend Fundamental Rights 

(b) Directive Principles have supremacy over Fundamental Rights 

(c) Fundamental Rights prevail over Directive Principles 

(d) Caste-based reservations are constitutional

Answer: (c) Fundamental Rights prevail over Directive Principles

2. Which amendment introduced Article 15(4) to allow reservations in education?

(a) 24th Constitutional Amendment 

(b) 1st Constitutional Amendment 

(c) 42nd Constitutional Amendment 

(d) 44th Constitutional Amendment

Answer: (b) 1st Constitutional Amendment

3. Which Supreme Court case introduced the Basic Structure Doctrine?

(a) Champakam Dorairajan Case 

(b) Golaknath Case 

(c) Kesavananda Bharati Case 

(d) Minerva Mills Case

Answer: (c) Kesavananda Bharati Case

4. Which constitutional amendment was struck down in Minerva Mills Case (1980)?

(a) 1st Amendment 

(b) 25th Amendment 

(c) 42nd Amendment 

(d) 44th Amendment

Answer: (c) 42nd Amendment

5. What is the main objective of Article 46 (DPSP)?

(a) Ensure equality before the law 

(b) Promote educational and economic interests of SCs, STs, and weaker sections 

(c) Provide free legal aid 

(d) Abolish untouchability

Answer: (b) Promote educational and economic interests of SCs, STs, and weaker sections

Mains Question

Analyze the Supreme Court’s evolving stance on the conflict between Fundamental Rights and Directive Principles, citing key cases.

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