State of Madras v. Champakam Dorairajan (1951)

Constitutional Law I · Protective Discrimination — Articles 15 & 16

Facts.

A Madras government order reserved seats in State medical and engineering colleges on a communal basis across castes and communities. Champakam Dorairajan, denied admission, challenged the order.

Issue.

In a conflict, do the Directive Principles (here, promoting weaker sections) prevail over the Fundamental Rights (equality and non-discrimination in admission under Articles 15 and 29(2))?

Held.

The Court held that in a direct conflict the Fundamental Rights prevail over the non-justiciable Directive Principles, and struck down the communal order as violating Article 29(2).

Why it matters.

It is the starting point of the FR–DPSP story and provoked the First Amendment (1951), which inserted Article 15(4) to enable special provisions for backward classes — the birth of protective discrimination.

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