State of West Bengal v. Anwar Ali Sarkar (1952)

Constitutional Law I · Right to Equality — Article 14

Facts.

A West Bengal law let the government pick particular cases and send them to special courts that followed a speedier, less protective procedure than ordinary criminal courts. Anwar Ali Sarkar, tried by such a court, challenged the law under Article 14.

Issue.

Does a law that allows the executive to single out cases for a harsher procedure, without any guiding principle, violate the equality guarantee of Article 14?

Held.

The Court struck the provision down. Article 14 forbids class legislation but permits reasonable classification, which must satisfy two tests — an intelligible differentia (a real basis for the grouping) and a rational nexus between that basis and the object of the law. The law gave the executive an uncontrolled discretion with no such basis, and so failed.

Why it matters.

It is the classic authority on the twin test of reasonable classification, cited in almost every Article 14 problem to this day.

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