Constitutional Law | July 3, 2025
ARTICLE 14 AND EQUALITY JURISPRUDENCE: THE SUPREME COURT AS A CATALYST FOR CHANGE
This Article is written by Yashita Bhardwaj Bcom. LL.B 5th year student at Banasthali Vidyapith
- Introduction:
Article 14, which clearly assures equality at the center of India's constitutional vision. The textual guarantee of equality would be meaningless, though, unless it were actively interpreted and put into practice in changing social conditions.
In this respect, the Indian Supreme Court has been instrumental in addressing systemic and structural discrimination in Indian society by turning Article 14 from a theoretical tenet of formal equality into a useful tool of substantive equality. According to this study, the Supreme Court has enlarged the scope of Article 14 by progressive interpretation, judicial innovation, and the doctrine of arbitrariness, making it the cornerstone of India's equality jurisprudence.
Furthermore, it explores the theoretical underpinnings of equality, the legislative background of Article 14, the key moments in its judicial interpretation, and the challenges and criticisms facing this developing legal framework.
By examining these aspects, the essay demonstrates how the Supreme Court has implemented constitutional morality to advance the ideals of justice, freedom, and dignity—a living Constitution in action.
II. Regulatory System for Article 14:
The former, which is rooted in British customs, suggests the unfavourable notion of lacking privilege, whereas the latter, which is based on the American Constitution, suggests the positive requirement that the state treat unequal things unequally and guarantee equality before the law for those who are equal. The Constituent Assembly debates reflect the framers' concept of creating a just and fair society, one that would prevent the socioeconomic inequalities left behind by colonialism from compounding structural disadvantages.
Article 14 must be understood in conjunction with Articles 15, 16, 17, and 21 in order to completely understand its overall contribution to Indian constitutional law, as equality underpins the rights to life, liberty, and dignity.
In the beginning, Article 14 was interpreted in light of the rational categorization notion, which permitted the State to categorize on the basis of comprehensible differentia and a logical connection to the goal to be achieved. Because a live interpretation was necessary, the concept of arbitrariness, which broadened the material application of Article 14, was developed.
III. The Role of Supreme Court Jurisprudence in Defining Article 14:
The court's responsiveness to the demands of social justice and the shifting needs of society is reflected in the several stages of development of Article 14. In its early stages, the Supreme Court focused on the notion of fair classification, supporting state laws that categorized individuals or groups according to reasonable distinctions that were logically related to the aim. However, the stringent application of this test sometimes permitted legislation to pass constitutional review notwithstanding its discriminatory consequences.
In the second phase, the Supreme Court's ruling in 1E.P. Royappa v. State of Tamil Nadu brought about a sea change by introducing the principle of arbitrariness, which states that it runs against equality and that any arbitrary act by the State violates Article 14, regardless of whether a reasonable classification was there or not. The Court maintained this stance in 2Maneka Gandhi v. Union of India by broadening the reach of Article 21 and combining it with Article 14, which stressed the need for legal procedures to be fair, reasonable, and just, rather than arbitrary.
This marked a significant step in comprehending equality, recognizing that an abstract idea of equality cannot guarantee justice in a highly unequal society.
The third phase concentrated on dismantling patriarchal structures that were ingrained in laws and putting Article14, which deals with gender equality, into practice.
In 3Anuj Garg v. Hotel Association of India, the Supreme Court decided that the prohibitions in the Punjab Excise Act that forbid women from working in establishments that sell alcohol are discriminatory and protective. In a similar vein, the Court implemented Article 14 in both public and private life by enacting legislation in 4Vishaka v. State of Rajasthan to address sexual harassment at workplace.
IV. Obstacles and Key Assessment:
By interpreting Article 14 broadly, the Supreme Court of India has largely transformed it into a tool to fight institutionalized discrimination and advance social justice, thus contributing to the achievement of material equality. By applying the concept of arbitrariness, the courts have managed to overturn laws and governmental actions that support inequality, even when there is no clear evidence of discrimination. The judiciary has managed to address the cultural and economic factors of discrimination and acknowledge the true experiences of marginalized groups by prioritizing substantive equality.
This lenient approach, however, has faced backlash, particularly concerning judicial overreach and the inequitable application of the arbitrariness principle. Due to the limitations set by traditional ideals, some choices have embraced a progressive perspective on equality, while others have resisted; thus, equality legislation is inconsistent. Moreover, the horizontal application of Article 14, which has commenced in several instances, remains restricted and incapable of entirely addressing discrimination in the private sector.
Additionally, employing judicial interpretation to advance equality raises concerns regarding the democratic legitimacy of those decisions, particularly when the legislative body has not acted. The successful establishment of equality initiatives through legislative frameworks is essential for the judiciary to actively uphold constitutional ethics.
V. Conclusive Argument: Academics such as Upendra Baxi contend that Article 14 should go beyond mere formal equality to effectively eradicate systems of oppression in society. M.P. Singh has evaluated the uneven enforcement of equality standards and emphasized the need for a systematic proportionality assessment.
Gautam Bhatia advocates for a rights-focused understanding of Article 14 that encompasses dignity, autonomy, and non-discrimination, aligning with international equality norms while being attuned to India's socio-economic context.
These critiques together highlight the necessity for consistency, clarity, and organized reasoning in equality adjudication under Article 14 to convert it into a powerful instrument for social justice.
VI. REFERENCES:
E. P. Royappa vs State Of Tamil Nadu & Anr 1974 AIR 555
Maneka Gandhi vs Union Of India1978 AIR 597
Anuj Garg & Ors vs Hotel Association Of India & OrsAIR 2008 SUPREME COURT 663
Vishaka & Ors vs State Of Rajasthan & OrsAIR 1997 SUPREME COURT 3011
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