Name of the Case : State of Madras vs. Champakam Dorairajan
Year of Judgement : 1951
Popular Name : -
Related Topic/ Issue : Communal reservation in admission to educational institutions
Related Article/ Schedule : 15, 29 & 46
Supreme Court Judgement
- Affirmed the judgement of the Madras High Court.
- Struck down the order issued by the Madras Government (known as the Communal GO) that provided for proportionate reservation of seats in government medical and engineering colleges for different communities.
- Held that the Communal GO was based on religion, race, and caste, thus violating Articles 15(1) and 29(2).
- Declared that directive principles cannot override or abridge fundamental rights.
- Stated that directive principles have to conform to and run as subsidiary to the fundamental rights.
Impact of the Judgement
- Led to the insertion of a new Clause (4) in Article 15 by the 1st Amendment Act (1951).
- This clause permits the state to make any special provision for the advancement of socially and educationally backward classes of citizens or for the SCs and STs.
- In this way, the effect of the judgement was nullified.
