Landmark Judgements on Article 15

Introduction


Article 15 forbids any form of discrimination based on a person's caste, race, gender, national origin, or religion. Access to public spaces including parks, stores, hotels, and restaurants are guaranteed under the Indian Constitution and may not be denied on the basis of a person's disability.

As a result of Article 15, Indian society has been able to stand strong in the face of increasing diversity as well as sexism and bigotry. It acts as a safeguard for the vulnerable and a barrier against bigotry. Despite the caste system, India has always been a united and egalitarian nation.

When it comes to helping those in need, Article 15 has always gone above and beyond. Since it began in 1949, the oppressed have seen tremendous gains in their situation. It gives the government all the tools it needs to enact laws that foster coexistence. The frequency of atrocities committed against the poor has dropped drastically.

    Janhit Abhiyan v. Union of India 

    The Indian Supreme Court, in the case of Janhit Abhiyan vs. Union of India, upheld the constitutionality of the Constitution (One Hundred and Third Amendment) Act, 2019, and the EWS reservation. 

    This case has had a significant impact because it ensured that people from economically disadvantaged backgrounds were not discriminated against in either educational or occupational pursuits. The EWS reservation serves as a permissive provision, allowing the state to make exceptional arrangements in terms of access to education and employment for economically disadvantaged members of society. 

    Thanks to the EWS quota, formerly unattainable opportunities in higher education and secure employment are now within reach of those from low-income families. Concerns have been voiced about how the introduction of reserve for Economically Weaker Sections (EWS) would affect the current reservations for SCs, STs, and OBCs.

    Existing bookings must not be diluted, and the total reservation percentage must be kept below 50%. Despite these reservations, the lawsuit has had a good influence because it seeks to help the poor and increase social and economic equality in India. 

    To make sure the EWS reservation is effective without disrupting other reservations, diligent monitoring of its deployment is essential.
     

    DP Joshi vs. State of Madhya Bharat

    Article 15(1) of the Indian Constitution forbids discrimination on a number of grounds, and this provision was invoked in the landmark case of DP Joshi vs. State of Madhya Bharat to challenge the constitutionality of a reservation order providing seats in medical and engineering colleges for candidates from backward classes. 

    The reservation order was maintained by the Supreme Court, which reasoned that Article 15(1) does not prevent the government from assisting economically and educationally disadvantaged groups.

    The Court emphasised that such laws should not be based on caste but on objective criteria like socioeconomic and educational backwardness if they are to be constitutionally upheld. The Court also emphasised the need for a reservation policy that can adapt to shifting demographic and economic realities.


    M. Nagaraj vs. Union of India

    In this judgement, the Supreme Court reaffirmed the significance of the "creamy layer" principle in reserving for SCs and STs in promotions within the public sector. The court ruled that the state must offer evidence of historical disadvantage and inadequate representation in order to justify the proposed promotions. 

    According to the court's analysis, the Rules of 2002 are unworkable since they run counter to Constitutional provisions such as Article 16(4)(A) and (B) and Article 335. The Nagaraj case ruled that the rules' provisions on quotas, backlog vacancies, unfilled positions carried forward, and roster operation were in violation of the law. 

    Unfilled reserved posts, which are not included against the 50% cap, were identified as the primary cause of the problem, and their numbers kept rising indefinitely. The court ruled that promotions of SC/ST category individuals made under these criteria were unlawful and must be overturned, potentially affecting more than 50,000 employees across a wide range of levels.

    State of Madras vs. Champakam Dorairajan


    The first amendment to India's Constitution was made possible by this landmark judgement. By inserting clause 4 into the Constitution, the First Amendment makes room for a reservation policy. 

    In its current form, Clause 4 of the Constitution authorises the state to aid the Scheduled Caste and Scheduled Tribe through educational and socially beneficial initiatives. The first amendment to the Constitution was ratified even as the Lok Sabha was being established. Back in 1952, it all got rolling.

    It was the first option taken to settle the tension between basic liberties and public policy maxims. In this landmark case, the Supreme Court found that a government directive creating quotas for specific religious and ethnic groups in schools violated the Constitution.

    The ruling established the principle of "reasonable classification," which states that socioeconomic and educational disadvantages should be prioritised over religious or caste affiliation when determining eligibility for affirmative action and reservations.

    Conclusion

    By fostering unity and minimising crimes against the poor, Article 15 has greatly improved the lives of those on the margins in India. Its goal is to guarantee socially disadvantaged groups are given equal opportunity and growth by outlawing discrimination based on religion, race, caste, gender, or place of birth.

    Although reservations have been a source of contention, it is not their intention to cause division but rather to help the poor. The article has helped reduce inequality and protect India's unity and equality, in line with the Constitution's preamble, yet discrimination still exists.

    In India, social justice and equality have been greatly advanced through major Article 15 rulings. These decisions represent the judiciary's attempt to maintain a meritocracy while yet supporting affirmative action. These rulings have helped move the country in the direction of a more inclusive and equal society, and Article 15 continues to be a potent tool in the battle against discrimination.

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