Ram Krishna Dalmia v. Justice S.R. Tendolkar

Facts

The Central Government, under the Commissions of Inquiry Act, 1952, appointed a commission headed by Justice Tendolkar to investigate the affairs of companies and firms associated with Ram Krishna Dalmia. The order was challenged as discriminatory for singling out the petitioner's group.

Issues

• Whether the Act and the appointment of the commission to inquire into a particular group's affairs violated Article 14.
• What principles govern the application of the reasonable-classification test and the presumption of constitutionality.

Arguments

The petitioners argued they were arbitrarily singled out for hostile inquiry without any rational basis. The Union argued the inquiry concerned a definite matter of public importance and a legislature may classify, with a presumption that it understands and acts on the needs of its people.

Held

The Court upheld the Act and the commission. Das C.J. distilled the established propositions on Article 14: a law may be constitutional even if applied to a single individual where special circumstances form a class by themselves; there is a strong presumption of constitutionality; and the burden lies on the challenger to show a clear transgression. The classification must rest on an intelligible differentia with a rational relation to the object sought. Singling out a group for inquiry on definite material did not offend equality.

Ratio decidendi

Article 14 permits reasonable classification on an intelligible differentia rationally connected to the legislative object; statutes carry a presumption of constitutionality, and even a class of one may be valid where peculiar circumstances justify it.

Significance

The classic restatement and consolidation of the Article 14 classification doctrine, frequently cited for the catalogue of governing principles and the presumption of constitutionality. It systematised Anwar Ali Sarkar into a workable framework relied on in countless later cases.

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