Chiranjit Lal Chowdhuri v. Union of India
Rule established
A statute may validly single out one enterprise for special treatment (nationalisation/takeover) if there is an intelligible differentia with a rational nexus to the object sought. Classification need not be abstract; it can be a "class of one" if circumstances justify.
Facts
- Sholapur Mills was mismanaged; production declined; workers faced unemployment
- Parliament enacted the Sholapur Spinning and Weaving Company (Emergency Provisions) Act, 1950
- Act applied only to this one company
- Chiranjit Lal (shareholder) challenged under Article 14, 19(1)(f), and 31
Issue
- Whether legislation targeting a single company violates Article 14 (right to equality).
Held
- Classification can be of a single entity ("class of one") if circumstances are peculiar
- Mismanagement causing large-scale unemployment created intelligible differentia
- Rational nexus existed between the differentia and the object (protecting workers, restoring production)
- Act upheld as constitutionally valid
Ratio Decidendi
Article 14 permits reasonable classification. A single entity may constitute a class by itself if the circumstances peculiar to it furnish an intelligible differentia bearing rational nexus to the object of the legislation.
How to use it in an exam
- "Class of one" doctrine under Article 14
- Bridges constitutional law and labour law (workers' protection as legislative object)
- Key line: "In Chiranjit Lal Chowdhuri v. Union of India (1951), the Supreme Court held that legislation targeting a single company is valid under Article 14 if peculiar circumstances create an intelligible differentia with rational nexus to the legislative object."
Source
Source: AIR 1951 SC 41
This is an educational summary, not the judgment itself. Cite the reported version in professional or academic work.