ClassificationClass of oneSupreme Court of India

Chiranjit Lal Chowdhuri v Union of India

AIR 1951 Supreme Court 4119511 min read
The case in brief30-second read
Facts
Sholapur Mills was mismanaged; production declined; workers faced unemployment. Parliament enacted the Sholapur Spinning and Weaving Company (Emergency Provisions) Act, 1950.
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.
Principle
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.
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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

  1. 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.

Exam use

How to use it in an answer

  • "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."

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Citation

Chiranjit Lal Chowdhuri v. Union of India AIR 1951 Supreme Court 41

Reported: AIR 1951 SC 41. This is an educational summary, not the judgment itself. Cite the reported version in professional or academic work.