State of Madras v Champakam Dorairajan

Facts

• A Government Order of the Madras Presidency provided for caste-based reservation of seats in state-run medical and engineering colleges
• Champakam Dorairajan, a Brahmin candidate, was denied admission despite securing higher marks than reserved-category candidates
• She challenged the order as violative of Art.29(2) (no denial of admission on grounds of religion, race, caste)
• The state defended the policy by invoking Art.46 (Directive Principle: promote educational interests of weaker sections)

Issue

1. Whether a state can justify a caste-based reservation policy that infringes Art.29(2) by relying on a Directive Principle, and how conflicts between Part III and Part IV are resolved.

Held

• The Madras High Court judgment striking down the Government Order was upheld
• Directive Principles, however fundamental in governance, are not enforceable in courts, and cannot override Fundamental Rights in Part III where a genuine conflict exists
• The reservation policy, lacking a specific enabling constitutional provision, violated Art.29(2)
• The judgment exposed a gap in the Constitution regarding reservations in educational institutions

Ratio Decidendi

Where Fundamental Rights and Directive Principles conflict, Fundamental Rights, being justiciable and enforceable, must prevail unless the Constitution itself is amended to permit the Directive Principle to operate notwithstanding the Fundamental Right.