मद्रास राज्य बनाम चंपकम दोराइराजन
| Citation | AIR 1951 SC 226 |
| Court | Supreme Court of India (Constitution Bench) |
| Date | 9 April 1951 |
| Year | 1951 |
| Bench | M.H. Kania CJI, Saiyid Fazl Ali, M. Patanjali Sastri, Mehr Chand Mahajan, B.K. Mukherjea, S.R. Das, Vivian Bose JJ. |
| Acts/Articles | Article 15, Article 29(2), Article 46 |
| Category | Constitutional Law |
Key Principle Established
Communal reservation in educational institutions based on caste/religion violates fundamental right to equality. Fundamental Rights prevail over Directive Principles.
The State of Madras had fixed proportionate seats for different communities in State medical and engineering colleges. Champakam Dorairajan, a Brahmin, was denied admission despite having higher marks than reserved category candidates.
The Supreme Court struck down the communal reservation as unconstitutional, holding that Fundamental Rights prevail over Directive Principles. The State cannot abridge fundamental rights under the garb of implementing Directive Principles (Article 46).
This was one of the first landmark cases on reservation. It led directly to the First Constitutional Amendment (1951) which inserted Article 15(4), empowering the State to make special provisions for advancement of socially and educationally backward classes — the constitutional basis for reservation in education.
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Read AnalysisThis judgment summary is for educational and research purposes. While care has been taken to accurately represent the ratio and findings, for authoritative reference always consult the original judgment text from official sources (SCC Online, AIR, Manupatra, or court websites).
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