Source: Supreme Court  

Why in News? 

Recently the Supreme Court observed that candidates within the same academic cohort cannot be discriminated against based on their admission date when determining eligibility for job appointments. This ruling raised the issue that the Rajasthan authorities' 2017 Teacher Grade III Level II recruitment notification set different graduation marks criteria based on the timing of candidates' B.Ed course admission. 

• Justices BR Gavai and KV Viswanathan held in the matter of Manilal v. the State of Rajasthan & Ors. 

What was the Background of Manilal v. the State of Rajasthan & Ors. Case? 

• On 11^th September 2017, Rajasthan authorities issued an advertisement for Teacher Grade III Level II positions in the Scheduled Area (TSP). 
• The advertisement provides different educational qualifications for candidates based on when they took admission to B.Ed courses: 
  • Those admitted before 31^st August 2009 needed a minimum of 45% marks in graduation. 
  • Those admitted after 31^st August 2009 needed a minimum of 50% marks in graduation. 
• The appellant had 44.58% marks in his graduation and secured admission to a B.Ed course on 23^rd October 2009. 
• The appellant from a reserved category met the qualifying percentage (40% marks) required for admission to the B.Ed Course at the time of his admission. 
• Despite scoring above the cut-off marks in the recruitment exam, the appellant's name did not appear in the provisional list of selected candidates. 
• The appellant was informed that his candidature was rejected because he had secured less than 45% marks in his graduation. 
• Aggrieved by this decision, the appellant filed a writ petition in the Rajasthan High Court. 
  • The Single Judge of the High Court dismissed the appellant's writ petition on 27th November 2018. 
  • The appellant then filed an appeal before the Division Bench of the Rajasthan High Court. 
• On 13^th November 2019, the National Council for Teacher Education (NCTE) issued a clarification stating that the minimum percentage requirement in graduation would not apply to candidates who had taken admission to B.Ed courses prior to 29th  July 2011. 
  • The Division Bench of the High Court dismissed the appellant's appeal on 27^th April, 2022. 
  • The appellant was initially appointed to the post pursuant to an interim order of the High Court dated 23^rd October 2021. 
• After the dismissal of his appeal, the appellant's appointment was cancelled on 7^th June 2022. 
• The appellant then approached the Supreme Court, challenging the High Court's decision. 

What were the Court’s Observations? 

• The Court observed that it would be improper to discriminate inter se among a homogenous group of students admitted for the academic session 2009-10. 
• The Court held that it would be discriminatory if students admitted in the first round of counselling were eligible with less than 50% marks in graduation, while others admitted in subsequent rounds were not. 
• The Court emphasized the principle of equality.  
• The Court took note of the NCTE notification dated 13th November 2019, which stated that minimum percentage of marks in graduation shall not be applicable to those who had taken admission to B.Ed courses prior to 29th July 2011. 
• The Court found that treating candidates differently based solely on their date of admission, when they were part of the same academic session and admission process, was not sustainable. 
• The Court determined that the High Court's judgment was not in consonance with the principles of equality and non-discrimination as enshrined in Article 14 of the Constitution of India, 1950 (COI). 
• The Court held that applying disparate qualifying criteria to candidates within the same academic cohort based solely on their round of admission would constitute arbitrary and unjustifiable discrimination. 
• The Court concluded that the appellant should not be disadvantaged merely because his admission was completed in a subsequent round of counselling. 

What is Reasonable Classification Under Article 14 of the COI? 

• Article 14 of the Indian Constitution guarantees equality before the law and equal protection of the laws. 
  • This does not mean that all laws must apply uniformly to all persons.  
  • The principle recognizes that different classes of people may require different treatment due to varying needs, circumstances, and societal factors. 
• Reasonable classification is an exception to Article 14 of the Constitution of India. 
• The doctrine of reasonable classification permits the State to make laws that treat different classes of persons differently, provided there is a rational basis for such classification. 
  • For a classification to be considered reasonable and not violative of Article 14, it must satisfy two essential tests as per State of West Bengal v. Anwar Ali Sarkar (1952): 
  • The classification must be founded on an intelligible differentia which distinguishes persons or things grouped from others left out of the group.  
  • The differentia must have a rational relation to the object sought to be achieved by the statute in question. 
• If the classification satisfies the test laid down in propositions, the law will be declared constitutional. 
  • The classification must not be arbitrary, artificial, or evasive.  
• It should be based on substantial distinctions and real differences. 
• The courts have consistently held that legislative wisdom in making classifications should be presumed, and the burden of proving unreasonableness lies on the person challenging the classification. 
• The differentia which is the basis of the classification, and the object of the Act are two distinct things. What is necessary is that there must be a nexus between the basis of classification and the object of the Act which makes the classification. 
• Even if a law discriminates, it can be upheld if there is a reasonable basis for the discrimination. 
• The principle of reasonable classification is not a substitute for the doctrine of classification.  
  • It is only one of the principles underlying the guarantee of equal protection of laws embodied in Article 14. 
• Prohibition of Class Legislation: Class legislation, which confers privileges on an arbitrarily selected group from a larger homogenous group, is forbidden.  
  • There must be a reasonable justification for including some and excluding others from the benefits or burdens of a law. 
• Substantial Difference: For a classification to be valid, there must be a substantial difference between those included and excluded from a particular law or privilege. This difference should justify the differential treatment. 
• Relation to the Object of the Law: The classification must have a rational relation to the object sought to be achieved by the law in question. 
• Equal Treatment in Unequal Circumstances: Identical treatment in unequal circumstances would amount to inequality. Therefore, differential treatment may sometimes be necessary to achieve true equality. 
• Legislative Discretion: The legislature has broad powers to classify persons and things upon which laws operate, given the diverse problems arising from various human relations. 
• Arbitrary Selection: A classification that arbitrarily selects a group for special treatment without any reasonable basis for distinction from others similarly situated would violate Article 14. 

What are Grounds for Reasonable Classification? 

• There are some important grounds for reasonable classification.  
  • Age  
  • Gender  
  • Geographical or territorial basis  
  • Nature of business or profession  
  • Nature of the source of authority  
  • Nature of offences and offenders  
  • Basis under tax laws  
  • State of Government  
  • Single individual or body as a class