1989 (2) TMI 409 - SC - Indian Laws

Summary

Issues Involved:
1. Constitutional validity of the rule restricting admission to evening classes of the Three-Year LL.B. Degree Course to regular employees of Government/Semi-Government institutions.
2. Reasonableness of the classification under Article 14 of the Constitution.
3. Justification for excluding private sector employees from admission.
4. Reservation of 100% seats for a specific class in educational institutions.
5. Relief to the appellants.

Summary:

1. Constitutional Validity of the Rule:
The appellants challenged the rule restricting admission to evening classes of the Three-Year LL.B. Degree Course to regular employees of Government/Semi-Government institutions, arguing it violated Article 14 of the Constitution. The High Court dismissed their writ petitions, upholding the rule.

2. Reasonableness of the Classification:
The Supreme Court reiterated that Article 14 forbids class legislation but allows reasonable classification. The classification must be based on an intelligible differentia and have a rational nexus to the objective. The Court found the rule deviated from its objective of accommodating employees unable to attend morning classes. The classification excluding private sector employees did not satisfy the test of intelligible differentia and was deemed unreasonable.

3. Justification for Excluding Private Sector Employees:
The respondents justified the exclusion on grounds of preventing bogus employment certificates and ensuring public interest by educating Government/Semi-Government employees. The Court found these reasons insufficient to justify the exclusion, noting that both private and public employees were equally disadvantaged in attending morning classes. The exclusion was thus deemed unfair and unjust.

4. Reservation of 100% Seats:
The Court addressed the issue of reserving 100% seats in evening classes for regular employees. It held that such reservation at the cost of merit was impermissible. Citing precedents, the Court stated that reservation should not exceed 50% of the seats after accounting for other valid reservations. The remaining seats should be open to general candidates on a merit basis.

5. Relief to the Appellants:
The appellants, having been refused admission under the invalid rule, were entitled to relief. The Court directed the respondents to admit the appellants in the second semester of the LL.B. course, adding their seats to the normal intake. The judgment of the High Court was set aside, and the impugned rule was struck down as discriminatory and violative of Article 14.

Conclusion:
The appeals were allowed, the impugned rule was struck down, and the appellants were granted admission. The Court emphasized that the classification must be reasonable and serve a logical objective, ensuring fairness and equality as mandated by Article 14 of the Constitution.