B. Early Fundamental Rights Jurisprudence
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| Case | Year | Holding |
|---|---|---|
| Charanjit Lal Chowdhury v. Union of India | 1950 | Laid down the presumption of constitutionality — a legislature is presumed to act within its powers and reasonably classify persons/things unless the challenger proves otherwise; foundational to all later Art. 14 analysis. |
| State of Madras v. V.G. Row | 1952 | On testing "reasonable restrictions" under Art. 19, held courts must weigh the nature of the right, the extent and urgency of the restriction, and the prevailing conditions — not accept the legislature's own view of reasonableness at face value. |
| State of West Bengal v. Anwar Ali Sarkar | 1952 | Struck down a special-courts law for lacking "intelligible differentia" — the foundational statement of the Art. 14 "reasonable classification" test (classification must be founded on intelligible differentia, and that differentia must have a rational nexus to the object sought). |
| A.K. Kraipak v. Union of India | 1969 | Blurred the older rigid line between "administrative" and "quasi-judicial" functions — held principles of natural justice (like bias and a fair hearing) apply to purely administrative decisions too, wherever they affect rights. |
Notes. These four cases are the toolkit exams draw on whenever a question describes a law and asks whether it survives Art. 14 or Art. 19 scrutiny: Charanjit Lal Chowdhury gives you the presumption of validity, Anwar Ali Sarkar gives you the two-part classification test (intelligible differentia + rational nexus), V.G. Row gives you the proportionality-style approach to "reasonable restriction," and Kraipak extends natural-justice protections beyond formal tribunals into ordinary administrative decision-making.
Mnemonic. "CRAK the Article 14 code" — Charanjit Lal Chowdhury (1950) → Row, i.e. V.G. Row (1952) → Anwar Ali Sarkar (1952) → Kraipak (1969). Image: a locksmith "cracking" open the Article 14 safe, one tumbler (case) at a time, in that order.