Article 14 Does Not Forbid Reasonable Classification for The Purposes of Legislation

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The Supreme Court comprising of Justice L. Nageswara Rao and Justice Hemant Gupta upheld a compassionate appointment regulation of Rajasthan State Road Transport Corporation which barred dependents of a deceased employee from claiming compassionate appointment in case of death of an employee while travelling in the vehicle of the Corporation.

The bench observed that though Article 14 of the Constitution of India forbids class legislation, it does not forbid reasonable classification for the purposes of legislation.

The Apex Court bench observed that the dependents of a deceased employee who claim compensation from the Corporation under the Act and compassionate appointment from the Corporation from a separate class. The bench said:

 “The Corporation has carved out two classes of dependents of the deceased employees in respect of claims for compassionate appointment. The reason for the disqualification of the dependents of an employee who died in an accident involving the vehicle of the Corporation is to avoid extra burden on the Appellant- Corporation. In such cases, the Appellant- Corporation has to pay the compensation under the Act and also to provide compassionate appointment to the dependents of the deceased employee. In a case where the vehicle of the Appellant- Corporation is not involved in the accident, the compensation under the Act is not the liability of the Appellant- Corporation. It cannot be said that the dependents of an employee who claim both compensation under the Act and compassionate appointment from the Appellant- Corporation are on the same footing as the dependents of the deceased employee whose claim under the Act against a private owner or an insurance company, and compassionate appointment from Appellant-Corporation.”

 Reiterating the principle of reasonable classification, the bench observed:

It is well-settled that though Article 14 forbids class legislation, it does not forbid reasonable classification for the purposes of legislation. When any impugned rule or statutory provision is assailed on the ground that it contravenes Article 14, its validity can be sustained if two tests are satisfied. The first test is that the classification on which it is founded must be based on an intelligible differentia which distinguishes persons or things grouped together from others left out of the group; and the second test is that the differentia in question must have a reasonable relation to the object sought to be achieved by the rule or statutory provision in question

 The bench noted that the intention with which Regulation 4(3) is made is to obviate the liability of the Corporation in payment of compensation under the Act and to provide compassionate appointment to the same person. While allowing the appeal, the bench further observed:

“The two categories of dependents i.e. dependents of employees who have died in an accident while travelling in a vehicle belonging to the Corporation and dependents of the employees who died while travelling in a vehicle not belonging to the Corporation are not similarly situated in respect of their claims against the Corporation. They cannot be treated as equals. Therefore, Regulation 4(3) cannot be said to be discriminatory. “.

Source: Livelaw.com