Judgement of the day: STATE OF MADRAS V. CHAMPAKAM DORAIRAJAN (AIR1951 SC 226)


• In 1951, a Brahmin girl named Champakan Dorairajan failed to get admission in a medical college in Madras even after securing sufficient marks because of an order (communal G.O.) issued by Madras government.

• The communal GO states that the seats should be filled in by the selection committee on the following basis, i.e., out of every 14 seats, 6 were to be allotted to non-Brahmin Hindus, 2 to backward Hindus, 2 to Brahmins, 2 to Harijans, 1 to Anglo Indians and Indian Christian and 1 to Muslim.

• Champakan Dorairajan then appealed to the Honourable Madras HC to issue the writ of mandamus under Art. 226 of the Indian Constitution against government order for the protection of her fundamental rights under Art. 15(1) and Art. 29(2).

• The Madras HC held that the case involves a substantial question of law and therefore it upheld the petitioner’s Later the state appealed in the Supreme Court against Madras HC decision.


This was a landmark verdict that led to the amendment in Article 15 of the Constitution, because of this decision of SC clause 4 was added in Article 15 of the Constitution. This judgment makes it clear that no education institutions can reserve seats based on religion or caste. This led to the major reform in the reservation system in India. This judgment is still followed by all education institutions in India.

The chapter of Fundamental Rights is hallowed and cannot be abridged by any Legislature or Executive act or order, except to the extent provided in the appropriate Article in Part III.

This judgement sends a clear message that educational institutions should not discriminate against any student in the name of law till the time it does not have the element of reasonableness. The Constitution talks about “classes” and not “castes”. So any discrimination based on caste will be a grave violation of the Constitution.

This judgment serves as a guideline for the Supreme Court in giving judgements in the future. As a result this led to the major decision in our reservation system. In the case of M.R. Balaji v. State of Mysore, The Court held that it is unreasonable and unconstitutional to reserve 68% seats for Scheduled Castes, Tribes, Backward classes and more Backward classes and the reservation should be less than 50% and how much less than 50% it would depend upon the prevailing circumstances.

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