India’s First Amendment to the Constitution, officially known as the Constitution (First Amendment) Act, 1951, was enacted on June 18, 1951. It was proposed by Prime Minister Jawaharlal Nehru on May 10, 1951, in response to a landmark Supreme Court ruling.

Context: State of Madras v. Champakam Dorairajan

The amendment was triggered by the Supreme Court’s decision in State of Madras v. Champakam Dorairajan. In this case, the Supreme Court upheld a Madras High Court ruling that struck down a quota system for college admissions in Madras that was based on caste.

At that time, there was a reservation system for college seats: of every fourteen seats, six were allocated for non-Brahmins, two for backward castes, two for Brahmins, two for Harijans, one for Anglo-Indians and Indian Christians, and one for Muslims. This system was established under a Government Order from 1927.

The state government argued that this quota was justified under Article 46 of the Constitution, which aims to promote the educational interests of Scheduled Castes, Scheduled Tribes, and other weaker sections of society.

However, Shrimathi Champakam Dorairajan, a Brahmin, challenged this system in court. She claimed her rights were violated because, despite her good grades, she was denied admission to a medical college due to the quota system.

Legal Arguments and Decision

The state defended the quota system by citing Article 46, arguing it was intended to protect and uplift marginalized groups. Although Article 46 is part of the Directive Principles of State Policy and not enforceable by courts, the state believed these principles were crucial for governance.

Justice R. Das addressed both this case and another similar one. Ultimately, the Supreme Court ruled that the quota system violated the fundamental rights guaranteed by the Constitution.

Path to the First Amendment

This ruling led to the First Amendment, which added provisions to the Constitution that allowed for reservation policies. It established that the state could promote the welfare of backward classes, specifically Scheduled Castes and Scheduled Tribes, in educational and social contexts.

The First Amendment was ratified while the Lok Sabha was still being formed and marked a significant step in reconciling the tension between fundamental rights and the goals set out in the Directive Principles of State Policy.