State of Madras v. Champakam Dorairajan

State of Madras v. Champakam Dorairajan (AIR 1951 SC 226) is a landmark decision of the Supreme Court of India. This judgement led to the First Amendment of the Constitution of India. It was the first major judgement regarding reservations in Republic of India. In its ruling the Supreme Court upheld the Madras High Court judgement, which in turn had struck down the Government Order (G.O) passed in 1927 in the [Madras Presidency]. The G.O had provided caste based reservation in government jobs and college seats. The Supreme Court's verdict held that providing such reservations was in violation of Article 29 (2) of the Indian Constitution.[1]

State of Madras v. Chamakam Dorairajan
Court	Supreme Court of India
Full case name	State of Madras v. Champakam Dorairajan
Citation(s)	AIR 1951 SC 226
Case history
Subsequent action(s)	Enactment of the First Amendment to the Constitution of India.

Here, the court held that Directive Principles of State Policy have to conform to and run as subsidiary to the Chapter of Fundamental Rights. Chapter on Fundamental Rights were sacrosanct, and DPSPs as in article 37 are expressly made unenforceable by a Court, hence, cannot override the provisions found in Part III which, notwithstanding other provisions, are expressly made enforceable by appropriate Writs, Orders or directions under article 32. DPSP can only be implemented as long as there is no infringement of Fundamental Rights under Part III, subject to limitations to legislative and executive powers provided under different parts of the Constitution. It as only in Minerva Mills case that a balance between Fundamental Rights and DPSP was sought.[2][3]