Precedents Cited

The judgment extensively references several key Supreme Court decisions that shape the interpretation of Article 14 concerning discrimination and arbitrary legislation:

• Chiranjit Lal Chowdhuri v. The Union of India (1950 INSC 36): Addressed differential legislation affecting a single company, emphasizing that such acts must have reasonable classification and nexus with their objectives.
• S.P. Mittal v. Union of India (1983 INSC 81): Highlighted the necessity for legislation targeting single entities to be based on substantial and non-arbitrary grounds.
• Shayara Bano v. Union of India (2017 INSC 78): Clarified the concept of manifest arbitrariness in legislation under Article 14.
• Subramanian Swamy v. CBI (2014 INSC 607): Reinforced that legislation can be struck down for being arbitrary if it lacks rational basis.
• Additional cases like Dharam Dutt v. Union Of India (2004 INSC 667) and Cellular Operators Assn. of India v. TRAI (2016 INSC 703) were also cited to support the arguments against discriminatory and arbitrary legislative actions.

Legal Reasoning

The core legal issue revolved around whether the State of Punjab's repeal of Khalsa University constituted arbitrary and discriminatory action in violation of Article 14. The Supreme Court analyzed the following:

• Classification Validity: The Court examined whether the repeal act involved a valid classification under Article 14, assessing if there was an intelligible differentia with a rational nexus to the objective of the legislation.
• Arbitrariness: The Court evaluated whether the repeal act was manifestly arbitrary, lacking in reason, fairness, or public interest justification.
• Burden of Proof: Emphasizing the presumption of constitutionality in legislation, the Court held that the burden was on the appellants to demonstrate the arbitrary and discriminatory nature of the repeal act.
• Contextual Factors: The Court noted the absence of compelling evidence or legislative intent justifying the targeted repeal of Khalsa University, especially when compared to other universities operating under the same policy framework.

The Supreme Court concluded that the repeal act lacked a rational basis for singling out Khalsa University, making it discriminatory and manifestly arbitrary, thereby violating Article 14.

Impact

This judgment has profound implications for future legislative actions, particularly those targeting specific institutions or entities. Key impacts include:

• Strengthening Equal Protection: Reinforces the judiciary's stance against discriminatory legislation, ensuring that any differential treatment must be justified with reasonable grounds.
• Limit on Legislative Power: Acts as a check on the legislature's power to enact laws that adversely affect specific entities without substantial justification.
• Guidelines for Singling Out: Establishes clear criteria that must be met for legislation targeting single entities, including the necessity of emergent and extraordinary circumstances preceded by thorough inquiries and consultations.
• Precedent for Educational Institutions: Particularly relevant for the higher education sector, ensuring universities and colleges are protected against arbitrary state actions affecting their establishment and operation.

Future cases involving similar issues will likely reference this judgment to ascertain the validity of targeted legislative actions under the purview of Article 14.