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Article 14 permits reasonable classification for administrative purposes if based on intelligible differentia and having rational nexus with the object sought to be achieved — a principle applied in cases like ______ to uphold affirmative action policies.
- Kesavananda Bharati
- Indra Sawhney
- Minerva Mills
- SR Bommai
Answer: Indra Sawhney
Article 14 classification principle: (a) Reasonable classification test: (i) Intelligible differentia: Classification must distinguish persons/things grouped together from others left out, (ii) Rational nexus: Differentia must have reasonable connection with object sought to be achieved by law/policy, (b) Indra Sawhney (1992) application: Upheld OBC reservation as reasonable classification: (i) Intelligible differentia: Socially and educationally backward classes distinct from forward castes, (ii) Rational nexus: Reservation aims to remedy historical disadvantage, promote substantive equality, (c) Evolution: From formal equality (treating likes alike) to substantive equality (addressing structural disadvantage) — classification permitted to achieve transformative justice, (d) Proportionality overlay: Modern cases apply proportionality to ensure classification not overbroad, underinclusive, or arbitrary; creamy layer exclusion ensures benefits reach neediest, (e) Balance: Equality not uniformity; reasonable classification enables affirmative action while preventing reverse discrimination. Illustrates adaptive constitutionalism: Article 14 interpreted to advance substantive equality for marginalized groups through calibrated classification.