Q. While celebrating 75 years of the Indian Constitution, there is discussion on “the woman in nine yard of saree who triggered First Amendment to the Constitution.” Elucidate the case.
Ans: The phrase refers to Srimathi Champakam Dorairajan, a Brahmin woman from Madras, whose legal challenge in 1951 led to the First Amendment of the Indian Constitution. Her case highlighted the tension between Fundamental Rights and Directive Principles of State Policy, shaping India’s approach to affirmative action.
Background of the Case:
- In 1948, the Madras government issued a Communal Government Order (G.O.) that reserved seats in educational institutions based on caste and religion.
- Dorairajan was denied admission to a medical college despite being academically qualified, as the quota for Brahmins was already filled.
- She filed a petition in the Madras High Court, arguing that the G.O. violated her Fundamental Rights, especially Article 15(1) (prohibition of discrimination) and Article 29(2) (equal access to educational institutions).
Supreme Court Verdict:
- In State of Madras v. Champakam Dorairajan (1951), the Supreme Court ruled that the Communal G.O. was unconstitutional, as it violated Articles 15(1) and 29(2).
- The Court held that Fundamental Rights prevail over Directive Principles, such as Article 46, which promotes the welfare of weaker sections.
Impact and First Amendment:
- The judgment created a legal barrier to caste-based reservations in education.
- To overcome this, the government introduced the First Constitutional Amendment (1951).
- It added Article 15(4), empowering the state to make special provisions for socially and educationally backward classes, including Scheduled Castes and Scheduled Tribes.
Conclusion:
Champakam Dorairajan’s case became a turning point in constitutional history, balancing individual rights with social justice. Her quiet defiance in a nine-yard saree reshaped India’s legal framework, enabling affirmative action and laying the foundation for inclusive development.