SC explains the dual test for a classification to be valid classification

The Hon’ble Supreme Court, on 11thJuly 2019, in the matter of All Manipur Pensioners Association by its Secretary v. The State of Manipur and others pronounced that the State cannot arbitrarily pick and choose from amongst similarly situated persons, a cut­-off date for extension of benefits especially pensionary benefits.

The Hon’ble Supreme Court observed that:

A valid classification is truly a valid discrimination. It is true that Article 16 of the Constitution of India permits a valid classification. However, a very classification must be based on a just objective. The result to be achieved by the just objective presupposes the choice of some for differential consideration/treatment over others. (Para 8)

A classification to be valid must necessarily satisfy two tests. Firstly, the distinguishing rationale has to be based on a just objective and secondly, the choice of differentiating one set of persons from another, must have a reasonable nexus to the objective sought to be achieved. (Para 8)

The test for a valid classification may be summarised as a distinction based on a classification founded on an intelligible differentia, which has a rational relationship with the object sought to be achieved. (Para 8)

Whenever a cut-­off date is fixed to categorise one set of pensioners for favourable consideration over others, the twin test for valid classification or valid discrimination therefore must necessarily be satisfied. (Para 8)

The State cannot arbitrarily pick and choose from amongst similarly situated persons, a cut­-off date for extension of benefits especially pensionary benefits. There has to be a classification founded on some rational principle when similarly situated class is differentiated for grant of any benefit. (Para 8)

Whenever a new benefit is granted and/or new scheme is introduced, it might be possible for the State to provide a cut­-off date taking into consideration its financial resources. But the same shall not be applicable with respect to one and single class of persons, the benefit to be given to the one class of persons, who are already otherwise getting the benefits and the question is with respect to revision.  (Para 8.1)

Copy of judgement: Judgement_11th-Jul-2019

-Tushar Kaushik

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