In E. P. Royappa v. State of Tamil Nadu, AIR 1974 SC 555, the Supreme Court expanded Article 14 by holding that:
Aequality and arbitrariness are sworn enemies — an arbitrary State action violates Article 14
Bany classification must withstand the strictest 'compelling State interest' standard
Cequality before the law must be confined to the formal Diceyan sense alone, not substantive
DArticle 14 cannot be invoked against the legislature but only against the executive's acts
Answer & Solution
Correct answer: A. equality and arbitrariness are sworn enemies — an arbitrary State action violates Article 14
1. Bhagwati J. in Royappa held: 'Equality is a dynamic concept with many aspects and dimensions and it cannot be cribbed, cabined and confined within traditional and doctrinaire limits.'
2. He added the famous formulation: 'equality and arbitrariness are sworn enemies' — any arbitrary State action is, eo ipso, violative of Article 14.
3. This 'arbitrariness doctrine' supplemented the older Anwar Ali Sarkar twin test.
4. The 'compelling State interest' test belongs to American constitutional law and was not adopted in Royappa.
_Source: Constitution of India (Bare Act, updated to 105th Amendment Act 2021), Govt. of India Legislative Dept., E. P. Royappa v. State of Tamil Nadu, AIR 1974 SC 555_
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