What is the main issue in Hira Nath v. State of Rajasthan?

Whether a special tax on agricultural land, without a fair basis, violated Article 14’s equality guarantee.

What did the Supreme Court decide?

The Court struck down the special tax as unconstitutional because the classification lacked a reasonable basis.

How does Article 14 apply to taxes?

Article 14 allows classification for taxation, but it must be reasonable and based on intelligible differentia with a rational link to the goal.

Why was the tax discriminatory here?

It targeted agricultural land alone and ignored factors like income capacity and farmers’ financial conditions.

What principle from this case helps students?

Taxes can differ across groups, but the government must show a fair reason that fits the objective—mere labels are not enough.

Hira Nath v. State of Rajasthan

AIR 1973 SC 1260 — Article 14, reasonable classification, and a special tax on agricultural land

Supreme Court of India 1973 Citation: AIR 1973 SC 1260 Constitutional Law Reading time: ~7 min India

Author: Gulzar Hashmi Published: October 24, 2025 Slug: hira-nath-v-state-of-rajasthan

PRIMARY_KEYWORDS: Article 14 equality, reasonable classification, agricultural land tax SECONDARY_KEYWORDS: discrimination in taxation, intelligible differentia, Supreme Court 1973

Quick Summary

The State put a special tax on agricultural land. A farmer, Hira Nath, said this was unfair when other property was not taxed the same way.

The Supreme Court held the levy unconstitutional. The tax failed the Article 14 test because the classification was not reasonable and did not match the goal of the law.

Issues

Does a punitive tax on agricultural land, without similar treatment for other property or benefits to farmers, violate Article 14?

Rules

Article 14: Equality before law and equal protection of laws.
Reasonable classification: Must have an intelligible differentia and a rational nexus to the law’s purpose.
Tax power: State may classify for taxes, but not in an arbitrary or oppressive way.

Facts (Timeline)

Levy announced: Rajasthan created a special tax for agricultural landholders.

Challenge by farmer: Hira Nath filed a petition. He said the tax was discriminatory and ignored income capacity.

Question before SC: Does this design breach Article 14 because the class chosen and the goal do not connect?

Arguments

Petitioner (Hira Nath)

Targets only agricultural land; other property is spared.
No look at yield, soil, rainfall, or farmer’s means.
Thus, the tax is arbitrary and unequal.

State (Rajasthan)

Tax policy allows classification.
Agriculture is a distinct sector and may be taxed differently.
The levy supports revenue goals.

Judgment (Held)

Special tax struck down as unconstitutional.
Classification ignored earning capacity of land and farmers’ financial position.
No clear rational nexus between chosen class and the law’s aim.

Ratio Decidendi

A tax classification that picks a group (farmers) but ignores key differences (output, capacity, conditions) fails Article 14. Equality permits reasonable lines, not blind lines.

Why It Matters

Shows that tax laws must be fair in design, not just in words.
Teaches how to apply the two-part Article 14 test to classification and nexus.
Protects vulnerable groups from one-size-fits-all levies.