State of West Bengal v. Anwar Ali Sarkar (AIR 1952 SC 75)

Quick Summary

The Supreme Court struck down Section 5(1) of the West Bengal Special Courts Act, 1950. The law gave the Government a free hand to send any case to a Special Court without clear rules. Such unchecked power broke Article 14, which requires fair and non-arbitrary treatment.

Issues

• Is the West Bengal Special Courts Act, 1950, unconstitutional under Article 14?
• Can the State pick cases for Special Courts without a clear policy or standard?

Rules

• Article 14 — Equality before law; no arbitrary State action.
• Classification Test — Needs intelligible differentia and rational nexus with the goal.
• No Unguided Discretion — Wide, standardless power violates equality.

Facts (Timeline)

Arguments

Judgment (Held)

Section 5(1) was declared void. It gave the Executive arbitrary power to select offences or cases for Special Courts without clear rules. Such standardless discretion offended Article 14.

Also, the Special Courts’ procedure departed substantially from ordinary criminal procedure, intensifying the inequality.

Ratio Decidendi

1. Equality forbids naked discretion: power must be guided by policy and standards.
2. Classification must rest on intelligible differentia with a rational nexus to speedier trials—mere convenience is not enough.
3. Special procedures that sharply differ from CrPC need strong, objective justification; otherwise they are discriminatory.

Why It Matters

• Draws a firm line against standardless executive discretion.
• Protects accused from unequal criminal procedures.
• Strengthens Article 14’s role in criminal justice policy.

Key Takeaways

• No guidelines = unconstitutional under Article 14.
• Classification needs differentia + nexus, both proven.
• Special courts require clear, objective selection criteria.

Mnemonic + 3-Step Hook

Mnemonic: “ EQUAL needs RULES”

1. Ask: Is there a clear policy to pick cases?
2. Check: Differentia + Nexus with speedier trials?
3. Conclude: If not, it fails Article 14.

IRAC Outline

Issue: Is S.5(1) of the Special Courts Act valid under Article 14?

Rule: Equality allows reasonable classification, not arbitrary discretion.

Application: S.5(1) had no guiding standards; it let the Executive choose cases freely; special procedure departed from CrPC.

Conclusion: Section 5(1) is unconstitutional; convictions set aside and regular trial ordered.

Glossary

Article 14

Guarantees equality and bans arbitrary State action.

Intelligible Differentia

A clear basis that separates one group from another.

Rational Nexus

A logical link between the classification and the purpose.

FAQs

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