Question

Equality is a dynamic concept with many... aspects and dimensions and it cannot be "cribbed, cabined and confined" within traditional and doctrinaire limits. From a positivistic point of view, equality is antithetic to arbitrariness. In fact equality and arbitrariness are sworn enemies - this was stated in the case of

• A. Jespar & Slong v. State of Meghalaya, AIR 2004 SC 3533
• B. Vajravelu Mudiliar Vs. Special Dty Collector, AIR 1965 SC 1017
• C. E. P. Royappa v. State of T.N. AIR 1974 S C 555
• D. In Punjab Communication Ltd. v. Union of India - 1999 (4) SCC 727

Hint:

For Article 14, remember the two main tests. The "Old Doctrine" is the test of Reasonable Classification. The "New Doctrine" is the test of Anti-Arbitrariness, famously laid down in \textit{E.P. Royappa}. Both tests are still applied by the courts.

Answer 1

The Correct Option is C

The way to place this quote correctly is to recognise it as the origin point of a specific doctrinal shift in Article 14 jurisprudence.

1. Recognise the doctrine: The passage describes the "new doctrine" that treats arbitrary state action as inherently unequal, moving beyond the older reasonable-classification test.
2. Trace it to its source: This doctrinal shift was introduced by Justice Bhagwati in E.P. Royappa v. State of Tamil Nadu, and was later built upon in subsequent cases like Maneka Gandhi v. Union of India.
3. Eliminate the other cases: Jespar & Slong concerns customary succession law, Vajravelu Mudiliar concerns land acquisition compensation, and Punjab Communication Ltd. concerns legitimate expectation, none of which originates this particular quote about equality and arbitrariness.

The correct answer is E. P. Royappa v. State of T.N.

Answer 2

Another way to identify the right case is to place each option on the timeline of Article 14 doctrine and see which one matches the shift being described.

1. Jespar & Slong v. State of Meghalaya: This case belongs to a body of law concerning tribal custom and inheritance, entirely outside the line of cases developing the classification-versus-arbitrariness debate under Article 14.
2. Vajravelu Mudiliar Vs. Special Dty Collector: Decided under the older reasonable-classification framework, this case predates and does not introduce the arbitrariness-based reading of equality that the quote describes.
3. E. P. Royappa v. State of T.N.: This is precisely the turning point in the doctrinal timeline, the case where the Court first departed from pure classification analysis and declared that arbitrary state action itself offends Article 14, using the specific words the question quotes.
4. Punjab Communication Ltd. v. Union of India: This later case applies established administrative law principles like legitimate expectation to a specific licensing dispute, rather than introducing this foundational reformulation of equality itself.

Placing the quote at its correct point in the doctrinal timeline again identifies Royappa as the source.

Hence, the correct answer is E. P. Royappa v. State of T.N.