Administrative Law
Chintaman Rao v. State of Madhya Pradesh
AIR 1951 SC 118; 1950 SCR 759
- Citation
- AIR 1951 SC 118; 1950 SCR 759
- Court
- Supreme Court of India
- Date
- 8 November 1950
- Bench
- H.J. Kania, CJ, M.C. Mahajan, B.K. Mukherjea, S.R. Das and N. Chandrasekhara Aiyar, JJ.
Facts
- A law allowed prohibition of bidi manufacture during agricultural seasons.
- The aim was to make labour available for agriculture.
- The authority imposed a broad prohibition on bidi manufacturing.
- Bidi manufacturers challenged it under Article 19(1)(g).
Issue
- Whether a total ban on bidi manufacturing was a reasonable restriction on trade.
Rule
- Restrictions on trade must be reasonable under Article 19(6).
- A restriction should not be excessive compared to the purpose.
- Administrative action under a statute must remain proportionate to the object.
- A total ban may be invalid if a narrower measure could achieve the object.
Application
- The purpose of the law was limited: ensuring agricultural labour availability.
- But the order imposed a wide prohibition on bidi manufacture.
- It affected people who may not have been agricultural labourers at all.
- The restriction was broader than necessary.
- The Court said the State could regulate labour movement for agriculture, but it could not completely destroy another lawful occupation without justification.
- The administrative measure therefore failed the test of reasonableness.
Conclusion
- The Supreme Court struck down the restriction.
- It held that the measure was excessive and unreasonable.
- Use this case for: administrative orders affecting fundamental rights must be reasonable and not overbroad.