Doctrine of Reasonable classification in Administrative Law

Doctrine of Reasonable classification

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Introduction of the Doctrine of Reasonable Classification: – The principle of proportionality in administrative law stipulates that there should be a reasonable and appropriate nexus between the intended goal and the measures required to ensure it. Since the action adopted must not be dramatically out of proportion to the court’s awareness, the aforementioned activities can subsequently be contested through judicial review.

The idea of reasonableness in administrative law was established as a result of the necessity of acting rationally and how it aids in the development and execution of legislation. And, in general, law and reasonability go hand in hand. In any system, the concept of reasonability is essential to evaluating the legal system.

Doctrine of reasonable classification

The State has the authority to enact laws that apply to certain classes of individuals differently so that the equality of civil rights & equal protection of the law is guaranteed since the Rule of Law cannot forbid a particular class of people from being subject to special laws this is known as The “Doctrine of Reasonable Classification”.

It can be applied as a substantive standard to examine the substance and supporting documentation of administrative actions, providing standards for public authorities performing administrative duties in this manner. Any decision made by public authorities may be declared unreasonable if it does not make sense given all the legally & reasonably pertinent aspects. People trust in and rely on administrative rules and regulations because they are consistent with reasonability.

As a result, it is clear that the notion of reasonableness is crucial in the area of administrative law. And although the two have been related for a very long time, the administration has changed significantly since then. The administration has evolved into a multipolar entity that interacts with society as a whole, which has altered how the concept of reasonability applies to it.

Article 14 of the Indian constitution

While class legislation is not permitted by U/A 14, reasonable classification is. By giving certain privileges to a class of people who were arbitrarily chosen from a large group of people, class legislation means eradicating unjustified discrimination. As a result, class law contradicts the principle of equal protection, because reasonable classification is always based on a genuine and significant disparity.

Administrative Laws Play an Important Role

Reasonability plays a significant role in Administrative Laws in at least three areas: –

As a test of legitimacy

The first argument for the justification of any law or bill enacted by the government is its legitimacy. By legitimacy, we mean adherence to laws and standards that can be justified and logical. Law logic is grounded on reason, and any law or rule that is supported by reasonable diligence has fewer problems and a higher degree of acceptability & adherence. As a result, legality is asserted through reasonability.

Used as a guide for interpreting statutes

The goal of any statutory interpretation is to arrive at a fair understanding of the law. By keeping an eye on two parameters, reasonable conformance is achieved. Avoiding irrational or ludicrous consequences and using context are these two factors.

The assumption guiding the creation of statutes is that they will not give rise to any ludicrous interpretations, as is common knowledge.

Contextual reasoning, which refers to how your law is written and what it says, is the second aspect outlined above.

When addressing contextual reasoning, we need to be aware of two aspects of lawmaking: activist and dynamic lawmaking. When an existing or widely supported notion is adopted and made into a law, this is referred to as activist lawmaking. Dynamic law-making entails the invention of an idea on which society has not yet come to a consensus, which is subsequently transformed into law and spread throughout society. Additionally, the term “fair” is crucial in both cases. When making, enforcing, and interpreting these laws, legislators, and judges used reasonableness as a benchmark.

As a norm for Judicial Review

When it comes to judicial review, the principle of reasonableness is particularly important and significant.  As this is the scope of the analysis, administrative actions can be nullified if they are found irrational.

In this context, the scope of reasonableness is fairly broad and diversified. The legal notion of reasonableness was firmly established in the UK, first discussed in Rooke’s case in 1598, and subsequently clarified in the Wednesbury decision in 1948, from when it had become more prominent and was accepted in the common laws of numerous countries worldwide.

When we discuss judicial review, we look at how it affects administrative discretion. Administrative action has been granted a larger scope, but its decisions are also subject to review based on their validity.

The issue of how much authority the court can exercise in the interest of reasonableness is extremely important, and in order to address it, it has been tried to hold that administrative discretion and authority are permitted and should not be unnecessarily restricted when exercising reasonability. In the Wednesbury Corporation case, Lord Greene M.R. stated that the courts would not interfere with an action of public authority if:

  • The authorities have taken into consideration all of the relevant items.
  • The authorities did not consider things that they should not have considered.
  • The decision is not irrational.

Administrative review

It is deemed important enough to take into account and adhere to the wider meaning of reasonableness. Because it can serve two purposes in the administrative review:

  • As it defines the public authority’s competence’s scope.
  • If the authority is capable enough, it specifies how it uses its discretion.

Understanding the idea of reasonability is not a simple or concise process since, as society has developed, modifications have been made to national and international laws, which have changed the parameters used to determine reasonability. Furthermore, it varies from one jurisdiction to another and from situation to situation.

Case Laws

Ram Krishna Dalmia v. Justice S.R. Tendolkar,

The Supreme Court concluded that, while Article 14 prohibited class legislation, it doesn’t prohibit fair classification for legal purposes. It forbids discrimination through both substantive law and procedural statute.

Article 14 thereby prohibits class legislation but does not prohibit fair classification; nonetheless, these categories must not be evasive, arbitrary, or artificial.

State of West Bengal v. Anwar Ali Sarkar

The twin criteria for reasonable classification were established by the Apex Court. The court determined that categorization must satisfy two criteria in order to pass the test:

  • It must be founded on an understandable distinction that distinguishes the individuals grouped together from others, and
  • It must also have a rational connection to the act’s purpose.


It is therefore challenging to describe it precisely. Between reasonability and various other notions like proportionality, reasonableness, and equality, there is also a very thin line of distinction. In a certain sense, we may even say that when this idea is implemented into reality, all other principles are implicated.

But despite being vague and challenging to comprehend, we can conclude with certainty that it serves as a criterion of evaluation for administrative action and has a significant impact on the field of administrative legislation.


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