Article 14 is a fundamental provision in the Constitution of India, enshrined under the Right to Equality (Articles 14 to 18). It mandates that "The State shall not deny to any person equality before the law or the equal protection of the laws within the territory of India." The provision was introduced into the Constitution in 1950 by the framers, including Dr. B.R. Ambedkar, to address historical discrimination in Indian society. Its two core concepts draw from different sources: "Equality before the law" is a negative concept borrowed from the English Common Law and A.V. Dicey's Rule of Law, meaning no person is above the law. "Equal protection of the laws" is a positive concept inspired by the 14th Amendment of the United States Constitution, requiring that equals must be treated equally.
The mechanism of Article 14 has evolved through judicial interpretation. Initially, the Supreme Court permitted the State to make a reasonable classification of persons or things, provided the classification was based on an intelligible differentia and had a rational nexus with the law's objective, as established in Ram Krishna Dalmia v. Justice S R Tendolkar (1958). However, the scope of Article 14 was drastically expanded in E.P. Royappa v. State of Tamil Nadu (1974), where the Court held that arbitrariness is the "sworn enemy" of equality, introducing the Doctrine of Anti-Arbitrariness to check executive action. This doctrine was reinforced in Maneka Gandhi v. Union of India (1978), connecting Article 14 with Article 21 by requiring that any procedure established by law must be "just and fair."
The interpretation of Article 14 has recently expanded through the Doctrine of Manifest Arbitrariness. For instance, in Shayara Bano v. Union of India (2017), the Supreme Court struck down instant triple talaq, ruling that a law can be invalidated if it is manifestly arbitrary. Furthermore, the Court used Article 14 to strike down Section 497 of the Indian Penal Code (adultery) in Joseph Shine v. Union of India (2018) and to read down Section 377 of the Indian Penal Code (decriminalizing consensual same-sex relations) in Navtej Singh Johar v. Union of India (2018), both on the grounds of arbitrariness. The core text of Article 14 itself has remained unchanged, but its judicial application has broadened to protect against all forms of arbitrary state action.