The State of Madras v. Srimathi Champakam Dorairajan (AIR 1951 SC 226) is a landmark Supreme Court judgment that addressed the conflict between Fundamental Rights and the Directive Principles of State Policy (DPSP). The case originated from a challenge to the Madras Communal Government Order (G.O.), a pre-independence policy from 1927 that reserved seats in state-run medical and engineering colleges based on caste and community quotas.
The problem it solved was the violation of equality rights caused by this communal quota system. The Supreme Court, in its judgment delivered on April 9, 1951, struck down the G.O., holding that it violated the fundamental rights guaranteed under Article 15(1) and Article 29(2) of the Constitution. The Court's ratio was that the enforceable Fundamental Rights are "sacrosanct" and cannot be overridden by the non-enforceable Directive Principles, such as Article 46, which the State had cited to justify the reservation.
This ruling directly connected to and necessitated the First Constitutional Amendment Act, 1951. This amendment introduced Article 15(4), which empowered the State to make special provisions for the advancement of any socially and educationally backward classes of citizens or for the Scheduled Castes and the Scheduled Tribes. This new clause effectively created a constitutional exception to the non-discrimination rule for affirmative action, laying the foundation for India's modern reservation policy in education.