A) ABSTRACT / HEADNOTE

In Chintaman Rao v. State of Madhya Pradesh, the Hon’ble Supreme Court addressed the constitutional validity of a statutory restriction imposed under the Central Provinces and Berar Regulation of Manufacture of Bidis (Agricultural Purposes) Act, 1948. The Act prohibited the manufacture of bidis in certain villages during the agricultural season, with the stated objective of ensuring adequate agricultural labor for the “Grow More Food” campaign. The petitioners challenged this restriction under Article 32 for violation of their fundamental right under Article 19(1)(g).

The Court held that although the state has the power to impose reasonable restrictions under Article 19(6), the impugned Act imposed an arbitrary, excessive, and unreasonable restriction on the fundamental right to carry on a lawful trade or business. The statute failed to strike a fair balance between individual freedom and public interest, especially since it imposed a blanket ban instead of a tailored restriction. The Court ruled that the law lacked a rational nexus to its objective and hence declared it unconstitutional.

Keywords: Article 19(1)(g), reasonable restriction, right to business, bidi manufacturing, agriculture labor, constitutional invalidity, Grow More Food campaign, Madhya Pradesh, Supreme Court of India.

B) CASE DETAILS

i) Judgment Cause Title:
Chintaman Rao v. The State of Madhya Pradesh

ii) Case Number:
Petitions Nos. 78 and 79 of 1950

iii) Judgment Date:
8th November, 1950

iv) Court:
Supreme Court of India

v) Quorum:
Shri Harilal Kania, C.J., Mehr Chand Mahajan, Mukherjea, Das and Chandrasekhara Aiyar, JJ.

vi) Author:
Justice Mehr Chand Mahajan

vii) Citation:
AIR 1951 SC 118; [1950] SCR 759

viii) Legal Provisions Involved:
Article 19(1)(g) and Article 19(6) of the Constitution of India;
Central Provinces and Berar Regulation of Manufacture of Bidis (Agricultural Purposes) Act, 1948 – Sections 3 and 4.

ix) Judgments overruled by the Case (if any):
None explicitly mentioned.

x) Case is Related to which Law Subjects:
Constitutional Law, Administrative Law, Labour Law, Fundamental Rights

C) INTRODUCTION AND BACKGROUND OF JUDGEMENT

The judgment in Chintaman Rao v. State of Madhya Pradesh unfolded during a crucial period following the enactment of the Constitution of India. The central issue was whether a pre-Constitution law—the Central Provinces and Berar Regulation of Manufacture of Bidis (Agricultural Purposes) Act, 1948—was consistent with the newly guaranteed fundamental rights, particularly the freedom to practice any profession or carry on any occupation, trade or business under Article 19(1)(g). The petitioners challenged the constitutionality of orders issued under the Act which prohibited bidi manufacturing in specific villages during agricultural seasons to ensure the availability of labor for farming. The law directly affected both employers and employees of the bidi industry, a major cottage industry in rural Madhya Pradesh. This case became one of the earliest decisions in which the Supreme Court examined the doctrine of reasonable restriction and set standards for determining whether legislation aligns with the constitutional guarantee of personal freedom against arbitrary State interference[1].

D) FACTS OF THE CASE

The Central Provinces and Berar Regulation of Manufacture of Bidis (Agricultural Purposes) Act, 1948 empowered the Deputy Commissioner to declare any period as an agricultural season for specified villages and to prohibit the manufacture of bidis during that time. This prohibition applied both to residents and employers, effectively halting the industry in those areas during such periods.

The Deputy Commissioner of Sagar issued orders under this Act on 13th June 1950 and later on 29th September 1950, forbidding bidi manufacturing in various villages from 8th October to 18th November 1950, citing the need to divert labor towards agriculture. Two petitioners—one a bidi factory proprietor and the other an employee—residing in the affected village filed petitions under Article 32, asserting that this law violated their fundamental right to carry on business.

They argued that the law disproportionately restricted their profession, especially since some individuals like women, old persons, and infirm individuals were not even capable of agricultural labor but were still restricted from bidi work, thereby unjustly depriving them of their livelihood.

E) LEGAL ISSUES RAISED

i) Whether the Central Provinces and Berar Regulation of Manufacture of Bidis (Agricultural Purposes) Act, 1948 violated Article 19(1)(g) of the Constitution.

ii) Whether the restrictions imposed by the Act qualified as “reasonable restrictions in the interest of the general public” under Article 19(6).

iii) Whether the scope of judicial review extended to examine whether restrictions imposed by the legislature were reasonable.

F) PETITIONER/APPELLANT’S ARGUMENTS

i) The counsels for Petitioner / Appellant submitted that:

The statute imposed a complete and blanket prohibition on the trade of manufacturing bidis during agricultural seasons, rather than imposing any regulated or conditional restriction[2]. This absolute ban failed to consider individuals who were incapable of engaging in agricultural labor, such as elderly women, children, or disabled persons, who relied on bidi rolling for their livelihood.

The counsel argued that the intended objective of ensuring labor for agriculture could have been achieved by limiting the employment of agricultural workers in bidi manufacturing, rather than halting the entire business. They emphasized that the law was not tailored to its objective, making the restrictions arbitrary, excessive, and disproportionate.

They contended that the provision was ultra vires as it failed the test of proportionality and lacked any nexus to the object. The legislation was too vague, allowed unchecked discretion to administrative officers, and therefore did not fall under the scope of reasonable restriction as contemplated by Article 19(6).

G) RESPONDENT’S ARGUMENTS

i) The counsels for Respondent submitted that:

The law was framed as part of a state-wide policy to promote agricultural development, particularly under the “Grow More Food” campaign. Ensuring the availability of agricultural labor during the sowing season was a pressing concern, especially in a rural agrarian economy like Madhya Pradesh.

They argued that the State had a duty to ensure public welfare, and this justified imposing certain restrictions on trades that detracted from this larger goal. The legislature was the best judge of what was in the interest of the public, and the judiciary should defer to its policy wisdom, particularly when it aimed at economic development and food security[3].

The restriction, according to the respondents, was temporary and localized, applicable only for a specific period and in designated villages, and hence, could be considered reasonable in light of Article 19(6).

H) RELATED LEGAL PROVISIONS

i) Article 19(1)(g) – Right to practise any profession or to carry on any occupation, trade or business
ii) Article 19(6) – Reasonable restrictions in the interest of the general public
iii) Sections 3 and 4 of the Central Provinces and Berar Regulation of Manufacture of Bidis (Agricultural Purposes) Act, 1948
iv) Article 32 – Right to Constitutional Remedies

I) JUDGEMENT

a. RATIO DECIDENDI

i) The Court held that the restrictions imposed under the Act failed the test of reasonableness under Article 19(6). A law that completely prohibits a trade during a certain period, even affecting those unrelated to agriculture, is not a reasonable restriction but an arbitrary interference with the freedom guaranteed under Article 19(1)(g).

The Court further held that judicial scrutiny under Article 19(6) must examine whether the means adopted by legislation are proportionate to the intended objective. The power of the Court to review the reasonableness of restrictions is a safeguard to prevent abuse of legislative discretion.

b. OBITER DICTA 

i) The Court observed that “reasonable” implies deliberation and intelligent care. Legislation must strike a balance between the rights of individuals and the interest of the public. Laws that fail this balance lack the quality of reasonableness.

The Court also commented that the term “reasonable restrictions” should not be used as a cloak for arbitrary and excessive control by the State.

c. GUIDELINES 

• Reasonableness requires that restrictions must not be arbitrary or excessive.

• Proportionality is essential – restrictions must be related directly to the object.

• Courts have authority to assess legislative judgment in matters of fundamental rights.

• Blanket prohibitions without distinguishing between affected groups violate constitutional protections.

J) CONCLUSION & COMMENTS

This landmark ruling laid the cornerstone for interpreting Article 19(1)(g). It clarified the scope of the State’s powers to restrict economic freedoms and reaffirmed the role of the judiciary as the guardian of fundamental rights. The Supreme Court stressed the principle that a fundamental right cannot be taken away entirely under the guise of public interest. The State may restrict, but cannot obliterate individual freedoms through sweeping prohibitions.

The doctrine of proportionality and judicial scrutiny initiated by this case has shaped many subsequent rulings. It set a clear precedent that legislative intent, no matter how noble, must align with constitutional mandates.

K) REFERENCES

a. Important Cases Referred

i) Chintaman Rao v. State of Madhya Pradesh, AIR 1951 SC 118, [1950] SCR 759
ii) State of Madras v. V.G. Row, AIR 1952 SC 196 – (Referred in future rulings for reasonableness test)
iii) R.M.D. Chamarbaugwalla v. Union of India, AIR 1957 SC 628 – (Doctrine of severability)
iv) Bennett Coleman & Co. v. Union of India, AIR 1973 SC 106 – (Media and economic rights)

b. Important Statutes Referred

i) Constitution of India – Articles 19(1)(g), 19(6), and 32
ii) Central Provinces and Berar Regulation of Manufacture of Bidis (Agricultural Purposes) Act, 1948 – Sections 3 and 4