A) ABSTRACT / HEADNOTE

The case centers on the constitutional validity of The Khalsa University (Repeal) Act, 2017, which annulled the establishment of Khalsa University under the Khalsa University Act, 2016. The appellants contended that the repealing legislation violated Article 14 of the Constitution as it discriminated against a single university without reasonable classification or a valid nexus. The Supreme Court held that while laws affecting individual entities are permissible, they must be based on intelligible differentia linked to legislative objectives. The lack of substantive justification for singling out Khalsa University rendered the repeal arbitrary and discriminatory.

Keywords: Khalsa University, Article 14, manifest arbitrariness, reasonable classification, discriminatory legislation.

B) CASE DETAILS

i) Judgment Cause Title:
Khalsa University and Another v. The State of Punjab and Another

ii) Case Number:
Civil Appeal No. 10999 of 2024

iii) Judgment Date:
October 3, 2024

iv) Court:
Supreme Court of India

v) Quorum:
Justices B.R. Gavai and K.V. Viswanathan

vi) Author:
Justice B.R. Gavai

vii) Citation:
[2024] 10 S.C.R. 445, INSC 751

viii) Legal Provisions Involved:

• Article 14 of the Constitution of India
• Khalsa University Act, 2016
• Khalsa University (Repeal) Act, 2017

ix) Judgments Overruled by the Case:
N/A

x) Case Related to the Following Law Subjects:
Constitutional Law, Administrative Law, Higher Education Policy

C) INTRODUCTION AND BACKGROUND OF JUDGMENT

In 2016, the Khalsa University Act was enacted under Punjab’s Private Universities Policy, 2010, enabling the establishment of self-financed private universities. The appellants established Khalsa University in line with this framework. In 2017, after a regime change, the state enacted the Khalsa University (Repeal) Act under the pretext of protecting the heritage character of the Khalsa College, leading to the present litigation.

D) FACTS OF THE CASE

1. The Khalsa University Act, 2016 allowed the establishment of Khalsa University as a self-financed entity.
2. The university admitted students for the academic session 2016–17 and began operations in compliance with UGC norms.
3. A political shift resulted in statements opposing the university’s existence, citing concerns over the heritage value of Khalsa College.
4. On July 17, 2017, the Khalsa University (Repeal) Act was passed without substantive deliberation or consultation.
5. The appellants challenged the repeal as arbitrary and violative of Article 14 in the Punjab and Haryana High Court, which dismissed their plea.

E) LEGAL ISSUES RAISED

1. Whether the Khalsa University (Repeal) Act, 2017 discriminates against Khalsa University in violation of Article 14.
2. Whether legislation affecting a single entity requires a reasonable classification.
3. Whether the repeal law is arbitrary and fails the test of manifest arbitrariness under Article 14.

F) PETITIONERS’ ARGUMENTS

1. The legislation selectively targeted Khalsa University, violating Article 14 by failing to provide a reasonable basis for its repeal.
2. Other universities established under the same policy were unaffected, showcasing discriminatory treatment.
3. The stated objective—preserving Khalsa College’s heritage—was factually baseless as the two institutions operated independently.
4. Shayara Bano v. Union of India was cited to argue that manifest arbitrariness is a valid ground to challenge legislative actions.

G) RESPONDENTS’ ARGUMENTS

1. The State contended that the repeal law aimed to safeguard Khalsa College’s identity and heritage value.
2. It asserted the existence of a presumption of constitutionality in favor of legislative enactments.
3. Reasonable classification, according to the State, allowed the singling out of Khalsa University for legislative action based on heritage concerns.

H) JUDGMENT

a. Ratio Decidendi

The court held the repeal unconstitutional under Article 14 due to its arbitrary nature. The State failed to justify its selective targeting of Khalsa University and lacked evidence of public interest necessitating such repeal.

b. Obiter Dicta

The judgment underscored that while differential treatment is permissible, it must be supported by compelling material establishing an intelligible basis.

c. Guidelines

1. Legislations targeting individual entities must present compelling reasons and withstand Article 14 scrutiny.
2. Mere assertions of public interest are insufficient; concrete evidence is mandatory to establish necessity.
3. A legislative presumption of validity does not absolve the State from demonstrating rational nexus in classifications.

I) CONCLUSION & COMMENTS

This judgment reinforces the doctrine of reasonable classification under Article 14. It underscores that legislative actions impacting single entities must rest on substantive justifications linked to public interest. The lack of material evidence for the repeal exemplified legislative arbitrariness.

J) REFERENCES

a. Important Cases Referred:

1. Chiranjit Lal Chowdhury v. Union of India, [1950] 1 SCR 869
2. D.S. Reddy v. Chancellor, Osmania University, [1967] 2 SCR 214
3. Shayara Bano v. Union of India, [2017] 9 SCR 797

b. Important Statutes Referred:

1. Constitution of India, Article 14
2. Khalsa University Act, 2016
3. Khalsa University (Repeal) Act, 2017