Champakam Dorairajan, a Brahmin woman from Madras, played a significant role in shaping India’s constitutional history by challenging caste-based reservations in educational institutions. Her case, State of Madras v. Champakam Dorairajan (1951), led to the introduction of the First Amendment to the Indian Constitution, paving the way for affirmative action policies.
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Champakam Dorairajan challenged caste-based reservation system in 1950, arguing it violated her fundamental right to equality under Article 14 of the Indian Constitution.
She was a well-educated Brahmin woman from Madras, with a B.Sc. in Physics and Chemistry, who wanted to become a doctor but faced financial difficulties.
The Madras government introduced the controversial Communal G.O. in 1948 to allocate educational seats based on caste.
The quota system in the G.O. allocated 6 seats to non-Brahmin Hindus, 2 to Backward Hindus, 2 to Brahmins, and 2 to Harijans (Dalits), restricting Brahmin students’ access to educational institutions.
Dorairajan approached the Madras High Court in 1950, which struck down the G.O. as unconstitutional.
The Madras government appealed to the Supreme Court, which ruled in 1951 that the caste-based reservation system violated Articles 14, 15(1), and 29(2).
The Supreme Court’s ruling was a major setback for the government, which then introduced the First Amendment to the Constitution in 1951.
The First Amendment added Article 15(4), allowing special provisions for socially and educationally backward classes, Scheduled Castes (SCs), and Scheduled Tribes (STs).
This amendment legitimized reservations in educational institutions, beyond public employment.
The case ignited national debates on merit vs. affirmative action, which continue to shape the discourse on social justice and reservations in India.




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