Chintaman Rao v State of MP: Article 19 and Reasonable Restrictions - Case Analysis

Introduction of Chintaman Rao v State of MP (1951)

The case of Chintaman Rao v State of MP (1951) centred around the constitutionality of the Central Provinces and Berar Regulation of Manufacture of Bidis (Agricultural Purposes) Act, 1948. The Act prohibited bidi manufacturing in villages during the agricultural season to ensure labor availability for farming. The Petitioners challenged the Act and argued that it imposed an unreasonable restriction on their right to carry on trade or business. The case addressed important questions about the scope of reasonable restrictions under Article 19(6) and the power of the judiciary to review legislative measures infringing fundamental rights. For a deeper understanding of important judicial decisions, explore Landmark Judgements

Historical Context and Facts of Chintaman Rao v State of MP (1951)

The case at hand centres around the constitutionality of the restrictions imposed under the Central Provinces and Berar Regulation of Manufacture of Bidis (Agricultural Purposes) Act, 1948. The main issue was whether the orders issued by the Deputy Commissioner of Sagar barring certain villagers from engaging in bidi manufacturing during the agricultural season infringed the fundamental right of the Petitioner to carry on their occupation and business under Article 19(1) (g) of Indian Constitution. The following are the brief facts of the case of Chintaman Rao v State of MP -

• Enactment of the Act: The Central Provinces and Berar Regulation of Manufacture of Bidis (Agricultural Purposes) Act, 1948 was enacted on 19th October 1948. This Act was in force in the State of Madhya Pradesh when the Constitution of India came into effect.
• Initial Restriction Order (13th June 1950): On 13th June 1950, the Deputy Commissioner of Sagar issued an order under the Act and forbidden residents of certain villages from engaging in the manufacture of bidis.
• Legal Challenge (19th June 1950): On 19th June 1950, two petitions were filed before the Supreme Court under Article 32 of the Constitution and challenged the legality of the order. The Petitioners in Chintaman Rao v State of MP contended that the restriction infringed their fundamental right to practice their occupation and business.
• Issuance of a New Order (29th September 1950): The earlier petitions were pending, the agricultural season mentioned in the 19th June 1950 order ended. However, on 29th September 1950, a new but identical order was issued and enforced the same restrictions for the next agricultural season, spanning from 8th October to 18th November 1950.
• Supplementary Petition: Following the issuance of the second order, the Petitioners filed a supplementary petition before the Supreme Court and challenged the renewed restrictions in Chintaman Rao v State of MP.

Issue addressed in Chintaman Rao v State of MP (1951)

The main issue in Chintaman Rao v State of MP was whether the prohibition on bidi manufacturing during the agricultural season under the contested Act constituted a reasonable restriction on the right to practice any trade or profession under Article 19(1)(g) of the Indian Constitution as allowed under Article 19(6). The following sub-issues were also addressed in this case -

• Whether the restrictions in the Act had a reasonable nexus with its objective?
• Whether a blanket prohibition on bidi manufacturing was excessive and arbitrary?
• Whether the provisions of the Act specifically Section 4 were overly broad and could be applied beyond constitutionally permissible limits?
• Whether the Supreme Court had the authority to review and strike down legislative measures that imposed unreasonable restrictions on fundamental rights?

Ultimately, the case of Chintaman Rao v State of MP centered on the constitutional validity of the Act and whether it met the test of reasonableness under Article 19(6).

Key Legal Provisions involved in Chintaman Rao v State of MP (1951)

In Chintaman Rao v State of MP Article 19 of Indian Constitution played a significant role. The following is the analysis of this provision -

Article 19 of Indian Constitution: Right to Freedom

• Freedom of Speech and Expression (Article 19(1)(a)): Citizens can express opinions freely with reasonable restrictions under Article 19(2) for state security, public order, decency and more.
• Freedom of Assembly (Article 19(1)(b)): Citizens can assemble peacefully, with restrictions to maintain sovereignty and public order.
• Freedom of Association (Article 19(1)(c)): Citizens have the right to form associations, unions, or cooperatives, with reasonable restrictions allowed under Article 19(4).
• Freedom of Movement (Article 19(1)(d)): Citizens can move freely across India, though Article 19(5) permits restrictions to protect Scheduled Tribes and the public.
• Freedom to Reside and Settle (Article 19(1)(e)): Citizens can reside anywhere in India.
• Freedom of Profession (Article 19(1)(g)): Citizens may pursue any profession, trade, or business, subject to reasonable restrictions.

In Chintaman Rao v State of MP, the contested legislation forbidden bidi manufacturing in specific villages during the agricultural season to ensure sufficient labor for farming. The Supreme Court examined whether this prohibition constituted a ‘reasonable restriction’ under Article 19(6) or if it was excessive and arbitrary, thereby violating Article 19(1)(g).

Judgment and Impact of Chintaman Rao v State of MP (1951)

The 5-Judges Bench of the Supreme Court comprising Justice Mehr Chand Mahajan, Justice Hiralal J. Kania, Justice Sudhi Ranjan Das, Justice B.K. Mukherjea and Justice N. Chandrasekhara Aiyar in Chintaman Rao v State of MP examined whether the challenged legislation aligns with fundamental rights.

The Supreme Court conducted a comprehensive review of its provisions. The preamble of the Act highlights its objective and ensures an adequate supply of labor for agricultural work in bidi-manufacturing regions to enhance food production and cultivate fallow lands.

Under the Act, the Deputy Commissioner is empowered with the power to forbid bidi manufacturing in designated villages and define the agricultural season. The Supreme Court in Chintaman Rao v State of MP observed that non-compliance with these directions according to Section 7 of the Act imposes a penalty of up to 6 months of imprisonment.

The Court regarding restrictions on fundamental rights highlighted that any limitations imposed on personal freedoms must be reasonable, avoid arbitrariness and excessiveness and serve the public interest. Legislative measures must cautiously balance the right to practice any profession or trade under Article 19(1)(g) with the permissible restrictions under Article 19(6) of the Constitution.

The Court in Chintaman Rao v State of MP noted that the Act imposed an absolute prohibition on bidi manufacturing during particular agricultural seasons making it an excessively restrictive measure. Instead of a blanket ban, a more proportionate approach such as regulating working hours could have sufficed to ensure labor availability without infringing on business operations. Moreover, the Court also observed that the Act not only prohibited manufacturing but also restricted employers from hiring labor from neighboring areas. 

On the basis of the above findings, the Supreme Court in Chintaman Rao v State of MP held that the Act failed to meet the standard of reasonableness and was therefore constitutionally void. The Court declared that the orders issued by the Deputy Commissioner were declared null and inoperative. The Supreme Court directed the Respondents to refrain from enforcing Section 4 of the Act against the Petitioners in any manner.

Conclusion

In Chintaman Rao v State of MP (1951) The Supreme Court held that the prohibition imposed by the Act was excessive and arbitrary. The Court ruled that the State could regulate professions in the public interest, a blanket ban on bidi manufacturing was not a proportionate measure. Consequently, the Act was declared constitutionally void.