University of Madras vs. Shantabai,1954: Article 12 Case Law

Fact of the Case:  Admission to Shantabai was denied due to discrimination (against women) in a State funded University of Madras, Shantabai invoked the Article 14 of the Constitution and filed a writ petition that her right against equality had been violated. 

Issues Involved:  The main issue involved in this case was whether University of Madras fall under the category of State defined under Article 12 of our Constitution. 

This is important why? Because Fundamental Rights can only be invoked against State, these are enforceable against State. If University of Madras is not held as State then there is no question of enforcement of violation of her Fundamental Right. 

Decision of Court:  Court used the Ejusdem Generis Principle.

The Ejusdem Generis Principle is a legal doctrine used in the interpretation of statutes or contracts when a list of specific items is followed by more general words. The Latin term “ejusdem generis” can be translated to mean “of the same kind” or “of the same nature.”

By using this principle, the Court held that ‘University of Madras’ Cannot be held as State under Article 12 of the Constitution of India. 

It is important to note that, the decision of Court in this case was reversed in the later judgement.