Article 14 and Magistrate trials: section 30 was upheld because the territorial classification was reasonable and non-discriminatory.

Section 30 of the Code of Criminal Procedure was upheld against an Article 14 challenge because the classification was based on intelligible differentia and a rational nexus with the object of workable administration in specified territories. The provision applied only in defined areas and to offences not punishable with death, and its practical justification lay in distance, witness inconvenience, and the difficulty of securing jurors or assessors in remote regions. The text further notes that equal treatment was preserved within the covered areas, and that uneven administration by itself did not establish unconstitutional discrimination absent intentional or purposeful discrimination. Accordingly, no infringement of the constitutional right was found.

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Issues: Whether section 30 of the Code of Criminal Procedure offended the equal protection guarantee in Article 14 of the Constitution of India by enabling trials by specially empowered Magistrates instead of the Court of Session, and whether the manner in which cases were placed before such Magistrates resulted in unconstitutional discrimination.

Analysis: Article 14 prohibits class legislation but permits reasonable classification, provided the classification rests on an intelligible differentia and bears a rational relation to the object sought to be achieved. Section 30 operated in specified territories and only in respect of offences not punishable with death. The classification was supported by territorial and practical considerations, including distance, inconvenience to witnesses, and difficulty in securing jurors or assessors in remote areas. The provision did not itself create unequal treatment, because persons committing the same offences in the covered areas were equally liable to be tried by a section 30 Magistrate. The possibility of uneven administration did not establish a constitutional violation in the absence of intentional or purposeful discrimination, and the ultimate choice between committal and trial by the Magistrate remained subject to judicial discretion under the Code.

Conclusion: Section 30 of the Code of Criminal Procedure did not violate Article 14 of the Constitution of India, and no infringement of the appellants' fundamental right was made out.

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