Arbitrary classification in private succession disputes violates equality when named claimants are singled out without judicial determination.

The impugned Act was held unconstitutional under Article 14 because it singled out identified claimants and denied them the ordinary right to pursue succession claims to a private estate. The classification was found to have no rational connection with the object of the law, and neither prolonged private disputes nor a non-judicial report by a State Legal Adviser provided a valid basis for hostile discrimination. A law affecting private rights and applying to named persons without adjudication by a properly constituted judicial tribunal was treated as arbitrary and discriminatory. The challenge under Articles 31(1) and 19(1)(f) was not examined further.

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Issues: Whether the impugned Act, by dismissing the claims of specified individuals to participate in the distribution of a private estate on the basis of a non-judicial report, violated the equality guarantee under Article 14 of the Constitution.

Analysis: The legislation singled out two named women and their children from among all rival claimants to the estate and denied them the ordinary right to assert their claims under the personal law governing succession. The classification was not founded on any rational principle connected with the object of the law. The mere existence of prolonged private disputes, or the fact that a State Legal Adviser had reported against the claims, did not furnish a reasonable basis for hostile differentiation. A law affecting private rights and made applicable to identified persons, without adjudication by a properly constituted judicial tribunal, was held to be arbitrary and discriminatory. The challenge under Articles 31(1) and 19(1)(f) was not examined further.

Conclusion: The impugned Act was unconstitutional to the extent that it singled out the specified claimants and violated Article 14.

Final Conclusion: The appeal failed because the legislation was struck down insofar as it imposed an arbitrary and discriminatory exclusion from succession claims.

Ratio Decidendi: A statute that targets identified persons for adverse treatment in a private rights dispute, without a rational classification or judicial determination, violates the equality guarantee.

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