Article 14 classification for profession tax upheld where location and years of practice reflected rational differences in opportunity

Differential profession tax rates for lawyers based on location of practice and length of practice were upheld as founded on intelligible differentia. Practice in the Bangalore Urban Agglomeration was treated as reflecting greater professional opportunities in a densely populated area, and classification by years of practice was accepted as a relevant proxy for professional prospects and capacity to pay. The challenge that the scheme was arbitrary or encroached on the Union field failed, and the classification was held valid under Article 14.

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Issues: Whether the classification of lawyers for profession tax on the basis of location of practice and length of practice violated Article 14 of the Constitution of India.

Analysis: The differential rates were upheld as resting on intelligible differentia. Lawyers practising in the Bangalore Urban Agglomeration were treated as operating in a more densely populated area with greater professional opportunities, and experience based classification by years of practice was also accepted as a relevant basis linked to professional prospects and capacity to pay. The Court found no merit in the challenge that the classifications were arbitrary or that they intruded upon the Union field.

Conclusion: The classification was held valid and not violative of Article 14 of the Constitution of India.

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