Article 14 classification requires intelligible differentia: EPF notifications treating private banks and nationalised banks differently were found constitutionally vulnerable.

Notifications extending the Employees Provident Fund regime to private sector banks while excluding nationalised banks were examined under Article 14. The text states that employees' service conditions were substantially alike, both sets of banks were governed by the Banking Regulation Act, 1949 and regulated by RBI, and no material difference justified separate treatment. It also notes that conditional legislation remains subject to constitutional review, and that exemption under Section 17 of the EPF Act did not validate the unequal classification. On that reasoning, the exclusion of nationalised banks was treated as lacking intelligible differentia and rational nexus with the statutory object, rendering the notifications vulnerable under Article 14.

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Issues: Whether the impugned notifications applying the Employees Provident Fund regime to private sector banks, while excluding nationalised banks, violated Article 14 of the Constitution of India.

Analysis: The service conditions of employees of the petitioners and of nationalised banks were found to be substantially alike, and the petitioners were also governed by the Banking Regulation Act, 1949 and regulated by the Reserve Bank of India. The impugned notifications were treated as conditional legislation, but that did not place them beyond constitutional scrutiny. The Court found no material or characteristic difference between private sector banks and nationalised banks for the purpose of applying the provident fund and pension schemes. The availability of exemption under Section 17 of the Employees Provident Funds and Miscellaneous Provisions Act, 1952 did not justify the unequal classification. In the absence of an intelligible differentia and rational nexus with the object of the statute, the exclusion of nationalised banks was held impermissible.

Conclusion: The notifications were unconstitutional and liable to be quashed as violative of Article 14.

Ratio Decidendi: A classification under Article 14 must rest on an intelligible differentia having a rational nexus with the statutory object, and a notification made by conditional legislation remains open to challenge where that test is not satisfied.

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