Equal protection under Article 14 bars statutes that target named persons or a single transaction without rational classification.

The Sathi Lands (Restoration) Act, 1950 was invalidated for violating Article 14 because it singled out two identified lessees and one specific settlement for adverse treatment without any rational basis for classification. The Court noted that other leaseholders under the same estate were similarly situated and had obtained settlements on comparable terms, yet the Act targeted only the named transaction. It also treated the measure as a legislative nullification of a private transaction without prior adjudication, rather than a general law based on an intelligible distinction. The statute was therefore held unconstitutional as hostile discrimination.

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Issues: Whether the Sathi Lands (Restoration) Act, 1950 was unconstitutional for singling out particular lessees and a single transaction for invalidation and eviction, in violation of the guarantee of equal protection under Article 14 of the Constitution of India.

Analysis: The Act did not proceed on any general classification based on a rational distinction. It targeted two identified individuals and one specific settlement, though other leaseholders under the same estate were in similar positions and had obtained settlements on comparable terms. The measure was not a judicial determination of disputed private rights but a legislative declaration nullifying a particular transaction without prior adjudication. Such selective treatment, without any rational basis related to the object of the law, amounted to hostile discrimination and could not be supported as a valid classification.

Conclusion: The Act was held unconstitutional and invalid as offending Article 14; the challenge succeeded in favour of the appellants.

Ratio Decidendi: A statute that singles out identified persons or a particular private transaction for adverse treatment, without a rational basis for classification, violates the equal protection guarantee and is constitutionally invalid.

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