Article 14 equality in State largesse bars lifetime government accommodation for former Chief Ministers from scarce public property.

Section 4(3) of the Uttar Pradesh Ministers (Salaries, Allowances and Miscellaneous Provisions) Act, 1981 was held invalid under Article 14 because it granted a former Chief Minister a lifetime government residence from scarce public property on request. The Court reasoned that public bungalows are State resources meant for current officeholders, and a past office cannot by itself justify a special privilege after demitting office. The provision created an unreasonable and arbitrary classification, lacking rational nexus with any legitimate constitutional objective, and amounted to discriminatory State largesse. The challenge succeeded and the writ petition was allowed.

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Issues: Whether Section 4(3) of the Uttar Pradesh Ministers (Salaries, Allowances and Miscellaneous Provisions) Act, 1981, which grants a former Chief Minister a government residence for life on request, violates Article 14 of the Constitution of India.

Analysis: Government bungalows are public property and scarce public resources meant for use by current holders of public office. Once a Chief Minister demits office, the office held becomes a matter of history and cannot by itself furnish a constitutionally valid basis for conferring a special privilege. The provision creates a separate class of citizens for the distribution of public property without a rational nexus to any legitimate constitutional objective. The classification is therefore unreasonable and the grant of a lifetime accommodation benefit is arbitrary and discriminatory. Such a statutory preference also fails on the touchstone of equality in the distribution of State largesse and public goods.

Conclusion: Section 4(3) of the Act is ultra vires the Constitution of India and cannot survive scrutiny under Article 14. The challenge succeeds and the writ petition is allowed.

Ratio Decidendi: A statutory provision conferring a lifetime benefit from scarce public property on the basis of former public office, after the office has ceased, is an unreasonable and arbitrary classification and is invalid under Article 14.

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