Article 14 classification for bank directors upheld where workmen and officer directors were treated as distinct categories.

Different eligibility and disqualification conditions for workman and officer directors under the nationalised banks scheme were held constitutionally permissible because the two employee categories are not similarly situated. Workmen are governed by the Industrial Disputes Act, 1947, while officers serve under separate service rules, and the legislature could rationally prescribe different qualifications based on the office held, experience, and the stream from which a director is drawn. The challenge under Article 14 therefore failed, and Clause 3(2)(iii) was upheld as valid.

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Issues: Whether Clause 3(2)(iii) of the Nationalized Banks (Management and Miscellaneous Provisions) Scheme, 1970 was unconstitutional under Article 14 of the Constitution of India for prescribing a disqualification for workman directors that was not made applicable to officer directors.

Analysis: The statutory scheme under Section 9(3)(e) and (f) of the Banking Companies (Acquisition and Transfer of Undertakings) Act, 1970/1980 creates two distinct categories of employee-directors, namely workmen and officers. The two classes are not similarly situated: workmen are governed by the Industrial Disputes Act, 1947, while officers serve under separate service rules. In that background, the legislature was competent to prescribe different qualifications and disqualifications for different categories depending on their office, experience, and the stream from which a director is drawn. Article 14 protects equals and does not forbid reasonable differentiation between unequals.

Conclusion: Clause 3(2)(iii) is valid and does not violate Article 14. The challenge to the scheme fails.

Final Conclusion: The legal distinction between workmen and officers for nomination as bank directors is constitutionally permissible, and the appeal was liable to fail.

Ratio Decidendi: A statutory classification prescribing different eligibility or disqualification conditions for distinct employee categories does not offend Article 14 if the classes are not similarly situated and the differentiation is rationally connected to the object of the scheme.

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