2026 Supreme(Gau) 1010

THE GAUHATI HIGH COURT (HIGH COURT OF ASSAM, NAGALAND, MIZORAM AND ARUNACHAL PRADESH) 
ASHUTOSH KUMAR, CJ., ARUN DEV CHOUDHURY, J. 
State of Sikkim, through the Chief Secretary – Appellant
Versus
Mr. Yogen Ghatani, Son of Mr. Amrit Kumar – Respondent 
Writ Appeal No.61 of 2021 
Decided On : 08-04-2026

State governments possess the constitutional authority to regulate administrative certificates for employment preference based on historical, special provisions, provided such classifications serve a rational purpose and do not arbitrarily infringe upon fundamental rights relative to the intended objective.

Headnote:(A) Constitution of India - Articles 14, 15, 16, 21 and 371-F - State government notifications restricting Certificate of Identification - Validity - The State has the authority to issue notifications regulating administrative certificates for public employment, provided they are rooted in a constitutionally protected historical framework - Such classifications are based on intelligible differentia concerning the unique identity of inhabitants of the state and do not violate fundamental rights so long as the classification has a rational nexus with the objective of safeguarding historical employment policies. (Paras 3, 30, 46, 49)

(B) Administrative Law - Policy decisions - Standard of judicial review - Courts should not interfere with policy-based classifications unless they are manifestly arbitrary or lack any rational basis - The court in appeal is not to substitute its view for that of the executive in matters of special state-specific constitutional protections. (Paras 30, 41, 51)

Facts of the case:
An individual challenged government notifications restricting the utility of a Certificate of Identification to employment purposes and excluding the third generation of descendants from eligibility. A single judge of the High Court had quashed these notifications as arbitrary and violative of fundamental rights. The State preferred an appeal against this order, contending the classification was a continuation of historical policies protected under special constitutional provisions.

Findings of Court:
The State was found to possess the competence to regulate the use of certificates as administrative instruments. The restrictions were deemed consistent with historical standards for employment-preference policies and did not infringe upon citizenship rights or civil status regarding other matters. The exclusion of grandchildren from this specific employment-linked certificate was held to be a reasonable exercise of policy-making to prevent the indefinite expansion of benefits tied to historical circumstances.

Issues: The primary issues were the constitutional validity of notifications restricting the utility of a state-issued certificate to employment purposes and the legality of excluding third-generation descendants from the benefits of such certificates under Articles 14, 16, and 21.

Ratio Decidendi: A certificate of identification used for employment is an administrative, employment-linked recognition rather than a determinant of citizenship. Restricting such a document for specific purposes, consistent with historical government establishment rules and special constitutional provisions for the integration of the state, is not arbitrary or discriminatory. The State is entitled to limit the scope of such administrative recognition to maintain the integrity of its employment policy.

Result: Appeal allowed; the judgment of the single judge was set aside.