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Gandhi v. Union of India[1], A.L. Kalra v. Project and Equipment Corporation of India Ltd.[2], Ajay Hasia v. Khalid Mujib Sehravardi[3], K.R. Lakshmanan v. State of T.N.[4] and two other Constitution Bench judgments in Mithu v. State of Punjab[5] and Sunil Batra v. Delhi Administration[6] and, eventually, came to hold thus:―
“It is, therefore, clear from a reading of even the aforesaid two Constitution Bench judgments that Article 14 has been referred to in the context of the constitutional invalidity of statutory law to show that such statutory law will be struck down if it is found to be “arbitrary”.”
And again:―
“.....The test of manifest arbitrariness, therefore, as laid down in the aforesaid judgments would apply to invalidate legislation as well as subordinate legislation under Article 14. Manifest arbitrariness, therefore, must be something done by the legislature capriciously, irrationally and/or without adequate determining principle. Also, when something is done which is excessive and disproportionate, such legislation would be manifestly arbitrary. We are, therefore, of the view that arbitrariness in the sense of manifest arbitrariness as
