Meaning and Constitutional Basis
The Doctrine of Repugnancy deals with conflicts between Central and State laws on matters listed in the Concurrent List of the Seventh Schedule. It is enshrined in Article 254 of the Indian Constitution. When both the Parliament and a State Legislature make laws on the same subject and there is a conflict between the two, the Central law prevails, and the State law becomes void to the extent of the inconsistency. This doctrine maintains constitutional supremacy of the Union Parliament while preserving the federal balance between the Centre and the States. It ensures uniformity of laws on matters of national importance.
Legal Provisions and Exceptions
Under Article 254(1), if any provision of a State law is repugnant to a Central law on a matter in the Concurrent List, the Central law prevails. However, Article 254(2) provides an exception — if a State law, having been reserved for the President’s assent, receives such assent, it shall prevail within that State, even if it conflicts with a Central law. Nevertheless, Parliament retains the power to override such a State law later. This mechanism balances federal autonomy and national uniformity, ensuring legislative harmony in overlapping areas of jurisdiction.
Objective and Importance
The primary purpose of this doctrine is to avoid confusion, duplication, and contradictions in the legal system. It ensures that citizens are governed by a clear and consistent set of laws. The doctrine reinforces the principle of supremacy of Parliament in the Concurrent List while respecting the legislative competence of States. It is an essential feature of cooperative federalism, providing a constitutional remedy for resolving legislative conflicts between different levels of government. Thus, it preserves both the unity and diversity of India’s federal structure.
Real-Time Example
A notable case illustrating this doctrine is M. Karunanidhi v. Union of India (1979), where the Supreme Court held that repugnancy arises only when there is a direct conflict between Central and State laws on the same subject. In this case, the Tamil Nadu Public Men (Criminal Misconduct) Act, 1973, was challenged for being inconsistent with the Central Prevention of Corruption Act, 1947. The Court ruled that since both laws operated in different fields, there was no repugnancy. This judgment clarified the circumstances under which Article 254 applies.
Mnemonic to Remember – “CARDS”
C – Conflict between Centre and State laws
A – Article 254 governs repugnancy
R – Repugnant State law becomes void
D – Doctrine ensures uniformity and clarity
S – State law valid only with Presidential assent
The mnemonic “CARDS” helps recall that the Doctrine of Repugnancy deals with Conflict, Article 254, Repugnancy, Doctrine purpose, and State assent, ensuring smooth Coordination Among Regulations of Dual Sovereigns.
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Discover the Doctrine of Repugnancy under Article 254 of the Indian Constitution at Lawgnan.in. Understand how conflicts between Central and State laws in the Concurrent List are resolved to maintain constitutional supremacy and federal balance. This detailed explanation includes legal provisions, exceptions, and case laws like M. Karunanidhi v. Union of India (1979) that shaped the interpretation of legislative conflicts. Ideal for law students, UPSC aspirants, and judiciary exam candidates, the article simplifies how repugnancy ensures uniformity and clarity in India’s dual legislative system while upholding the principle of cooperative federalism.
