Judgments

REYNOLDS VS SIMS : CASE SUMMARY

The Supreme Court held in Reynolds Vs SIMS (1964) that legislative districts of unequal population sizes in States are unconstitutional.

FACTS OF THE CASE

Prior to passing of this judgment representation in state legislatures had become skewed over the years due to urbanization and industrialization. Population in every legislative district was not equal. Rural areas were overrepresented in State Legislatures while Urban areas were underrepresented. Situation was similar in State of Alabama. The effect of this was that in rural area value of one vote was greater than value of one vote in urban area.

Some voters including Sims of  Jefferson County, Alabama  challenged the disparity in representation on the ground that it violates equal protection clause of the Fourteenth Amendment.

OPINION OF THE SUPREME COURT

The Supreme Court held that apportionment system in Alabama was violative of equal protection clause of the Fourteenth Amendment.

There Supreme Court relied on Baker Vs Carr (1962) wherein it has been held that Supreme Court has power to review apportionment cases.  The Supreme Court also relied on Gray vs Sanders  (1963) wherein the Supreme Court has held that principle of “one person one vote” should be adopted in State Elections.

Both houses of the State Legislature should be apportioned in a manner that each legislative district should have roughly equal population size.

Chief Justice Warren commented that Legislature represent people not trees or acres. Each citizen regardless of where they live should have equal representation. Legislative District of unequal sizes are violative of equal protection clause of Fourteenth Amendment.

DISSENTING OPINION

Justice Harlan II delivered dissenting opinion. Justice Harlan II was of the view that Equal Protection Clause did not extend to voting rights. The Court has amended the Constitution through its opinion rather than waiting for amendment process envisaged in the Constitution.

IMPACT OF THE CASE

Reynolds Vs Sims is a landmark judgment in Constitutional Law which firmly established one person one vote principle. Urban population was largely benefited by this judgment. This judgment also benefited ethnic and racial minorities as they were mostly settled in urban centers.

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Mukesh Kumar Suman is an advocate and legal author based at Delhi. He regularly appears before various Judicial Forums including NCLT, NCLAT, High Courts and the Supreme Court. He can be approached at mukesh_suman@outlook.com or +91 9717864570.

Mukesh Kumar Suman

Mukesh Kumar Suman

Mukesh Kumar Suman is an advocate based at Delhi. He has rich experience in civil, criminal, commercial, arbitration and corporate insolvency matters. He regularly appears before District Courts, NCLT, NCLAT, High Court and the Supreme Court. He can be approached at mukesh_suman@outlook.com or +91 9717864570.

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