In E. P. Royappa v. State of Tamil Nadu (1974), Justice P.N. Bhagwati, speaking for himself and Justice Chandrachud, laid down the principle that Article 14 strikes at arbitrariness in State action. He stated that equality is a dynamic concept, and arbitrariness is the very antithesis of equality. This judgment expanded the scope of Article 14 beyond mere classification and incorporated the doctrine that any arbitrary action by the state violates the guarantee of equality.