Maneka Gandhi Case (1978)

Supreme Court Judgement:

• Overruled its earlier judgement in the A.K. Gopalan case (1950).

• Declared Section 10(3)(c) of the Passport Act (1967) as valid and not violative of Articles 14, 19(1)(a), or (g), and 21.

• Articles 14, 19, and 21 are not mutually exclusive, meaning a law depriving a person of 'personal liberty' must stand the tests of Articles 14 and 19, in addition to Article 21.

• The expression 'personal liberty' in Article 21 is of the widest amplitude, covering a variety of rights constituting personal liberty, some of which are fundamental rights protected under Article 19.

• The right to life under Article 21 includes all aspects that make a man's life meaningful, complete, and worth living. It is not confined to mere physical existence but includes the right to live with human dignity.

• The expression 'procedure established by law' in Article 21 means the procedure must be just, fair, and reasonable, and not arbitrary, fanciful, or oppressive. The procedure should conform to the principles of natural justice.

• The Supreme Court expanded the interpretation of the right to life and personal liberty under Article 21, recognizing it as inclusive of human dignity and various aspects that make life meaningful.

• It established that laws affecting personal liberty must pass the tests of Articles 14, 19, and 21, ensuring they are just, fair, and reasonable.

• The judgement emphasized that the procedure prescribed by law must adhere to principles of natural justice, setting a precedent for future interpretations of Article 21.

Impact of the Judgement:

• Wider Interpretation of Article 21: The judgement significantly broadened the scope of Article 21, emphasizing its inclusive nature and reinforcing the importance of personal liberty and dignity.

• Introduction of 'Due Process of Law': By advocating that the procedure established by law must be just, fair, and reasonable, the judgement introduced the American concept of 'due process of law' into Indian judicial interpretation.

• Establishment of the 'Golden Triangle' Rule: The judgement firmly established the interrelation of Articles 14, 19, and 21, ensuring that any law affecting personal liberty must pass the tests of equality, freedom, and due process.

• Expansion of Article 21: This broader interpretation paved the way for subsequent cases to declare numerous rights as integral parts of Article 21, thus enhancing the protection of fundamental rights under the Constitution.