Name of the Case : S. R. Bommai vs. Union of India
Year of Judgement : 1994
Popular Name : -
Related Topic/ Issue : President's rule
Related Article/ Schedule : 356
Supreme Court Judgement:
- Upheld the constitutionality of President's rule under Article 356 in Madhya Pradesh, Himachal Pradesh, and Rajasthan in 1992.
- Declared the imposition of President's Rule in Nagaland (1988), Karnataka (1989), and Meghalaya (1991) as unconstitutional.
Established key propositions regarding Article 356:
- Judicial review is applicable to the proclamation issued by the President under Article 356(1).
- The burden of proof lies on the Union Government to justify the proclamation with relevant material.
- Article 74(2) does not prevent scrutiny of the material used by the President to arrive at their decision.
- Invalidity of the proclamation allows courts to reinstate the Legislative Assembly and Ministry, even if approved by Parliament.
- Secularism is part of the basic structure of the constitution, justifying President's Rule in cases of anti-secular acts by State Governments.
Impact of the Judgement:
- Imposed a check on the arbitrary exercise of power under Article 356 by the Centre.
- Ensured that the imposition of President's Rule in states would be subject to judicial scrutiny and require justifiable grounds.
- Upheld the principles of federalism and the autonomy of state governments against undue interference by the central authority.
