Maneka Gandhi v. Union of India
| Maneka Gandhi v. Union of India | |
|---|---|
| Court | Supreme Court of India |
| Full case name | Maneka Gandhi v. Union of India |
| Decided | 1978 |
| Citations | 1978 2 S.C.R. 621; 1978 INSC 16; AIR 1978 SC 597; (1978) 1 SCC 248 |
| Court membership | |
| Judges sitting | M. H. Beg (Chief Justice), Y. V. Chandrachud, V. R. Krishna Iyer, P. N. Bhagwati, N. L. Untwalia, S. Murtaza Fazal Ali, P. S. Kailasam |
| Case opinions | |
| Decision by | P. N. Bhagwati (for himself, N. L. Untwalia, and S. Murtaza Fazal Ali) |
| Concurrence | M. H. Beg (Chief Justice), Y. V. Chandrachud, V. R. Krishna Iyer |
| Dissent | P. S. Kailasam |
| Laws applied | |
This case overturned a previous ruling | |
| A. K. Gopalan v. State of Madras | |
Maneka Gandhi v. Union of India, AIR 1978 SC 597, was a landmark decision of the Supreme Court of India that significantly expanded the interpretation of Article 21 of the Constitution of India. The Court overruled A. K. Gopalan v. State of Madras (1950), which had held that fundamental rights were exclusive and independent of each other. Instead, the Court established that Articles 14, 19, and 21 were interlinked, forming what is known as the 'golden triangle' of the Constitution.: 222 It held that any law depriving a person of "personal liberty" must satisfy all three provisions.: 220
The Court further ruled that the "procedure" established by law under Article 21 must be just, fair, and reasonable, rejecting earlier interpretations that allowed arbitrary or oppressive state action.: 220 This decision marked a fundamental shift in Indian constitutional law, prioritizing individual rights over a restrictive reading of state power.
Legal scholars have described the ruling as a turning point in Indian jurisprudence, signaling a move away from formalistic interpretations and toward a more rights-expanding approach. As one scholar noted, Maneka Gandhi marked the moment when the Supreme Court "inaugurated a new path where Courts would expand the rights of individuals against the State, instead of limiting or contracting them."