Maneka Gandhi v. Union of India

Maneka Gandhi v. Union of India
CourtSupreme Court of India
Full case name Maneka Gandhi v. Union of India (UOI).
Decided1978
Citations1978 2 S.C.R. 621; 1978 INSC 16; AIR 1978 SC 597; (1978) 1 SCC 248
Court membership
Judges sittingM. 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 byP. N. Bhagwati (for himself, N.L. Untwalia, and S.M. Fazal Ali)
ConcurrenceM. H. Beg (Chief Justice), Y. V. Chandrachud, V. R. Krishna Iyer
DissentPalapatti Sadaya Goundar Kailasam
Laws applied
This case overturned a previous ruling
A. K. Gopalan v. State of Madras by Supreme Court of India

Maneka Gandhi v. Union of India, AIR 1978 SC 597, was a landmark decision of the Supreme Court of India in which the Court significantly expanded the interpretation of Article 21 of the Constitution of India. It overruled A. K. Gopalan v. State of Madras, which had implied the exclusiveness of fundamental rights, and established a relationship between Articles 14, 19, and 21 of the Constitution (known as the 'golden triangle' or 'trinity'),[1]: 222  holding that a law depriving a person of 'personal liberty' must not violate any of them.[1]: 220  Once again overruling A. K. Gopalan, the Court in this case held that a 'procedure' under Article 21 of the Constitution cannot be arbitrary, unfair, oppressive, or unreasonable.[1]: 220 

The decision had a significant influence on Indian constitutional law and has been described as the moment when the Supreme Court of India rejected "three decades of formalist interpretation, and inaugurated a new path where Courts would expand the rights of individuals against the State, instead of limiting or contracting them."[2]

  1. ^ a b c Singh, Mahendra Pal (2019). V. N. Shukla's Constitution of India (13th ed.). Eastern Book Company. ISBN 978-9388822213.
  2. ^ Bhatia, Gautam (9 September 2017). "The Supreme Court's Right to Privacy Judgment – X: Conclusion: The Proof of the Pudding". Indian Constitutional Law and Philosophy. Retrieved 18 May 2021.