Maneka Gandhi v. Union of India | |
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Court | Supreme Court of India |
Full case name | Maneka Gandhi v. Union of India (UOI). |
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.M. Fazal Ali) |
Concurrence | M. H. Beg (Chief Justice), Y. V. Chandrachud, V. R. Krishna Iyer |
Dissent | Palapatti 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]