RAS question
In Maneka Gandhi v. Union of India (1978), the Supreme Court significantly expanded the scope of Article 21. What was the key ruling?
Correct answer: (B) The 'procedure established by law' must be just, fair, and reasonable — not arbitrary.
In Maneka Gandhi v. Union of India (1978), the Supreme Court held that Article 21 permits deprivation of life or personal liberty only through a procedure that is just, fair, reasonable and not arbitrary.
Explanation
Maneka Gandhi gave Article 21 a wider, rights-protective meaning. The Court did not treat "procedure established by law" as a mere formal requirement that any enacted procedure would satisfy. It held that a law affecting life or personal liberty must also meet the standards of Articles 14 and 19. In practical terms, the procedure must pass the test of reasonableness and must be right, just and fair, not arbitrary, fanciful or oppressive. That is why option B is the key ruling: Article 21 became a safeguard against both executive and legislative action that deprives a person of liberty through an unfair or unreasonable process.
Why the other options are wrong
- (A) The case concerns life and personal liberty under Article 21, not a ruling that the right to property is a Fundamental Right.
- (C) The holding explained the quality of procedure required under Article 21; it was not about whether Parliament can amend Fundamental Rights.
- (D) The decision links Article 21 with the safeguards of Articles 14 and 19, rather than saying that DPSP prevail over Fundamental Rights in all cases.
Concept
This tests the judicial expansion of Fundamental Rights, especially the Article 14-19-21 relationship. It recurs in RAS because many polity questions turn on whether a legal procedure is merely enacted or is constitutionally fair and non-arbitrary.