RAS question
In the S.R. Bommai case (1994), the Supreme Court held that:
Correct answer: (D) Imposition of President's Rule under Article 356 is subject to judicial review.
In S.R. Bommai v. Union of India, the Supreme Court held that the imposition of President's Rule under Article 356 is subject to judicial review.
Explanation
S.R. Bommai v. Union of India is the controlling Article 356 case because the Supreme Court treated President's Rule as a constitutional power with judicially enforceable limits. The judgment says a proclamation under Article 356 can be examined by courts to see whether the required conditions existed and whether the President's satisfaction rested on relevant material, though courts do not reweigh the adequacy of that material as an appellate body. The Court also held that parliamentary approval does not validate an invalid proclamation. Until both Houses approve the proclamation, the State Legislative Assembly should not be dissolved; at most, it may be suspended. This is why option D captures the core holding.
Why the other options are wrong
- (A) The judgment held the opposite: dissolving the Legislative Assembly before approval by both Houses of Parliament is invalid, while suspension may be used.
- (B) The case was about Article 356 and President's Rule, not a holding on imposing Financial Emergency in individual states.
- (C) The Supreme Court expressly treated an Article 356 proclamation as open to judicial review, including after parliamentary approval.
Concept
This tests emergency provisions, federalism, and judicial review under the Indian Constitution. It recurs in RAS because Article 356 is a standard way to examine Centre-State relations and the limits on executive power.