RAS question
The Supreme Court in Maneka Gandhi v. Union of India (1978) expanded the scope of which Article?
Correct answer: (B) Article 21.
In Maneka Gandhi v. Union of India (1978), the Supreme Court expanded the scope of Article 21 by requiring any procedure that deprives life or personal liberty to be fair, just and reasonable.
Explanation
Maneka Gandhi v. Union of India is central to Article 21 because it transformed ‘procedure established by law’ from a merely formal requirement into an effective constitutional safeguard. The judgment treated Article 21 as the foundation of many substantive and procedural rights and held that a procedure affecting life or personal liberty cannot be arbitrary, unfair or unreasonable. Article 21 is therefore the principal provision at issue, rather than equality or freedoms viewed separately. Articles 14 and 19 remain connected: a law affecting personal liberty must satisfy the tests of non-arbitrariness and constitutional reasonableness, but it is Article 21 whose scope was expanded.
Why the other options are wrong
- (A) Article 14 supplies the non-arbitrariness and equality lens linked to the judgment, but Article 21’s protection of life and personal liberty is the provision expanded in Maneka Gandhi.
- (C) Article 19 is relevant because personal-liberty restrictions must also meet constitutional reasonableness, but the Maneka Gandhi expansion concerns Article 21.
- (D) The judgment linked Articles 14, 19 and 21, yet Article 21 was the specific provision expanded through the fairness requirement for procedure affecting life or personal liberty.
Concept
Under the Indian Constitution’s Fundamental Rights doctrine, Article 21 requires legal procedure to be substantively fair, not merely formally valid. Maneka Gandhi recurs in RAS because it is a foundational case for questions on personal liberty, reasonableness and non-arbitrariness.