Maneka Gandhi vs Union of India (1978)
Syllabus: Polity and Governance (UPSC GS II)
The Maneka Gandhi vs Union of India case is a landmark judgment that transformed the interpretation of Article 21 of the Indian Constitution, expanding the meaning of “personal liberty” and establishing the “Golden Triangle” doctrine linking Articles 14, 19, and 21. It reaffirmed the Supreme Court’s role as the watchdog of democracy and strengthened the concept of a welfare state.
Facts of the Case
Maneka Gandhi’s passport, issued in 1976 under the Passport Act, 1967, was impounded by the Regional Passport Office in 1977 under Section 10(3)(c), without disclosing any reason, citing “public interest.” When she sought clarification, the authorities refused to provide an explanation. She filed a writ petition under Article 32, alleging violation of her fundamental rights under Articles 14, 19, and 21, and challenging the constitutional validity of Section 10(3)(c) as arbitrary and ultra vires.
Issues Before the Court
- Whether the right to travel abroad is part of the right to personal liberty under Article 21.
- Whether Articles 14, 19, and 21 are interrelated and must be read together.
- Whether Section 10(3)(c) of the Passport Act violates fundamental rights and principles of natural justice.
- What is the scope of “procedure established by law” under Article 21?
Contentions
- Petitioner: Argued that impounding her passport violated her right to personal liberty and was neither fair nor reasonable, breaching natural justice (audi alteram partem). The procedure under the Passport Act lacked due process and failed to meet constitutional standards of fairness and reasonableness.
- Respondent: Relied on the A.K. Gopalan precedent, contending that “procedure established by law” did not need to meet the test of reasonableness, and the government acted in the public interest.
Judgment
Delivered on January 25, 1978, the Supreme Court ruled in favour of Maneka Gandhi, holding that “personal liberty” must be interpreted broadly. It declared that any law depriving a person of liberty must satisfy the tests of Articles 14, 19, and 21, forming the Golden Triangle of rights. The Court overruled A.K. Gopalan, establishing that laws must be fair, just, and reasonable, and that arbitrary state action violates fundamental rights.
Impact
The judgment revolutionized constitutional interpretation in India by expanding Article 21 to include due process of law, laying the foundation for the protection of human dignity and procedural fairness. It remains a cornerstone in the evolution of constitutional democracy and judicial activism in India.
