The Maneka Gandhi v. Union of India case is a landmark judgment in Indian constitutional law, particularly in the context of personal liberty. Maneka Gandhi, the daughter-in-law of former Prime Minister Indira Gandhi, had her passport impounded by the government under the Passport Act. She challenged this action, arguing that it violated her fundamental rights.
The case primarily revolved around Article 21 of the Indian Constitution, which guarantees the right to life and personal liberty. The Supreme Court, in its judgment delivered by Chief Justice Y. V. Chandrachud, significantly expanded the scope of Article 21. The court held that the procedure established by law for depriving a person of their life or personal liberty must be fair and reasonable, and it cannot be arbitrary, fanciful, or oppressive.
Background:
Maneka Gandhi’s passport was impounded by the government, preventing her from traveling abroad. The authorities cited Section 10(3)( c ) of the Passport Act, 1967, as the basis for their action. Maneka Gandhi challenged this decision, asserting that it violated her fundamental right to life and personal liberty under Article 21 of the Constitution.
Key aspects and rulings:
Broader Interpretation of Article 21:
The Supreme Court, in this case, held that the right to life and personal liberty is not confined to mere animal existence but includes a right to live with dignity. The court widened the scope of Article 21 to cover a range of rights beyond the right to physical existence.
Procedure Established by Law:
The court rejected the narrow interpretation that any procedure prescribed by law would be sufficient for depriving a person of their personal liberty. It introduced the concept that the procedure must be fair, just, and reasonable, marking a departure from the strict literal interpretation of “procedure established by law.”
Natural Justice:
The court emphasized the principles of natural justice, stating that the principles of natural justice must be read into Article 21. This means that any action affecting the personal liberty of an individual must be taken fairly and justly.
Reasonable Procedure:
The court held that the procedure must not only be fair but must also be reasonable, which involves being just, fair, and not arbitrary.
Conclusion:
The Maneka Gandhi case is considered a pivotal moment in Indian jurisprudence, setting the groundwork for a broader understanding of fundamental rights and the limitations on state action. It marked a departure from the strict literal interpretation of constitutional provisions, emphasizing the need for fairness and reasonableness in procedures affecting individual liberties.