Maneka Gandhi Case(1978)

The Maneka Gandhi case, formally known as “Maneka Gandhi vs. Union of India” (1978), is a landmark judgment in Indian constitutional law that significantly expanded the interpretation of Article 21 of the Indian Constitution, which guarantees the right to life and personal liberty.

Background: Maneka Gandhi, a journalist and social activist, was issued a passport under the Passport Act, 1967. However, her passport was impounded by the Indian government “in the interest of the general public.” Maneka Gandhi was not provided with any reasons for this action nor was she given an opportunity to be heard. She challenged the government’s order, arguing that it violated her fundamental rights under Articles 14 (Right to Equality), 19 (Right to Freedom), and 21 (Right to Life and Personal Liberty).

Judgment: The Supreme Court of India, in a historic judgment, held that the right to life and personal liberty under Article 21 is not confined to mere animal existence but includes the right to live with human dignity. The court stated that any procedure established by law, under Article 21, must be “just, fair and reasonable,” and not arbitrary or oppressive.

Key Highlights:

1. Expansion of Article 21: The court broadened the scope of Article 21, asserting that personal liberty encompasses a variety of rights that constitute the personal liberty of an individual.
2. Interrelation of Fundamental Rights: The judgment emphasized that Articles 14, 19, and 21 are not mutually exclusive but are interlinked. Any law depriving a person of ‘personal liberty’ has to stand the test of these three articles.
3. Due Process: The court implicitly incorporated the concept of ‘due process of law’ into Article 21, requiring any law affecting personal liberty to be reasonable, just, and fair.

Significance: The Maneka Gandhi case is pivotal because it transformed the interpretation of the right to life and personal liberty, making it more comprehensive and meaningful. It ensured that any action by the state affecting these rights must be fair and just, thus safeguarding individuals against arbitrary state action. This judgment also laid the foundation for subsequent rulings on human rights and personal liberties in India, making it a cornerstone of Indian constitutional jurisprudence.