Juris Miscellanea

MANEKA GANDHI vs. UNION OF INDIA 

by | Jul 3, 2025

Supreme Court of India - Maneka Gandhi Judgment 1978 expanding Article 21.

Supreme Court landmark ruling in Maneka Gandhi case 1978 broadening the scope of personal liberty under Article 21.

MANEKA GANDHI vs. UNION OF INDIA 

Gist of Judgment

This landmark judgment reconsidered the scope of Article 21 of the Indian Constitution. The Court held that the expression “personal liberty” includes a variety of rights and that any procedure interfering with this liberty must be just, fair, and reasonable. The judgment overturned the narrow interpretation of fundamental rights laid down in earlier cases like A.K. Gopalan and reinforced the doctrine of natural justice .

MANEKA GANDHI vs. UNION OF INDIA 

Judgment Date – 25th January 1978
Bench – M. Hameedullah Beg (CJ), Y.V. Chandrachud, P.N. Bhagwati, V.R. Krishna Iyer, N.L. Untwalia, Syed Murtaza Fazal Ali, P.S. Kailasam
Citations – AIR 1978 SC 597, (1978) 1 SCC 248, (1978) 2 SCR 621

Legal Issues Involved

  1. Scope and interpretation of Article 21 – “procedure established by law” .
  2. Interrelationship between Articles 14, 19, and 21 .
  3. Whether Section 10(3)(c) of the Passports Act is arbitrary or unconstitutional .
  4. Applicability of Natural justice in administrative actions .
  5. Whether the Right to travel abroad is a part of the right to personal liberty .

Highlights of Judgment

  • Expanded the scope of Article 21 to include substantive due process – laws must be just, fair, and reasonable .
  • Held that Articles 14, 19, and 21 are not mutually exclusive but part of a combined constitutional guarantee .
  • Asserted that natural justice applies even to administrative actions affecting fundamental rights.
  • Clarified that denial of reasons for passport impounding without hearing violates constitutional norms .
  • Overruled the A.K. Gopalan doctrine of exclusive compartmentalization of fundamental rights .
  • Introduced the “golden triangle” doctrine – Articles 14, 19, and 21 are interlinked .

Final Verdict

The Supreme Court has overturned the order of Maneka Gandhi’s passport case and held that the action was violative of her fundamental rights. The judgment laid down that executive actions must pass the tests of fairness and reasonableness, and natural justice must be followed .

Impact of Judgment

  • Changed the face of constitutional jurisprudence in India .
  • Strengthened individual liberties and civil rights .
  •  Inspired several future rulings on due process and natural justice .
  • Paved the way for judicial activism in protecting rights under Article 21 .
  • Triggered reforms in administrative laws and executive accountability .

Related Judgments

  1. A.K. Gopalan vs. State of Madras (1950)
  2. R.C. Cooper vs. Union of India (1970)
  3. ADM Jabalpur vs. Shivkant Shukla (1976)
  4. Satwant Singh Sawhney vs. D. Ramarathnam (1967)
  5. Bennett Coleman vs. Union of India (1973)

    “Article 21… embodies a constitutional value of supreme importance in a democratic society .”

SOURCE – SUPREME COURT OF INDIA

ALSO READ – DOCTRINE OF NATURAL JUSTICE 

Written By Nancy Sharma

I am Nancy Mahavir Sharma, a passionate legal writer and a judicial service aspirant who is interested in legal researching and writing. I have completed Latin Legum Magister degree. I have been writing from past few years and I am excited to share my legal thoughts and opinions here. I believe that everyone has the potential to make a difference.

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