Maneka Gandhi v Union of India was a 1978 decision of the Supreme Court of India arising after the government impounded journalist Maneka Gandhi's passport without giving reasons. The Court held that any law depriving a person of personal liberty under Article 21 of the Constitution must be just, fair and reasonable, not merely enacted through some procedure established by law, effectively reading a due process requirement into a constitutional text that, unlike the American due process clause, had deliberately omitted the phrase. The decision is regarded as the beginning of the Indian judiciary's expansive, rights protective reading of the right to life and personal liberty, and it underlies later rulings on dignity and privacy including Justice K S Puttaswamy v Union of India.
Facts
Decision Year HoldingThe Court held that any law depriving a person of personal liberty under Article 21 must prescribe a procedure that is just, fair and reasonable, reading Articles 14, 19 and 21 together rather than as mutually exclusive, rejecting a reading that allowed arbitrary or oppressive state action. 2 Current StatusLandmark decision, described by legal scholars as a turning point in Indian jurisprudence that moved the Court away from formalistic interpretation toward expanding individual rights against the state; treated as continuing good law. 2 Case Status
Case Status (category) Connections
Associated With
Due Process, Doctrines Maneka Gandhi is the landmark case reading substantive due process into Article 21 of the Indian Constitution despite the framers' deliberate rejection of the phrase.
Decided By
Decided by the Supreme Court of India, 1978.
In Legal System
A ruling of the Indian Supreme Court under the Indian Constitution.
In the Other Atlases
Found In
Also in Geography Atlas: where this subject is found.
Sources
1. Wikidata: Maneka Gandhi v Union of India
Source: this decision overruled prior precedent and established the still-current 'golden triangle' doctrineView the Source 2. Maneka Gandhi v. Union of India (Wikipedia)
Wikimedia FoundationCase infobox, citation field
1978 2 S.C.R. 621
Significance section, Article 21 procedure standard
the 'procedure established by law' under Article 21 must be just, fair, and reasonable
Background section, scholarly assessment of the ruling's significance
Legal scholars have described the ruling as a turning point in Indian jurisprudence, signaling a move away from formalistic interpretations and toward a more rights-expanding approach.
In Group: Liberty, Emergency Powers and Social Rights Cases, Introduction, sentence 4
It held that any law depriving a person of "personal liberty" must satisfy all three provisions.
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