Maneka
Gandhi v. Union of India (1978) overruled the restrictive interpretation
of Article 21 established in A.K. Gopalan v. State of Madras (1950) by
expanding the scope of personal liberty and introducing substantive due process
standards.
Rejecting
Compartmentalization
A.K.
Gopalan had treated fundamental rights as watertight compartments, holding that
Articles 14, 19, and 21 operated independently—Article 21 only required a
"procedure established by law," not one that was fair or just. Maneka
rejected this, declaring Articles 14 (equality), 19 (freedoms), and 21 (life
and liberty) as interlinked, forming a "golden triangle" where any
law depriving liberty must satisfy the reasonableness test under all three.
Introducing
Fairness Requirement
Gopalan
permitted arbitrary procedures if legislatively sanctioned, limiting personal
liberty to physical restraint. Maneka overruled this by mandating that
procedures be "right, just, and fair," aligning with natural justice
principles and overruling Gopalan's narrow view, as echoed in Justice Fazl
Ali's Gopalan dissent.
Lasting
Doctrinal Shift
This
shift empowered judicial review of laws for arbitrariness, paving the way for
Article 21's evolution to include rights like privacy and dignity,
fundamentally altering constitutional jurisprudence from procedural to
substantive protections.
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