Maneka
Gandhi v. Union of India (1978) fundamentally transformed Article 21 of
the Indian Constitution, which guarantees that no person shall be deprived of
life or personal liberty except by procedure established by law.
Overruling
Narrow Precedents
Prior
to this case, A.K. Gopalan v. State of Madras (1950) had interpreted Article 21
restrictively, confining "personal liberty" to physical freedom and
allowing any legislatively prescribed procedure, even if arbitrary. The Supreme
Court rejected this, holding that the procedure must be "right, just, and
fair," effectively introducing substantive due process akin to the U.S.
model without explicitly adopting the term.
Forming
the Golden Triangle
The
judgment interlinked Articles 14 (equality), 19 (freedoms), and 21, mandating
that any deprivation of liberty must satisfy all three—any law failing this
test would be unconstitutional. This expansive reading elevated Article 21 from
a mere procedural safeguard to a bulwark protecting a broad spectrum of rights.
Expansive
Rights Incorporation
Post-Maneka, Article 21 evolved to encompass rights to privacy, health, shelter, education, clean environment, speedy trial, and dignity, as seen in later cases like Puttaswamy (2017) and Hussainara Khatoon. It strengthened judicial review, curbing executive overreach and ensuring reasonableness in laws affecting liberty.
Howdid Maneka Ghandhi case overrule AK Gopalan case
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