Tuesday, January 20, 2026

What was the key ruling in Maneka Gandhi case

What was the key ruling in Maneka Gandhi case

Maneka Gandhi v. Union of India (1978) delivered its key ruling by expanding Article 21's protection of life and personal liberty, mandating that any deprivation must follow a procedure that is "right, just, and fair," rather than merely one established by law.

 

Linking the Golden Triangle

 

The Court ruled that Articles 14 (equality), 19 (freedoms), and 21 mutually reinforce each other—any law impinging on personal liberty must pass tests of non-arbitrariness under Article 14, reasonableness under Article 19, and fairness under Article 21. This overturned the siloed approach of earlier precedents.

 

Rejecting Passport Impoundment

 

On facts, the Court invalidated the arbitrary impounding of Maneka's passport without hearing or reasons, upholding her right to travel abroad as part of personal liberty while preserving Sections 10(3)(c) and 10(5) of the Passports Act.

 

Broader Implications

 

This introduced an Indian version of substantive due process, enabling Article 21 to encompass dignity, privacy, and more, fueling judicial activism in rights expansion.

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