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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