- The right to life and personal liberty is one of the most cherished rights guaranteed by the Indian Constitution. Over the years, courts have expanded its scope to cover not only physical survival but also dignity, privacy, and freedom of movement. One of the most important milestones in this journey is the Supreme Court’s decision in Maneka Gandhi v. Union of India (1978). This case transformed the interpretation of Article 21 of the Constitution and remains a cornerstone of Indian constitutional law.
- The case arose when the government impounded Maneka Gandhi’s passport under the Passports Act, 1967 without giving her a proper hearing. She challenged this action, arguing that it violated her fundamental right to personal liberty under Article 21. The central question before the Court was whether the procedure prescribed by law for depriving a person of liberty must also be fair and reasonable.
- The Supreme Court delivered a pathbreaking judgment. It held that the term “personal liberty” in Article 21 is of the widest amplitude and covers a variety of rights that constitute the personal freedom of an individual. More importantly, the Court held that no procedure prescribed by law can be arbitrary, unfair, or unreasonable. In other words, the right to life and liberty is not just about following any procedure but about following a fair and just procedure.
- The judgment established a vital connection between Articles 14, 19, and 21. The Court declared that these three articles form a golden triangle, ensuring that laws affecting liberty must satisfy the tests of equality, reasonableness, and fairness. This interpretation opened the doors for judicial creativity in protecting rights such as the right to travel abroad, the right to live with dignity, and later, even the right to privacy.
- The impact of Maneka Gandhi has been profound. It shifted the constitutional philosophy from a narrow interpretation of fundamental rights to a broad, people-centric approach. It ensured that the government could not curtail liberty under the cover of procedural technicalities. Every law interfering with personal liberty would henceforth be scrutinized for fairness.
- Today, this judgment continues to guide courts whenever the state seeks to restrict individual freedom. Whether it is preventive detention, surveillance, or restrictions on movement, the principle laid down in Maneka Gandhi ensures that liberty cannot be compromised except through fair, just, and reasonable means.
- In conclusion, the Maneka Gandhi case breathed life into Article 21 and transformed it into a powerful safeguard of human freedom. It remains a shining example of judicial activism in defense of personal liberty.
