Landmark Supreme Court Cases — Set 2

Correct Answer: B. Narrowly, confining it to procedure established by law only

A.K. Gopalan v State of Madras (1950) was the Supreme Court's first major pronouncement on Article 21, which guarantees the right to life and personal liberty. The court adopted a narrow interpretation, holding that 'procedure established by law' means any procedure prescribed by a validly enacted law, regardless of whether it conforms to principles of natural justice or due process. This approach kept each fundamental right in watertight compartments and was significantly overruled by Maneka Gandhi v Union of India (1978).

Correct Answer: C. Article 21

Maneka Gandhi v Union of India (1978) arose from the government's impounding of Maneka Gandhi's passport without giving her any reason or opportunity to be heard. The Supreme Court dramatically expanded Article 21, holding that the 'procedure established by law' must be fair, just, and reasonable — not arbitrary, fanciful, or oppressive. This judgment also established that Articles 14, 19, and 21 are not mutually exclusive but form a golden triangle that must be read together to give full effect to the right to life.

Correct Answer: B. Articles 14, 19, and 21

Maneka Gandhi v Union of India (1978) established that Articles 14 (right to equality), 19 (right to freedom), and 21 (right to life and personal liberty) are not mutually exclusive but are interrelated and form a 'golden triangle'. Any law restricting Article 21 must also satisfy the requirements of Articles 14 and 19. This interconnected reading vastly expanded the protection offered to citizens and transformed Article 21 from a narrow procedural guarantee into a substantive fundamental right.

Correct Answer: B. Human dignity

Francis Coralie Mullin v Administrator, UT of Delhi (1981) involved a detenu's right to meet her lawyer and family members. Justice Bhagwati held that the right to live with human dignity, free from exploitation, is an integral part of Article 21's right to life and personal liberty. The judgment stated that the right to life encompasses not just animal existence but the full gamut of rights that make life worth living, including adequate nutrition, clothing, shelter, and opportunity to develop faculties.

Correct Answer: B. Right to livelihood

Olga Tellis v Bombay Municipal Corporation (1985), popularly known as the 'Pavement Dwellers' case, challenged the eviction of pavement and slum dwellers from Bombay. Chief Justice Chandrachud held that the right to livelihood is an integral component of the right to life under Article 21, because no person can live without the means of living. The state must therefore follow fair procedure before evicting persons whose livelihood depends on their residence near their place of work.

Correct Answer: C. Unni Krishnan v State of AP 1993

Unni Krishnan v State of Andhra Pradesh (1993) is the landmark judgment in which the Supreme Court held that the right to education is a fundamental right flowing from Article 21 read with Articles 41, 45, and 46 of the Constitution. The court held that every child/citizen has a right to free education until age 14 years, after which the obligation depends on the economic capacity of the state. This judgment laid the foundation for the later 86th Constitutional Amendment (2002) which inserted Article 21A.

Correct Answer: B. Unni Krishnan v State of AP 1993

Unni Krishnan v State of Andhra Pradesh (1993) directly inspired the 86th Constitutional Amendment Act of 2002 which inserted Article 21A, making the right to free and compulsory education for children aged 6-14 years a Fundamental Right. The Supreme Court's judicial activism in deriving education as a fundamental right from Article 21 pushed the legislature to constitutionally enshrine it. The Right to Education Act, 2009 was subsequently enacted to give effect to Article 21A.

Correct Answer: A. Hussainara Khatoon v State of Bihar 1979

Hussainara Khatoon v State of Bihar (1979) arose from a newspaper report about thousands of undertrial prisoners in Bihar jails who had spent more time in prison than the maximum sentence for their alleged offences. Justice Bhagwati held that the right to speedy trial is a fundamental right implicit in Article 21's guarantee of the right to life and personal liberty. This landmark PIL judgment led to the release of over 40,000 undertrial prisoners and established public interest litigation as a powerful tool of justice.

Correct Answer: B. Maneka Gandhi 1978

Maneka Gandhi v Union of India (1978) effectively read due process into Article 21 by holding that 'procedure established by law' must be reasonable, fair, and just. Though the Constitution's framers had consciously rejected the American 'due process' clause and substituted 'procedure established by law', the Supreme Court in Maneka Gandhi achieved a substantially similar result through purposive interpretation. This transformed Article 21 from a formal procedural protection into a substantive guarantee of fairness.

Correct Answer: B. Article 21 — Right to Life and Personal Liberty

Maneka Gandhi v Union of India (1978) primarily involved Article 21 — the right to life and personal liberty — when Maneka Gandhi's passport was impounded under the Passports Act, 1967. The government refused to give reasons for the impoundment, claiming it was not in the public interest. The court held that the right to go abroad is part of personal liberty under Article 21 and its deprivation must follow a procedure that is fair, just, and reasonable, giving rise to the expanded interpretation of Article 21.