Authored By: SANJANA GHOSH
SAGE UNIVERSITY BHOPAL
Case Title:
Maneka Gandhi v. Union of India (1978)
Court:
Supreme Court of India
Bench:
Justice P.N. Bhagwati and others
Facts of the Case:
The petitioner, Maneka Gandhi, was issued a passport under the Passport Act, 1967. In 1977, the government ordered her to surrender her passport without providing clear reasons. When she requested an explanation, the authorities declined, stating that the reasons could not be disclosed in the interest of the general public. Aggrieved by this action, she filed a writ petition before the Supreme Court claiming violation of her fundamental rights.
Issues Raised:
- Whether the impounding of the passport violated Article 21.
- Whether the procedure established by law was fair and reasonable.
- Whether Articles 14, 19, and 21 are interconnected.
Arguments by the Petitioner:
The petitioner argued that the government’s action was arbitrary and violated her right to personal liberty. She contended that the procedure was not fair, just, or reasonable.
Arguments by the Respondent:
The government argued that the action was taken in the interest of the general public and was within the powers granted under the Passport Act, 1967.
Judgment:
The Supreme Court held that the procedure established by law must be fair, just, and reasonable. The Court ruled in favor of Maneka Gandhi.
Ratio Decidendi:
Articles 14, 19, and 21 are interconnected. Any law affecting personal liberty must be non-arbitrary and reasonable.
Significance of the Case:
This case expanded the scope of Article 21 and introduced the concept of due process in India.
Conclusion:
The judgment strengthened fundamental rights and limited arbitrary government action.
