Article 21 and Due Process
Maneka Gandhi v. Union of India
Court: Supreme Court of India | Year: 1978
A landmark Article 21 judgment that expanded personal liberty and required legal procedure to be fair, just, and reasonable.
Maneka Gandhi v. Union of India transformed the interpretation of Article 21. The case concerned the impounding of a passport and raised questions of personal liberty, procedure, and fairness.
The Court moved away from a narrow reading of Article 21 and held that any procedure depriving a person of life or personal liberty must be fair, just, and reasonable.
The case also connected Articles 14, 19, and 21, making fundamental rights more interdependent and meaningful.
Key Learning Points
- Expanded the meaning of personal liberty.
- Required procedure under Article 21 to be fair and reasonable.
- Linked Articles 14, 19, and 21.
- Became the foundation for later rights-based Article 21 jurisprudence.
Intern Takeaway
When reading Article 21 cases, check whether the State action is lawful, non-arbitrary, fair, and proportionate.
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