Court: Supreme Court of India · Date: 25 January 1978 · Citation: (1978) 1 SCC 248
Bench: Seven-Judge Bench
Case
Maneka Gandhi v. Union of India
Facts
Passport of the petitioner was impounded without a pre-decisional hearing; she challenged the procedure and the rights impact.
Legal issues
Can personal liberty under Article 21 be curtailed by any procedure established by law, however unfair?
Law / provisions
Articles 14, 19, 21; Passport Act.
Holding
‘Procedure established by law’ under Article 21 must be fair, just and reasonable. Articles 14, 19 and 21 are read together — due-process content entered Indian constitutional law.
Key takeaways
- Article 21 is not a formal checkbox — procedure must be fair.
- Rights are read as a web, not sealed silos.
- Administrative action affecting liberty needs fairness.
Significance
Turns Article 21 into the engine of substantive fairness in Indian public law.
Primary source
https://indiankanoon.org/doc/1766147/
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Education desk note — Advocate Adesh Kumar — advadeshkumar.com
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