सतवंत सिंह साहनी बनाम डी. रामरत्नम
| Citation | AIR 1967 SC 1836 |
| Court | Supreme Court of India (Constitution Bench) |
| Date | 24 April 1967 |
| Year | 1967 |
| Bench | K. Subba Rao CJI, M. Hidayatullah, R.S. Bachawat, J.M. Shelat, C.A. Vaidialingam JJ. |
| Acts/Articles | Article 14, Article 21 |
| Category | Constitutional Law |
Key Principle Established
Right to travel abroad is a fundamental right under Article 21. Refusal or impounding of passport without following due process violates Articles 14 and 21.
The passport of a citizen was impounded without giving reasons. The question was whether the right to travel abroad is part of “personal liberty” under Article 21.
The Constitution Bench held that right to travel abroad is part of personal liberty under Article 21. The expression “personal liberty” includes the right of locomotion and the right to travel abroad. Refusal to issue a passport or impounding one already issued, without following due process, violates Articles 14 and 21.
This judgment was a precursor to the Passports Act, 1967 and later to the more expansive interpretation of Article 21 in Maneka Gandhi (1978). It established that personal liberty is not limited to freedom from physical restraint.
(1984) 3 SCC 243
Release of bonded labourers without rehabilitation is cruelty. The State must ensure identification, release AND rehabilitation of bonded labourers.
Read Analysis(1986) 3 SCC 632
Children cannot be kept in jails. Directions issued for establishment of juvenile courts, children's homes, and appointment of duty counsel…
Read AnalysisAIR 1993 SC 1960
State is liable to pay compensation for custodial death as a public law remedy under Article 32/226, independent of any…
Read AnalysisThis judgment summary is for educational and research purposes. While care has been taken to accurately represent the ratio and findings, for authoritative reference always consult the original judgment text from official sources (SCC Online, AIR, Manupatra, or court websites).
22+ years of practice before Punjab & Haryana High Court and Supreme Court of India.