मनेका गाँधी बनाम भारत संघ
| Citation | AIR 1978 SC 597 |
| Court | Supreme Court of India (Constitution Bench) |
| Date | 25 January 1978 |
| Year | 1978 |
| Bench | M.H. Beg CJI, Y.V. Chandrachud, P.N. Bhagwati, V.R. Krishna Iyer, N.L. Untwalia, S. Murtaza Fazl Ali, P.S. Kailasam JJ. |
| Acts/Articles | Article 14, Article 19(1)(a), Article 19(1)(g), Article 21, Passports Act 1967 |
| Category | Constitutional Law |
Key Principle Established
Article 21 requires procedure to be fair, just, and reasonable — not merely "procedure established by law." Articles 14, 19, and 21 are interconnected and form a golden triangle.
Maneka Gandhi’s passport was impounded by the government under Section 10(3)(c) of the Passports Act, 1967 “in the interests of the general public” without giving any reasons. She challenged this action as violative of her fundamental rights.
The 7-Judge Constitution Bench delivered what is considered the most transformative judgment in Indian constitutional law:
Maneka Gandhi fundamentally transformed Article 21 from a limited procedural guarantee into a comprehensive charter of rights. Every subsequent expansion of Article 21 — right to speedy trial, right to legal aid, right to health, right to education, right to privacy — traces its origin to this judgment. The “golden triangle” concept ensures that no law can survive constitutional challenge by satisfying only one article while violating another.
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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.