Maneka Gandhi v. Union of India
Visual Summary
Golden Triangle: Articles 14 (Equality), 19 (Freedom), and 21 (Life & Liberty) are interconnected and must be read together.
Case Details
Facts of the Case
The passport of the petitioner was impounded by the government under the Passport Act without providing reasons. The petitioner challenged this action.
Legal Issues
Whether the right to travel abroad is part of personal liberty under Article 21? What is the scope of "procedure established by law"?
The Judgment
Court's Decision
The Court held that the procedure under Article 21 must be fair, just, and reasonable. Articles 14, 19, and 21 are not mutually exclusive but form a golden triangle.
Legal Principles Established
The procedure established by law must satisfy the test of reasonableness under Articles 14 and 19. The golden triangle doctrine was established.
Impact & Significance
Impact on Society
This judgment significantly expanded the interpretation of Article 21 and established that personal liberty can only be curtailed by a procedure that is fair, just, and reasonable.
Real-Life Impact
This judgment transformed the interpretation of Article 21 and became the basis for numerous subsequent rights-based decisions.