Skip to main content
Adhikar is an independent citizen-awareness initiative — not a Government of India website.
Home Landmark Judgments Fundamental Rights & Personal Liberty
1978

Maneka Gandhi v. Union of India

AIR 1978 SC 597 · 7-judge bench

The Facts

The government impounded journalist Maneka Gandhi's passport "in the public interest" without giving her a reason or a hearing. She challenged this as a violation of her personal liberty.

The Holding

The Court held that the "procedure established by law" restricting personal liberty under Article 21 must itself be fair, just and reasonable — not just any procedure Parliament happens to enact. It also held that Articles 14 (equality), 19 (freedoms) and 21 (life and liberty) are interlinked, not watertight compartments — together known as the "Golden Triangle."

This single ruling transformed Article 21 from a narrow procedural guarantee into the foundation for almost every major personal-liberty right the Supreme Court has recognised since (privacy, dignity, livelihood, a clean environment, and more all trace back to this expanded reading).

Cross-References

Related law

Art. 21

The right to life and personal liberty this case fundamentally expanded