📚 Case Law Example: A.K. Gopalan v. State of Madras (1950)

Citation: AIR 1950 SC 27

Facts: The petitioner challenged his preventive detention under the Preventive Detention Act, 1950, arguing it violated his fundamental rights under Articles 19, 21, and 22.

Issue: Whether preventive detention violates fundamental rights, particularly the right to life and personal liberty under Article 21.

Held: The Supreme Court adopted a narrow, literal interpretation approach. It held that Article 21 only requires procedure "established by law" and did not read into it requirements of natural justice or due process. Each fundamental right was interpreted in isolation.

Significance: This case represents the literal interpretation approach, though it was later overruled in Maneka Gandhi case where the Court adopted a more expansive interpretation.

📚 Case Law Example: Kesavananda Bharati v. State of Kerala (1973)

Citation: AIR 1973 SC 1461

Facts: This landmark case involved a challenge to the 29th Amendment, questioning Parliament's power to amend fundamental rights and the Constitution.

Issue: Whether Parliament has unlimited power to amend the Constitution under Article 368.

Held: The Supreme Court propounded the "Basic Structure Doctrine," holding that while Parliament can amend the Constitution, it cannot alter its basic structure or essential features. The Court examined the intent of the framers and held that they did not intend to give unlimited amendment power.

Significance: The Court balanced originalism with the need to protect fundamental constitutional values. It looked at the original intent while establishing limits on amendment power.

📚 Case Law Example: Maneka Gandhi v. Union of India (1978)

Citation: AIR 1978 SC 597

Facts: Petitioner's passport was impounded without giving reasons. She challenged this action as violating her fundamental rights under Articles 14, 19, and 21.

Issue: Whether the right to travel abroad is part of personal liberty under Article 21, and whether "procedure established by law" includes principles of natural justice.

Held: The Supreme Court revolutionized constitutional interpretation by adopting an expansive, progressive approach. It held that:

• Article 21 is the heart of fundamental rights
• The procedure must be fair, just, and reasonable (not just legally valid)
• Fundamental rights are interconnected and must be read together
• Right to life includes right to livelihood, dignity, and other aspects

Significance: This case marked a shift from literal to progressive interpretation, making the Constitution a living document responsive to changing needs.

📚 Case Law Example: Justice K.S. Puttaswamy v. Union of India (2017)

Citation: (2017) 10 SCC 1

Facts: The case arose from challenges to the Aadhaar scheme and the mandatory linking of Aadhaar with various services.

Issue: Whether the right to privacy is a fundamental right under the Constitution.

Held: A 9-judge bench unanimously held that the right to privacy is a fundamental right under Article 21. The Court adopted a progressive interpretation approach, recognizing that:

• Privacy is intrinsic to life and personal liberty
• The digital age requires protection of informational privacy
• The Constitution must protect individual autonomy and dignity in modern times
• Technological advancements necessitate evolution of constitutional rights

Significance: This landmark judgment demonstrates the living constitution approach, recognizing new rights based on contemporary needs despite privacy not being explicitly mentioned in the Constitution.

📚 Case Law Example: Vishaka v. State of Rajasthan (1997)

Citation: AIR 1997 SC 3011

Facts: Social workers filed a PIL regarding sexual harassment of women at the workplace, highlighting the lack of specific legislation on the subject.

Issue: Whether constitutional provisions can be interpreted to provide protection against sexual harassment in the absence of specific legislation.

Held: The Supreme Court adopted a purposive interpretation approach and:

• Interpreted Article 14 (equality), Article 19(1)(g) (right to practice profession), and Article 21 (life and dignity) to include protection from sexual harassment
• Laid down detailed guidelines (Vishaka Guidelines) for prevention of sexual harassment
• Held that constitutional provisions must be interpreted to fulfill India's international obligations (CEDAW)
• Emphasized that the purpose of fundamental rights is to ensure dignity and equality

Significance: The Court filled a legislative vacuum by interpreting constitutional provisions purposively to protect women's rights and dignity, leading to the Sexual Harassment of Women at Workplace Act, 2013.

📚 Case Law Example: Minerva Mills v. Union of India (1980)

Citation: AIR 1980 SC 1789

Facts: Challenge to the validity of the 42nd Amendment which gave primacy to Directive Principles over Fundamental Rights under Article 31C.

Issue: Whether Directive Principles can be given supremacy over Fundamental Rights.

Held: The Supreme Court applied harmonious construction and held that:

• Fundamental Rights and Directive Principles are complementary, not contradictory
• Neither can be given absolute supremacy over the other
• Both are essential for achieving constitutional goals
• The balance between them is part of the basic structure

Significance: The case exemplifies how harmonious construction helps maintain constitutional balance and prevent one set of provisions from nullifying another.

📚 Case 1: Golak Nath v. State of Punjab (1967)

Citation: AIR 1967 SC 1643

Facts: The case involved challenge to amendments that curtailed property rights under Part III of the Constitution.

Issue: Whether Parliament has power to amend Fundamental Rights under Article 368.

Held: The Supreme Court held that:

• Fundamental Rights are transcendental and immutable
• Parliament cannot amend fundamental rights as they are given by the Constitution, not created by it
• The word "law" in Article 13 includes constitutional amendments
• This decision was prospective only

Significance: Though later overruled in Kesavananda Bharati, this case established that certain constitutional provisions have special sanctity and cannot be easily altered.

📚 Case 2: I.C. Golak Nath and Ors. v. State of Punjab (Interpretation of Article 13)

The Court's interpretation that "law" in Article 13 includes constitutional amendments showed a strict interpretation approach initially, later modified to balance amendment power with constitutional protection.

📚 Case 3: Indra Sawhney v. Union of India (1992)

Citation: AIR 1993 SC 477 (Mandal Commission Case)

Facts: Challenge to implementation of 27% reservation for Other Backward Classes (OBCs) in government jobs based on Mandal Commission recommendations.

Issue: Whether reservation for OBCs violates the basic structure of the Constitution, particularly the right to equality.

Held: The Supreme Court upheld reservation for OBCs but with important limitations:

• Total reservation should not exceed 50% (rule of thumb)
• Creamy layer among OBCs should be excluded
• Reservation cannot be made in promotions for OBCs
• Equality is part of basic structure, but affirmative action is permissible
• Backwardness should be identified primarily by social criteria, not just caste

Significance: The case balanced equality with social justice through purposive interpretation, showing how constitutional provisions can accommodate both competing values.

📚 Case 4: S.R. Bommai v. Union of India (1994)

Citation: AIR 1994 SC 1918

Facts: Challenge to the imposition of President's Rule in several states under Article 356.

Issue: Whether President's Rule imposed in various states was valid, and whether Article 356 is subject to judicial review.

Held: The Supreme Court held that:

• Presidential satisfaction under Article 356 is not beyond judicial review
• Secularism is part of the basic structure of the Constitution
• Federal structure is part of basic structure
• President's Rule can be challenged if it violates constitutional principles
• The Court can restore dismissed state governments if satisfied that Article 356 was misused

Significance: The judgment protected federalism and established that even executive actions must conform to constitutional values and are subject to judicial scrutiny.

📚 Case 5: Francis Coralie Mullin v. Administrator, UT of Delhi (1981)

Citation: AIR 1981 SC 746

Facts: A foreign national in detention challenged the conditions of her detention as violating Article 21.

Issue: What is the scope of "life" under Article 21?

Held: Justice Bhagwati held that:

• The right to life includes the right to live with human dignity
• It includes all aspects that make life meaningful, complete, and worth living
• Even prisoners and detenues have fundamental rights
• Procedure established by law must be reasonable, fair, and just

Significance: This case expanded Article 21 to include quality of life, not just existence, setting the foundation for numerous other rights to be read into Article 21.

📚 Case 6: Olga Tellis v. Bombay Municipal Corporation (1985)

Citation: AIR 1986 SC 180 (Pavement Dwellers Case)

Facts: Pavement dwellers in Mumbai challenged eviction notices without being given alternative accommodation.

Issue: Whether the right to livelihood is part of the right to life under Article 21.

Held: Justice Chandrachud held that:

• The right to life includes the right to livelihood
• No person can be deprived of livelihood without following fair and reasonable procedure
• Eviction of pavement dwellers affects their livelihood and thus Article 21
• The state must balance public interest with individual rights

Significance: This case linked survival and dignity, recognizing that right to life is meaningless without means of livelihood.

📚 Case 7: M.C. Mehta v. State of Tamil Nadu (1996)

Citation: AIR 1997 SC 699 (Child Labour Case)

Facts: PIL concerning employment of children in hazardous industries, particularly match factories and glass industries.

Issue: Whether child labour in hazardous industries violates fundamental rights.

Held: The Supreme Court held that:

• Right to education is fundamental to Article 21
• Child labour in hazardous industries violates Articles 21, 23, and 24
• The State must ensure rehabilitation and education of child workers
• Employers must pay compensation for employing child labour
• The Court gave detailed directions for elimination of child labour

Significance: The case demonstrated judicial activism and purposive interpretation to protect vulnerable sections of society.

📚 Case 8: M.C. Mehta v. Union of India (1987)

Citation: AIR 1987 SC 1086 (Oleum Gas Leak Case)

Facts: PIL filed after Oleum gas leak from Shriram Foods and Fertilizer Industries in Delhi.

Issue: Whether industries engaged in hazardous activities are absolutely liable for any harm caused.

Held: Justice Bhagwati evolved the principle of absolute liability:

• Industries engaged in hazardous activities owe absolute and non-delegable duty to ensure safety
• In case of accident, they are absolutely liable to compensate victims
• No exceptions like those in Rylands v. Fletcher apply
• Liability is strict and absolute to ensure environmental protection
• Right to clean environment is part of Article 21

Significance: The Court went beyond existing tort law principles to create a stricter liability regime, interpreting Article 21 to include environmental rights.

📚 Case 9: Subhash Kumar v. State of Bihar (1991)

Citation: AIR 1991 SC 420

Facts: PIL regarding water pollution from washeries discharging sludge into Bokaro river.

Issue: Whether right to pollution-free water is a fundamental right.

Held: The Supreme Court held that:

• Right to live in pollution-free environment is part of Article 21
• Right to access clean water is fundamental to right to life
• Citizens have right to approach courts for protection of environment
• State has duty to protect environment and natural resources

Significance: First case to explicitly recognize right to pollution-free environment as fundamental right under Article 21.

📚 Case 10: Navtej Singh Johar v. Union of India (2018)

Citation: (2018) 10 SCC 1 (Section 377 case)

Facts: Challenge to Section 377 IPC which criminalized consensual homosexual acts.

Issue: Whether Section 377 violates fundamental rights of LGBTQ+ individuals.

Held: The Supreme Court unanimously held that:

• Section 377, insofar as it criminalizes consensual sexual acts between adults, is unconstitutional
• Sexual orientation is protected under Article 14 (equality), Article 15 (non-discrimination), Article 19 (expression), and Article 21 (privacy, dignity)
• Constitutional morality must triumph over social morality
• The Constitution protects diversity and individual autonomy
• LGBTQ+ individuals have equal citizenship rights

Significance: This landmark judgment shows constitutional interpretation evolving to recognize marginalized identities, emphasizing dignity and autonomy over majoritarian morality.

📚 Case 11: Indian Young Lawyers Association v. State of Kerala (2018)

Citation: (2019) 11 SCC 1 (Sabarimala case)

Facts: Challenge to practice prohibiting women aged 10-50 from entering Sabarimala temple.

Issue: Whether the prohibition violates rights of women under Articles 14, 15, and 25.

Held: The majority (4:1) held that:

• The prohibition violates rights to equality and dignity of women
• Article 25 guarantees right to worship to all, including women
• Biological features cannot be grounds for discrimination
• Religious practices must conform to constitutional values
• Patriarchy cannot be given religious sanction

Note: The case was later referred to a larger bench for reconsideration.

Significance: The case reflects tension between religious freedom and gender equality, showing how constitutional interpretation must balance competing fundamental rights.