Maneka Gandhi (1978): Article 21 Revolution

Generated from prompt:

{"prompt":"Create a 6-slide PowerPoint presentation on 'Maneka Gandhi v. Union of India (1978): Expansion of Fundamental Rights'. The slides should be in English and cover: 1) Title, 2) Background, 3) Legal Issue, 4) Arguments, 5) Judgment, and 6) Significance (with a simple flowchart). The presentation should be clear, professional, and visually engaging, including a symbolic image of the Supreme Court of India and a flowchart showing case progress (Passport Impounded → Petition Filed → Legal Debate → Judgment → Expansion of Article 21)."}

6-slide overview of Maneka Gandhi v. Union of India case—passport impoundment background, Article 21 violation issue, arguments, judgment expanding rights to due process, and significance flowchart.

December 15, 20256 slides
Slide 1 of 6

Slide 1 - Maneka Gandhi v. Union of India (1978)

This title slide features the landmark case Maneka Gandhi v. Union of India (1978). It emphasizes the expansion of fundamental rights, spotlighting its significance for Article 21.

Expansion of Fundamental Rights

Landmark Case on Article 21

Speaker Notes
Include a symbolic image of the Supreme Court of India (e.g., building or scales of justice). Add [Your Name] | [Date] at the bottom footer.
Slide 1 - Maneka Gandhi v. Union of India (1978)
Slide 2 of 6

Slide 2 - Background

Maneka Gandhi's passport was impounded on July 25, 1977, without reasons or prior hearing under Section 10(3)(c) of the Passport Act, 1967. She challenged the action through a writ petition under Article 32.

Background

  • Passport impounded on July 25, 1977, without reasons.
  • Issued under Section 10(3)(c), Passport Act, 1967.
  • No prior hearing provided to Maneka Gandhi.
  • Challenged via Article 32 writ petition.
Slide 2 - Background
Slide 3 of 6

Slide 3 - Legal Issue

The slide poses the legal issue of whether impounding a passport without a hearing violates Article 21 of the Indian Constitution. It references the pre-A.K. Gopalan interpretation limiting Article 21 to "procedure established by law" and questions if executive action alone can restrict these rights.

Legal Issue

  • Does impounding passport without hearing violate Article 21?
  • Pre-A.K. Gopalan: Article 21 meant only 'procedure established by law'
  • Can executive action alone restrict Article 21 rights?
Slide 3 - Legal Issue
Slide 4 of 6

Slide 4 - Arguments

The slide "Arguments" outlines the Petitioner's claim that the impoundment procedure violates Articles 14, 19, and 21 of the Constitution by being unfair, unjust, or unreasonable. The Respondent counters that the Passports Act, 1967, authorizes executive impoundment as an administrative action, exempt from prior judicial hearings or natural justice principles.

Arguments

Petitioner's ArgumentsRespondent's Arguments
The impoundment procedure was not 'fair, just, or reasonable,' violating Articles 14 (equality), 19 (fundamental freedoms), and 21 (right to life and liberty) of the Constitution.Executive authority under the Passports Act, 1967, allows impoundment without prior judicial hearing, as it is an administrative executive action, not requiring natural justice principles.

Source: Maneka Gandhi v. Union of India (1978)

Slide 4 - Arguments
Slide 5 of 6

Slide 5 - Judgment

A 7-judge Supreme Court bench led by CJI Chandrachud ruled that Article 21 requires fair, reasonable procedures, interlinking it with Articles 14 and 19 while introducing due process of law. The judgment restored the passport and issued guidelines.

Judgment

  • 7-judge bench presided by CJI Chandrachud.
  • Article 21 demands fair, reasonable procedure.
  • Interlinks Articles 14, 19, and 21.
  • Introduces due process of law.
  • Passport restored; guidelines issued.

Source: Maneka Gandhi v. Union of India (1978)

Slide 5 - Judgment
Slide 6 of 6

Slide 6 - Significance

The slide depicts the workflow of the Maneka Gandhi passport case, starting with the government's impoundment without hearing, Maneka's Article 226 petition, and the court's debate on "procedure established by law" versus due process. It culminates in the Supreme Court's judgment mandating fair, just, and reasonable procedures, expanding Article 21 into the "Golden Triangle" with Articles 14 and 19.

Significance

{ "headers": [ "Phase", "Key Development" ], "rows": [ [ "Passport Impounded", "Government impounds passport without hearing" ], [ "Petition Filed", "Maneka files writ petition under Article 226" ], [ "Legal Debate", "Court debates 'procedure established by law' vs. due process" ], [ "Judgment", "SC holds procedure must be fair, just, reasonable" ], [ "Expansion of Article 21", "Art. 21 interlinked with Arts. 14 & 19 forming 'Golden Triangle'" ] ] }

Source: Maneka Gandhi v. Union of India (1978)

Speaker Notes
Transformed Indian jurisprudence: 'Golden triangle' of Arts 14,19,21; due process over mere procedure.
Slide 6 - Significance
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