Meet Justice M. Patanjali Sastri and his Notable Judicial decisions

Justice Mandakolathur Patanjali Shastri (1889–1963) was the second Chief Justice of India, serving from November 7, 1951, to January 3, 1954. Born in Mandakolathur, Madras Presidency (now Tamil Nadu), he was the son of Pandit Krishna Sastri, a renowned Sanskrit scholar. Justice Shastri graduated from Madras University and began his legal career in 1914, quickly gaining a reputation for his expertise in tax law and civil matters. He was appointed as a judge of the Madras High Court in 1939, then to the Federal Court in 1947, and became Chief Justice following the untimely death of Justice H.J. Kania.

Judicial Career and Philosophy
Justice Shastri’s tenure as Chief Justice was marked by a deep commitment to constitutionalism, judicial independence, and the protection of fundamental rights. He authored 75 judgments and sat on 171 benches during his Supreme Court tenure. Known for his scholarly approach and impartiality, he played a crucial role in shaping the early jurisprudence of the Supreme Court of India.

Landmark Judgments
1. State of Madras v. Champakam Dorairajan (1951)
Perhaps the most influential judgment of Justice Shastri’s career, this case challenged the communal reservation system in educational institutions in Madras. The Supreme Court, with Justice Shastri presiding, struck down the Madras government’s order reserving seats based on caste, holding it violated Article 29(2) of the Constitution, which guarantees non-discrimination in state-run educational institutions. This judgment led to the First Amendment of the Indian Constitution, introducing “reasonable restrictions” to fundamental rights and paving the way for affirmative action policies.

2. A.K. Gopalan v. State of Madras (1950)
Justice Shastri played a key role in this foundational case on preventive detention. The Court upheld the constitutionality of the Preventive Detention Act, ruling that “procedure established by law” in Article 21 did not mean “due process of law” as in the U.S. Constitution. This interpretation, which treated each fundamental right as distinct, influenced Indian constitutional law for decades until it was later revisited.

3. Berubari Union Case (1952–53)
Justice Shastri presided over the early stages of the Berubari Union case, which clarified Parliament’s power to alter state boundaries. The judgment established that ceding Indian territory required a constitutional amendment, reinforcing the supremacy of the Constitution and the need for democratic procedures in territorial changes.

4. Romesh Thapar v. State of Madras (1950)
Although not the author, Justice Shastri was part of the bench that struck down pre-censorship of the press, affirming freedom of speech and expression as a cornerstone of Indian democracy. This judgment had a profound impact on press freedom and was instrumental in shaping the contours of Article 19(1)(a).

Legacy
Justice M. Patanjali Shastri is remembered as a legal luminary whose judgments laid the foundation for constitutional interpretation in India. His tenure saw the Supreme Court assert itself as a guardian of fundamental rights and judicial independence. He was also active in legal education and public service after his retirement, contributing to the development of legal institutions and scholarship.

His legacy endures in the principles of equality, rule of law, and constitutional supremacy that continue to guide the Indian judiciary today.