Relationship between constitutional rights and administrative discretion

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

In this landmark case, the Supreme Court expanded the interpretation of Article 21, emphasizing that the right to life and personal liberty cannot be curtailed except according to a procedure established by law. The Court held that any law or executive action that deprives a person of their liberty must be just, fair, and reasonable. This case underscored the necessity for administrative actions to adhere to constitutional principles, ensuring that discretionary powers are not exercised arbitrarily.

2. S. R. Bommai v. Union of India (1994)

This case addressed the misuse of Article 356 (President's Rule) and its impact on federal governance. The Supreme Court held that the imposition of President's Rule is subject to judicial review and cannot be based solely on the discretion of the executive. The Court emphasized that such discretion must be exercised in good faith and in accordance with constitutional provisions, safeguarding the democratic structure of the nation.

3. Kesavananda Bharati v. State of Kerala (1973)

In this seminal judgment, the Supreme Court propounded the "Basic Structure Doctrine," asserting that certain fundamental features of the Constitution cannot be altered by the Parliament. The Court emphasized that any exercise of power, including administrative discretion, must respect the core principles of the Constitution, ensuring that fundamental rights are not undermined.

4. Indira Gandhi v. Raj Narain (1975)

This case examined the validity of the 39th Amendment, which sought to immunize the election of the Prime Minister from judicial scrutiny. The Supreme Court struck down the amendment, holding that it violated the basic structure of the Constitution. The Court reaffirmed that administrative actions, even those at the highest level, are subject to constitutional limitations, ensuring the protection of fundamental rights.

5. ADM Jabalpur v. Shivkant Shukla (1976)

During the Emergency, this case dealt with the suspension of habeas corpus petitions. The Supreme Court controversially held that during an emergency, the right to move a court for the enforcement of fundamental rights could be suspended. However, this judgment was later overruled, reaffirming that administrative discretion must always be exercised in a manner consistent with constitutional safeguards.

Conclusion

The interplay between constitutional rights and administrative discretion is pivotal in maintaining the rule of law. While administrative authorities are vested with discretion to implement policies and make decisions, such discretion must be exercised within the boundaries set by the Constitution. Judicial review acts as a safeguard, ensuring that administrative actions do not infringe upon fundamental rights and adhere to constitutional principles.

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