Top 10 Cases on Article 21
Top 10 Landmark Cases on Article 21 of the Indian Constitution
1. Maneka Gandhi v. Union of India (1978)
Significance: Expanded the scope of Article 21 beyond mere physical existence.
Facts: Maneka Gandhi’s passport was impounded without providing her a proper opportunity to be heard.
Judgment: The Supreme Court held that the right to life and personal liberty includes the right to live with dignity and all facets of life.
Principle: Procedure established by law must be just, fair, and reasonable — linking Article 21 with Article 14 (equality before law).
2. Kharak Singh v. State of UP (1962)
Significance: Early case defining the ambit of Article 21.
Facts: The case challenged domiciliary visits and surveillance by police.
Judgment: The Court held that personal liberty includes the right to privacy in one's home.
Principle: State intrusion into personal privacy is restricted under Article 21.
3. Olga Tellis v. Bombay Municipal Corporation (1985)
Significance: Recognized the right to livelihood as part of Article 21.
Facts: Slum dwellers were being evicted by the Bombay Municipal Corporation.
Judgment: The Supreme Court held that the right to life includes the right to livelihood because no person can live without livelihood.
Principle: Eviction without due process violates Article 21.
4. Hussainara Khatoon v. State of Bihar (1979)
Significance: Addressed the right to speedy trial under Article 21.
Facts: Many undertrial prisoners were languishing in jail for years.
Judgment: The Court held that a speedy trial is a fundamental part of the right to life and personal liberty.
Principle: Justice delayed is justice denied.
5. Sunil Batra v. Delhi Administration (1978)
Significance: Highlighted the right against cruel, inhuman, and degrading treatment.
Facts: Complaints about prisoner mistreatment.
Judgment: The Court ruled that prisoners retain fundamental rights under Article 21.
Principle: Even prisoners have right to life with dignity.
6. Francis Coralie Mullin v. Administrator, Delhi (1981)
Significance: Elaborated the content of right to life and personal liberty.
Facts: Petitioner was held in custody without proper facilities.
Judgment: The Court held that the right to life includes the right to live with human dignity and not mere animal existence.
Principle: Life includes all faculties—physical, mental, emotional.
7. D.K. Basu v. State of West Bengal (1997)
Significance: Laid down guidelines to prevent custodial torture and deaths.
Facts: Custodial deaths and torture complaints.
Judgment: The Court issued binding guidelines for police conduct to protect detainees' rights.
Principle: Protection against custodial torture is part of Article 21.
8. Shantisar Builders v. Narayan Khimalal Totame (1990)
Significance: Right to property under Article 21.
Facts: Compensation for land acquisition challenged.
Judgment: The Court ruled that deprivation of property without adequate compensation violates Article 21.
Principle: Deprivation of property must be just and fair.
9. Right to Privacy Judgment - Justice K.S. Puttaswamy v. Union of India (2017)
Significance: Right to privacy recognized as an intrinsic part of Article 21.
Facts: Challenge to Aadhaar project and surveillance concerns.
Judgment: The Supreme Court declared privacy as a fundamental right protected under Article 21.
Principle: Privacy is an essential aspect of life and personal liberty.
10. Navtej Singh Johar v. Union of India (2018)
Significance: Right to equality and personal liberty includes sexual orientation.
Facts: Challenge to criminalization of consensual homosexual acts (Section 377 IPC).
Judgment: Supreme Court decriminalized consensual same-sex relations, holding that discrimination violates Article 21.
Principle: Right to live with dignity includes sexual orientation.
Summary Table
| Case | Key Principle |
|---|---|
| Maneka Gandhi (1978) | Right to life includes dignity; procedure must be fair |
| Kharak Singh (1962) | Right to privacy within home |
| Olga Tellis (1985) | Right to livelihood is part of right to life |
| Hussainara Khatoon (1979) | Right to speedy trial |
| Sunil Batra (1978) | Prisoners’ right against cruel, inhuman treatment |
| Francis Coralie Mullin (1981) | Right to life = life with dignity |
| D.K. Basu (1997) | Guidelines against custodial torture |
| Shantisar Builders (1990) | Deprivation of property must be just & fair |
| K.S. Puttaswamy (2017) | Right to privacy as fundamental right |
| Navtej Singh Johar (2018) | Right to dignity includes sexual orientation |
Conclusion
Article 21 has evolved through judicial interpretation to encompass a wide range of rights essential for a meaningful life — from physical safety to privacy, livelihood, dignity, and equality. These landmark cases highlight the dynamic nature of constitutional rights in India.
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