Question:
Procedural and substantive fairness was read under Art 14,19 and 21 creating the doctrine of golden triangle by the Supreme Court in
Procedural and substantive fairness was read under Art 14,19 and 21 creating the doctrine of golden triangle by the Supreme Court in
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Any question asking about "just, fair, and reasonable procedure," the "interconnection of Articles 14, 19, and 21," or the "Golden Triangle" points to the Maneka Gandhi case.
Updated On: Jul 7, 2026
- Kesavananda Bharati v State of Kerala
- Maneka Gandhi v Union of India
- Minerva Mills v Union of India
- Francis Coralie v State of Maharashtra
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The Correct Option is B
Solution and Explanation
Step 1: Understanding the Question:
The question asks us to identify the landmark Supreme Court case that read procedural and substantive fairness into Articles 14, 19, and 21, thereby establishing the "Golden Triangle" doctrine.
Step 2: Key Concepts and Approach:
The "Golden Triangle" refers to the three most crucial fundamental rights in the Indian Constitution: Articles 14 (Equality), 19 (Freedom), and 21 (Life and Liberty).
We need to identify the judgment that established that these three articles are not mutually exclusive but are deeply interconnected.
Step 3: Detailed Explanation:
• The Pre-Maneka View: In A.K. Gopalan (1950), the Court held that Article 21 was a complete code in itself and was independent of Article 19. If a procedure was enacted by law, its reasonableness could not be tested under Article 19.
• Maneka Gandhi v. Union of India (1978): A 7-judge bench rejected this compartmentalized view. It held that any law depriving a person of personal liberty under Article 21 must also satisfy the tests of Article 14 (non-arbitrariness) and Article 19 (reasonableness).
• The Golden Triangle: The Court declared that Articles 14, 19, and 21 form a "Golden Triangle." A law must pass the tests of all three articles to be constitutional.
• Procedural and Substantive Fairness: By requiring that the procedure be "just, fair, and reasonable," the Court imported the American concept of procedural and substantive due process into Indian jurisprudence.
Step 4: Final Answer:
The doctrine of the Golden Triangle was established in Maneka Gandhi v. Union of India. Hence, Option B is correct.
The question asks us to identify the landmark Supreme Court case that read procedural and substantive fairness into Articles 14, 19, and 21, thereby establishing the "Golden Triangle" doctrine.
Step 2: Key Concepts and Approach:
The "Golden Triangle" refers to the three most crucial fundamental rights in the Indian Constitution: Articles 14 (Equality), 19 (Freedom), and 21 (Life and Liberty).
We need to identify the judgment that established that these three articles are not mutually exclusive but are deeply interconnected.
Step 3: Detailed Explanation:
• The Pre-Maneka View: In A.K. Gopalan (1950), the Court held that Article 21 was a complete code in itself and was independent of Article 19. If a procedure was enacted by law, its reasonableness could not be tested under Article 19.
• Maneka Gandhi v. Union of India (1978): A 7-judge bench rejected this compartmentalized view. It held that any law depriving a person of personal liberty under Article 21 must also satisfy the tests of Article 14 (non-arbitrariness) and Article 19 (reasonableness).
• The Golden Triangle: The Court declared that Articles 14, 19, and 21 form a "Golden Triangle." A law must pass the tests of all three articles to be constitutional.
• Procedural and Substantive Fairness: By requiring that the procedure be "just, fair, and reasonable," the Court imported the American concept of procedural and substantive due process into Indian jurisprudence.
Step 4: Final Answer:
The doctrine of the Golden Triangle was established in Maneka Gandhi v. Union of India. Hence, Option B is correct.
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