Question

Which case placed judicial limits on Article 356?

Hint:

Whenever Article 356 appears in a question, the first case to cite is always \textbf{S.R. Bommai (1994)}. It is the constitutional checkpoint against the Centre’s misuse of President’s Rule.

Answer 1

The case that decisively placed judicial limits on the use of Article 356 (President’s Rule) is S.R. Bommai v. Union of India (1994). This judgment fundamentally reshaped India’s federal structure and the constitutional understanding of Centre–State relations.
Why is Bommai so important?

Before 1994, Article 356 was widely misused by the Union Government to dismiss State Governments on political grounds.
The Supreme Court held that the proclamation of President’s Rule is subject to judicial review.
The Court declared that the existence of “constitutional breakdown” must be objectively established, not merely asserted by the Centre.
Most importantly, the Court held that the majority of a State Government must be tested on the floor of the Assembly, not through the Governor’s subjective opinion.
Key Principles from Bommai:

Judicial review applies to Art. 356 proclamations.
President cannot use Art. 356 for malafide or extraneous political reasons.
Floor test is mandatory to verify loss of majority.
If the proclamation is struck down, the Court may restore the dismissed government.
Federalism is part of the basic structure.
Thus, S.R. Bommai marks the transition from political discretion to constitutional accountability in the use of Article 356.

Answer 2

Several cases touch Article 356 before 1994, so it helps to check why each of them fails to be the case that placed real judicial limits on its use, before confirming the one that did.

Candidate: State of Rajasthan v. Union of India (1977).
This case arose after the Centre dismissed several state governments following the Emergency, and it did discuss whether a presidential proclamation under Article 356 is justiciable. But the Court largely accepted the political nature of the satisfaction required under Article 356 and declined to lay down a workable test for judicial review, leaving the Centre's discretion practically intact. It raised the question of limits without answering it.

Candidate: the run of dismissals through the 1980s.
Throughout this period, Article 356 was invoked repeatedly on shifting political grounds, and courts mostly declined to interfere, treating the President's satisfaction as largely non justiciable. No binding, generally applicable test for reviewing Article 356 proclamations emerged from this run of cases, so none of them can be credited with placing the limits the question asks about.

The case that actually placed the limits: S.R. Bommai v. Union of India (1994).
Bommai did what the earlier cases did not: it held squarely that a proclamation under Article 356 is subject to judicial review, that the material behind a claim of constitutional breakdown must be objectively verifiable rather than a matter of pure political satisfaction, and that where the question is one of majority support in the Assembly, that majority must be tested on the floor of the House rather than assumed by the Governor. It further held that if a court strikes down a proclamation, the dismissed government can be restored, giving the limitation real teeth rather than a merely declaratory one. Federalism was also read into the basic structure, giving the ruling constitutional weight beyond ordinary statutory interpretation.

Confirming the survivor.
Unlike the 1977 case and the unreviewed dismissals of the 1980s, Bommai supplied a workable, judicially enforceable test and a remedy. That combination, review plus a real remedy, is what makes it the case that placed limits on Article 356, rather than merely discussing them.

Working backward through the candidates and eliminating the ones that raised the issue without resolving it isolates Bommai as the decisive case.

\[ \boxed{\text{S.R. Bommai v. Union of India (1994)}} \]