Maneka Gandhi v Union of India

Supreme Court of IndiaAIR 1978 SC 597

Bench: Beg CJ, Chandrachud J, Bhagwati J, Krishna Iyer J, Untwalia J, Fazl Ali J, Kailasam J (7-judge bench)

Article 21's "procedure established by law" must be just, fair, and reasonable — not any arbitrary procedure. The Court overruled A.K. Gopalan (1950) and held that Articles 14, 19, and 21 are not mutually exclusive but form a golden triangle. Any law depriving life or personal liberty must satisfy all three. The Court expanded Article 21 to include the right to go abroad.