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In Maneka Gandhi v. Union of India, AIR 1978 SC 597, the Supreme Court held that:

Answer & Solution
Correct answer: D.
1. Maneka Gandhi overruled the narrow view in A. K. Gopalan (1950) and held that the rights in Articles 14, 19 and 21 are not water-tight compartments but form a 'golden triangle'. 2. The Court held that the 'procedure established by law' under Article 21 must be just, fair and reasonable — substantially importing American 'due process'. 3. The right to travel abroad was held to be part of personal liberty. 4. Hence option D captures the holding; the others are contrary to the judgment. _Source: Constitution of India (Bare Act, updated to 105th Amendment Act 2021), Govt. of India Legislative Dept., Maneka Gandhi v. Union of India, AIR 1978 SC 597_
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