Which case overruled the proposition in A. K. Gopalan v. State of Madras, AIR 1950 SC 27 that Fundamental Rights are 'mutually exclusive' silos?
AR. C. Cooper v. Union of India, AIR 1970 SC 564, followed by Maneka Gandhi (1978) — golden triangle
BKesavananda Bharati v. State of Kerala, AIR 1973 SC 1461 — basic structure doctrine
CMinerva Mills v. Union of India, AIR 1980 SC 1789 — balance between FRs and DPSPs
DI. R. Coelho v. State of Tamil Nadu, (2007) 2 SCC 1 — Ninth Schedule judicial review
Answer & Solution
Correct answer: A. R. C. Cooper v. Union of India, AIR 1970 SC 564, followed by Maneka Gandhi (1978) — golden triangle
1. A. K. Gopalan (1950) treated the Fundamental Rights as separate, mutually exclusive provisions — each tested only against its own ground of restriction.
2. R. C. Cooper (Bank Nationalisation case, 1970) was the first decisive break, holding that a law could be tested against the cumulative impact of multiple Fundamental Rights.
3. Maneka Gandhi (1978) consolidated the new approach and read Articles 14, 19 and 21 together as a 'golden triangle'.
4. Kesavananda (basic structure) and Minerva Mills / Coelho (Ninth Schedule) addressed different issues.
_Source: Constitution of India (Bare Act, updated to 105th Amendment Act 2021), Govt. of India Legislative Dept., R.C. Cooper v. Union of India (1970); Maneka Gandhi v. Union of India (1978)_
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