In MANEKA GANDHI v. UNION OF INDIA, AIR 1978 SC 597, the Supreme Court held that:
AArticles 14, 19 and 21 are INTERLINKED ('golden triangle'); the procedure established by law under Article 21 must be 'just, fair and reasonable', not arbitrary
BArticle 14, 19 and 21 are separate water-tight compartments (cf. Maneka Gandhi v. Union of India, AIR 1978 SC 597) (cf. Maneka Gandhi v. Union of India, AIR 1978 SC 597)
CArticle 21 protects only physical liberty (cf. Maneka Gandhi v. Union of India, AIR 1978 SC 597) (cf. Maneka Gandhi v. Union of India, AIR 1978 SC 597)
DArticle 21 cannot be invoked against the State (cf. Maneka Gandhi v. Union of India, AIR 1978 SC 597) (cf. Maneka Gandhi v. Union of India, AIR 1978 SC 597)
Answer & Solution
Correct answer: A. Articles 14, 19 and 21 are INTERLINKED ('golden triangle'); the procedure established by law under Article 21 must be 'just, fair and reasonable', not arbitrary
1. Maneka Gandhi (1978) overruled the AK Gopalan (1950) view that FRs are water-tight compartments.
2. The 7-Judge Bench held: Articles 14 (equality), 19 (freedoms), and 21 (life) are interlinked — the 'GOLDEN TRIANGLE'.
3. The procedure prescribed by law under Article 21 must be JUST, FAIR, AND REASONABLE — substantially importing American 'due process'.
4. The case dealt with the impounding of Maneka Gandhi's passport without giving her a hearing.
5. Right to travel abroad held to be part of personal liberty.
6. Hence option B is correct.
_Source: UDHR 1948 / ICCPR 1966 / ICESCR 1966 / CAT 1984 / CEDAW 1979 / CRC 1989 / PHRA 1993 / Constitution Part III — Maneka Gandhi v. Union of India, AIR 1978 SC 597_
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