Why Landmark Judgments Matter for TNPSC Group 1
TNPSC Group 1 tests landmark judgments in:
- Prelims: Direct questions — "Which case established Basic Structure?" or "Vishaka guidelines relate to?"
- Mains Paper II: Answer writing — "Examine the evolution of Right to Life under Article 21" requires citing Maneka Gandhi, Olga Tellis, Puttaswamy
- Interview: "What is your view on the Electoral Bonds judgment?" — examiners expect knowledge of recent cases
Part 1 — Constitutional Fundamentals
1. Kesavananda Bharati v. State of Kerala (1973)
Subject: Basic Structure of the Constitution Court: 13-judge Constitutional Bench (largest in SC history); 7:6 majority Article: Article 368 (Amendment power)
Facts: Swami Kesavananda Bharati challenged Kerala land reform laws. The broader question: Can Parliament amend any part of the Constitution including Fundamental Rights?
Held:
- Parliament CAN amend the Constitution under Art 368 — including Fundamental Rights
- BUT cannot alter the Basic Structure of the Constitution
- Basic Structure includes: Supremacy of Constitution, Democratic republic, Secularism, Separation of powers, Federalism, Judicial review, Fundamental Rights, Unity and integrity of India, Free and fair elections
Significance:
- Overruled Golak Nath (1967) which said FRs cannot be amended
- But imposed the Basic Structure limit — Parliament cannot destroy what makes India, India
- Most important constitutional judgment in Indian history
- Protected democracy itself — prevented Parliament from converting India into a dictatorship
Related: Minerva Mills v. Union of India (1980) — SC struck down 42nd Amendment clauses that tried to make Parliament supreme over courts; reaffirmed Basic Structure.
2. Golak Nath v. State of Punjab (1967)
Subject: Fundamental Rights vs. Parliamentary amendment power Court: 11-judge bench; 6:5 majority
Held: Parliament CANNOT amend Fundamental Rights (Part III) at all — they are beyond amendment.
Overruled by: Kesavananda Bharati (1973) — which allowed amendment but imposed Basic Structure limit.
3. Shankari Prasad v. Union of India (1951)
Subject: Whether constitutional amendments can abridge Fundamental Rights Held: Article 368 amendment power is separate from ordinary law; constitutional amendments can abridge FRs.
Note: This was the first case on amendability of FRs; later overruled by Golak Nath (1967), then restored partially by Kesavananda Bharati (1973).
4. Maneka Gandhi v. Union of India (1978)
Subject: Scope of Article 21 — Right to Life and Personal Liberty Article: Article 21
Facts: Government impounded Maneka Gandhi's passport without reasons.
Held:
- Article 21's "procedure established by law" must be just, fair, and reasonable — not arbitrary
- Articles 14 (equality), 19 (freedoms), and 21 (life and liberty) must be read together — they form a golden triangle
- Expanded "personal liberty" to include right to travel abroad
- Effectively imported "due process" into Article 21
Significance: Transformed Art 21 from narrow to expansive. Foundation for all rights subsequently read into Art 21 — privacy, health, livelihood, education, clean environment, legal aid.
5. A.K. Gopalan v. State of Madras (1950)
Subject: Scope of Article 21 (early interpretation) Held: Articles 19, 21, 22 are separate and independent; "procedure established by law" means any law passed by Parliament.
Overruled by: Maneka Gandhi (1978) — which read Arts 14, 19, 21 together and required procedure to be just and fair.
6. ADM Jabalpur v. Shiv Kant Shukla (1976)
"Habeas Corpus" case — Emergency judgment Subject: Fundamental Rights during Emergency Held (4:1 majority): During Emergency, no person can move court for habeas corpus — even Article 21 is suspended.
Dissent: Justice H.R. Khanna alone dissented — said Art 21 cannot be suspended; was subsequently superseded for promotion.
Overruled by: Puttaswamy (2017) — declared that right to life cannot be abridged even during emergency.
Significance: Called the "darkest hour" of the Supreme Court. Justice Khanna's dissent celebrated as a beacon of judicial independence.
Part 2 — Reservations & Equality
7. Indra Sawhney v. Union of India (1992)
"Mandal Commission Case" Subject: OBC reservations, 50% cap, creamy layer Court: 9-judge bench Article: Article 16(4)
Held:
- 27% OBC reservation in central services upheld
- 50% cap on total reservations (SC+ST+OBC) — can be exceeded only in extraordinary circumstances
- Creamy layer must be excluded from OBC reservation — advanced OBCs get no benefit
- Reservation in promotions not permitted (later allowed by 77th/85th amendments)
- Reservation only in initial appointment
- Separate MBC (Most Backward Class) quota within OBC is valid
Significance: Foundation of India's reservation law. Every reservation case since refers to this judgment.
8. State of Kerala v. N.M. Thomas (1976)
Subject: Reservation in promotions Held: Article 16(4) is not an exception to 16(1) — it is a facet of equality; reservations can be given in promotions.
9. M. Nagaraj v. Union of India (2006)
Subject: Reservation in promotions for SC/ST Held: Parliament CAN provide reservation in promotions for SC/ST — but state must show: 1. Backwardness of the class 2. Inadequacy of representation 3. Overall efficiency of administration is maintained
Related: Jarnail Singh v. Lachhmi Narain Gupta (2018) — Modified Nagaraj; "quantifiable data" on backwardness not required for SC/ST (as they are already presumed backward by Presidential lists).
10. Indra Sawhney II / Chebrolu Leela Prasad Rao v. State of AP (2020)
Subject: 100% reservation for ST teachers in Scheduled Areas Held: Even for tribal areas, reservations cannot exceed 50% ceiling — 100% reservation for one category is unconstitutional.
11. EWS Reservation Case — Janhit Abhiyan v. Union of India (2022)
Subject: 103rd Constitutional Amendment — 10% EWS reservation Court: 5-judge bench; 3:2 majority Held: EWS reservation (10% for economically weaker sections from general category) is constitutionally valid.
Minority view (2 judges): Violates Basic Structure by using economic criterion alone; also breaches 50% cap.
Part 3 — Federalism & Centre-State
12. S.R. Bommai v. Union of India (1994)
Subject: Misuse of Article 356 (President's Rule) Court: 9-judge bench
Held:
- Floor test must be conducted before dismissing a state government — majority must be proved on floor of assembly, not based on Governor's report
- President's Rule is subject to judicial review — courts can examine if it was justified
- Secularism is part of Basic Structure — state government that promotes communalism can be dismissed
- President cannot dissolve state assembly until Parliament approves President's Rule proclamation
Significance: Drastically curtailed misuse of Art 356. Before this, President's Rule was used 100+ times, often for political reasons. After Bommai, frequency dropped significantly.
13. State of West Bengal v. Union of India (1963)
Subject: Federal character of Indian Constitution Held: India is NOT a true federation — it is a Union of States with centralising features; Parliament's legislative power extends to state subjects in national interest.
14. State of Karnataka v. Union of India (1977)
Subject: Centre's power to issue directions to states Held: Commission of Inquiry Act can be applied to state matters; Centre can investigate state government acts.
Part 4 — Fundamental Rights & Personal Liberty
15. Vishaka v. State of Rajasthan (1997)
Subject: Sexual harassment at workplace Facts: Bhanwari Devi gang rape case in Rajasthan — prompted PIL asking for guidelines on workplace harassment.
Held:
- Sexual harassment at workplace violates Articles 14, 15, 19(1)(g), and 21
- SC laid down Vishaka Guidelines — mandatory for all workplaces until Parliament passes law
- Employer must constitute Complaints Committee; sensitise employees
Later: Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act 2013 — codified Vishaka guidelines; mandatory ICC (Internal Complaints Committee).
16. Justice K.S. Puttaswamy v. Union of India (2017)
Subject: Right to Privacy as Fundamental Right Court: 9-judge bench; unanimous
Held:
- Right to Privacy is a Fundamental Right under Article 21
- Privacy includes: informational privacy, bodily integrity, decisional autonomy
- Three-pronged test for restriction: legality, legitimate aim, proportionality
- Overruled ADM Jabalpur (1976)
Impact: DPDP Act 2023; basis for challenging Aadhaar mandatory linkages; marriage equality arguments; abortion rights.
17. Navtej Singh Johar v. Union of India (2018)
Subject: Section 377 IPC — criminalisation of consensual same-sex relations Court: 5-judge bench; unanimous
Held:
- Section 377 IPC is unconstitutional to the extent it criminalises consensual sexual acts between adults
- Relied on Puttaswamy (privacy), Maneka Gandhi (dignity)
- LGBTQ+ persons have equal fundamental rights
18. Olga Tellis v. Bombay Municipal Corporation (1985)
Subject: Right to livelihood as part of Article 21 Facts: Pavement dwellers in Mumbai challenged eviction.
Held: Right to livelihood is part of Right to Life (Art 21) — state cannot deprive people of livelihood without just and fair procedure.
19. Unni Krishnan v. State of Andhra Pradesh (1993)
Subject: Right to education as fundamental right Held: Right to education (up to age 14) flows from Article 21 — right to life.
Impact: Led to 86th Amendment (2002) and Article 21A — making education an explicit FR.
20. PUCL v. Union of India (1997)
Subject: Right to food, telephone tapping Multiple cases by PUCL:
- Phone tapping case: Telephone tapping violates Art 19(1)(a) and 21; must follow strict procedure
- Right to food case (2001 onwards): Right to food is part of Art 21; SC directed states to implement food schemes; led eventually to NFSA 2013
21. Common Cause v. Union of India (2018)
Subject: Right to die with dignity Held: Right to die with dignity is part of Art 21 — passive euthanasia (withdrawal of treatment) and living will (advance directive) are legal under strict safeguards.
Part 5 — Women's Rights & Social Justice
22. Shayara Bano v. Union of India (2017)
"Triple Talaq case" Subject: Instant Triple Talaq (Talaq-e-biddat) among Muslims Court: 5-judge bench; 3:2 majority
Held: Instant Triple Talaq is unconstitutional — violates Articles 14 (equality) and 21 (dignity).
Impact: Muslim Women (Protection of Rights on Marriage) Act 2019 — criminalised triple talaq; 3 years imprisonment.
23. Indian Young Lawyers Association v. State of Kerala (2018)
"Sabarimala case" Subject: Ban on women aged 10–50 entering Sabarimala temple Court: 5-judge bench; 4:1 majority
Held: Exclusion of women based on age (menstruation) is unconstitutional — violates Articles 14, 15, 17, 25.
Dissent: Justice Indu Malhotra — essential religious practices deserve protection; courts should not interfere in matters of faith.
24. Joseph Shine v. Union of India (2018)
Subject: Section 497 IPC — Adultery law Held: Section 497 (which only punished men for adultery, treated women as property) is unconstitutional — violates Articles 14 and 21 (dignity of women).
25. Chairman, Railway Board v. Chandrima Das (2000)
Subject: Compensation for rape of Bangladeshi national Held: Right to life (Art 21) applies to all persons — including foreigners — not just citizens.
Part 6 — Environment & Public Interest
26. M.C. Mehta v. Union of India (Multiple Cases)
India's most prolific environmental litigant. Key Mehta cases:
| Case | Year | Subject | Held |
|---|---|---|---|
| Oleum Gas Leak | 1987 | Absolute Liability | Industries using hazardous substances have ABSOLUTE liability — no exceptions (stricter than strict liability) |
| Ganga Pollution | 1988 | Right to clean environment | Art 21 includes right to clean environment; tanneries ordered to close |
| Taj Trapezium | 1996 | Pollution near Taj Mahal | Industries near Taj ordered to shift to CNG or relocate |
| Delhi Vehicular Pollution | 1998 | CNG for buses | SC directed Delhi buses to convert to CNG |
27. Vellore Citizens' Welfare Forum v. Union of India (1996)
Subject: Pollution by tanneries in Tamil Nadu (River Palar, North Arcot) Held:
- Precautionary Principle and Polluter Pays Principle are part of Indian law
- Tanneries ordered to pay compensation; Green Benches of High Courts constituted
- Environment Protection Fund established
TN significance: This case directly concerns Tamil Nadu — North Arcot tanneries polluting Palar river.
28. Indian Council for Enviro-Legal Action v. Union of India (1996)
"Bichhri Village Case" (Rajasthan) Held: Absolute liability for industries causing pollution; industries must pay for clean-up; "polluter pays" principle.
Part 7 — Election Law & Democracy
29. S. Subramaniam Balaji v. State of Tamil Nadu (2013)
Subject: Election freebies (free TV, grinders, mixers promised by parties) Held: Election promises/manifesto items are not "corrupt practice" under Representation of People Act — not a ground for disqualification. SC expressed concern but declined to interfere.
Contrast: Supreme Court recently took up freebie issue again (2022 writ petition pending).
30. PUCL v. Union of India (2013)
"NOTA case" Subject: Right of voters to reject all candidates Held: Voters have right to express disapproval of all candidates — directed ECI to provide NOTA (None of the Above) option on EVMs.
31. Association for Democratic Reforms v. Union of India (2002)
Subject: Voters' right to know candidates' criminal, financial background Held: Voters have fundamental right to know antecedents of candidates — SC directed candidates to disclose criminal cases, assets, educational qualifications in affidavits.
Impact: Now mandated by Form 26 (candidate affidavit) before every election.
32. Electoral Bonds Case — Association for Democratic Reforms v. Union of India (2024)
Subject: Electoral Bonds Scheme Court: 5-judge Constitutional Bench; unanimous Decided: February 15, 2024
Held:
- Electoral Bonds Scheme is unconstitutional — violates Article 19(1)(a) (right to information)
- Voters have a fundamental right to know who funds political parties
- SBI directed to stop issuing bonds; disclose all bond purchase and redemption data to ECI
- ECI published data on SBI's disclosure
Part 8 — Recent Important Judgments
33. Article 370 — In Re: Article 370 of the Constitution (2023)
Subject: Validity of abrogation of Article 370 Court: 5-judge Constitutional Bench; unanimous Decided: December 11, 2023
Held:
- Article 370 was a temporary provision — Parliament had authority to abrogate it
- Abrogation via Presidential Order was valid
- J&K's downgrade to UT (with legislature) is valid; Ladakh UT (without legislature) is valid
- SC directed free and fair elections in J&K by September 30, 2024
(Elections held October 2024; NC-Congress coalition won; Omar Abdullah became CM)
34. Maratha Reservation — Jaishri Laxmanrao Patil v. Chief Minister, Maharashtra (2021)
Subject: 16% Maratha reservation (SEBC Act) Court: 5-judge bench; unanimous Held: Maratha reservation exceeds 50% cap; no exceptional circumstances exist; SEBC Act struck down. Reaffirmed 50% cap from Indra Sawhney (1992).
35. Same-Sex Marriage — Supriyo @ Supriya Chakraborty v. Union of India (2023)
Subject: Right of same-sex couples to marry Court: 5-judge bench; unanimous on the outcome Held:
- No fundamental right to marry exists in the Constitution
- Same-sex couples do NOT have a constitutional right to marry
- Parliament (not courts) must decide whether to extend marriage rights to same-sex couples
- LGBTQ+ individuals have right to live freely (Navtej Johar stands), but marriage is a legislative question
Quick Reference Table — Most Tested Cases
| Case | Year | Subject | Key Holding |
|---|---|---|---|
| Kesavananda Bharati | 1973 | Basic Structure | Parliament cannot destroy Basic Structure |
| Golak Nath | 1967 | FR amendment | FRs cannot be amended (overruled 1973) |
| Maneka Gandhi | 1978 | Art 21 scope | Procedure must be just, fair, reasonable; golden triangle |
| ADM Jabalpur | 1976 | Emergency + FR | FRs suspended during Emergency (later overruled) |
| Indra Sawhney | 1992 | OBC reservation | 27% OBC upheld; 50% cap; creamy layer |
| S.R. Bommai | 1994 | Art 356 misuse | Floor test mandatory; judicial review of President's Rule |
| Vishaka | 1997 | Workplace harassment | Vishaka guidelines; now replaced by 2013 Act |
| Olga Tellis | 1985 | Right to livelihood | Livelihood = part of Art 21 |
| MC Mehta (Oleum) | 1987 | Absolute liability | Hazardous industries have absolute liability |
| Vellore Citizens | 1996 | TN tanneries/Palar | Precautionary + Polluter Pays principles |
| Puttaswamy | 2017 | Right to Privacy | Privacy = FR under Art 21; overruled ADM Jabalpur |
| Navtej Johar | 2018 | Section 377 | Consensual same-sex acts decriminalised |
| Shayara Bano | 2017 | Triple Talaq | Instant triple talaq unconstitutional |
| Sabarimala | 2018 | Women entry to temples | Exclusion based on menstruation unconstitutional |
| NOTA case | 2013 | Right to reject | NOTA option directed to ECI |
| Electoral Bonds | 2024 | Political funding | Electoral Bonds unconstitutional; violates Art 19(1)(a) |
| Art 370 case | 2023 | J&K special status | Abrogation valid; elections directed |
Board Exam Tips — Landmark Judgments
- Basic Structure = Kesavananda Bharati 1973 (13-judge bench; 7:6); includes secularism, FR, judicial review
- Maneka Gandhi 1978 = Art 21 must be just+fair; Arts 14+19+21 = golden triangle
- ADM Jabalpur 1976 = darkest hour of SC; overruled by Puttaswamy 2017
- Indra Sawhney 1992 = 9-judge bench; 50% cap; creamy layer; no reservation in promotions (later amended)
- S.R. Bommai 1994 = floor test before dismissing state govt; Art 356 subject to judicial review
- Vishaka 1997 = workplace harassment guidelines; replaced by POSH Act 2013
- Puttaswamy 2017 = Privacy = FR under Art 21; 9-judge unanimous
- Electoral Bonds = struck down February 15, 2024; 5-judge unanimous; violates Art 19(1)(a)
- Art 370 case = December 11, 2023; 5-judge; abrogation upheld
- Vellore Citizens 1996 = Tamil Nadu case (Palar river + tanneries); Polluter Pays principle
- Navtej Johar 2018 = Section 377 IPC partially struck down; consensual acts between adults decriminalised