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Maneka Gandhi v. Union of India (1978)

Case Summary


The case of Maneka Gandhi v. Union of India (1978) is a landmark legal proceeding that deals with the fundamental right to personal liberty and the right to travel abroad under the Indian Constitution. Maneka Gandhi, an Indian citizen, had her passport impounded by the government without providing her with an opportunity to be heard. She challenged this action as a violation of her fundamental rights guaranteed under Articles 14, 19, and 21 of the Constitution.


In its judgment delivered in 1978, the Supreme Court of India held that the right to travel abroad was encompassed within the broader right to personal liberty guaranteed under Article 21 of the Constitution. The court ruled that any restriction on the right to travel must adhere to the principles of natural justice, including the right to be heard and the right to a fair procedure. The judgment emphasized that personal liberty could not be curtailed arbitrarily or without due process of law. Additionally, the court adopted a broad and expansive interpretation of fundamental rights, recognizing their intrinsic value and importance in a democratic society.


The judgment in Maneka Gandhi v. Union of India had profound implications for constitutional law and the protection of individual rights in India. It established the principle that fundamental rights must be interpreted in a holistic manner, taking into account their interrelationship and overarching purpose. The decision reaffirmed the judiciary's role as the guardian of constitutional liberties and underscored the importance of procedural fairness in administrative actions. Furthermore, the case expanded the scope of Article 21 beyond mere physical liberty to encompass various aspects of personal freedom, including the right to travel, privacy, and dignity.

List of Linked Cases:

Kharak Singh v. State of Uttar Pradesh (1963)

A.K. Gopalan v. State of Madras (1950)

Menaka Gandhi v. Union of India (1978)

Maneka Gandhi v. Union of India (1978)

Sunil Batra v. Delhi Administration (1980)

Olga Tellis v. Bombay Municipal Corporation (1985)