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SR Bommai vs. Union of India case (1994)

Case Summary


The SR Bommai vs. Union of India case (1994) unfolded against the backdrop of political turmoil and constitutional crises in India. The case stemmed from the dismissal of the SR Bommai-led government in Karnataka in 1989 under Article 356 of the Indian Constitution, which allows for the imposition of President's Rule in states. SR Bommai, the Chief Minister of Karnataka, challenged the dismissal, alleging that it was politically motivated and violated the principles of federalism and democratic governance. The case raised crucial questions about the scope of executive power, the autonomy of state governments, and the balance of power between the Union and the States.


In a landmark judgment delivered on March 11, 1994, the Supreme Court of India pronounced its verdict in the SR Bommai case. The court held that the power of the President to dismiss a state government under Article 356 was not absolute and could only be exercised under specific circumstances, such as a breakdown of constitutional machinery in the state. The court laid down guidelines to prevent the arbitrary use of Article 356 and ensure that it was invoked only as a last resort when all other constitutional mechanisms had failed. Additionally, the judgment affirmed the principle of federalism and upheld the autonomy of state governments as essential pillars of Indian democracy.


The SR Bommai case had profound implications for Indian federalism and democratic governance. Firstly, it reaffirmed the principle of constitutionalism and the rule of law by placing limits on executive discretion and ensuring that the exercise of power was subject to judicial review. The judgment provided a safeguard against the misuse of Article 356 and strengthened the federal structure of the Indian Constitution by protecting the autonomy of state governments. Secondly, the case underscored the role of the judiciary as the guardian of the Constitution and the ultimate arbiter of constitutional disputes. By upholding the principles of federalism and democratic governance, the judgment contributed to the consolidation of India's democratic institutions and the preservation of the country's pluralistic ethos.

Cases Linked to SR Bommai vs. Union of India:

Rameshwar Prasad vs. Union of India (2006)

Kihoto Hollohan vs. Zachillhu and Others (1992)

State of Karnataka vs. Union of India (1977)

I. C. Golaknath and Ors. vs. State of Punjab (1967)

S. P. Gupta vs. Union of India (1981)

Waman Rao vs. Union of India (1981)