Maneka Gandhi v. Union of India
Expanded Article 21 to include the right to live with dignity; any procedure affecting personal liberty must be fair, just, and reasonable.
The background
The government impounded journalist Maneka Gandhi's passport 'in the public interest' without giving any reasons. She challenged the action as a violation of her fundamental rights to equality (Article 14), freedom (Article 19), and life and personal liberty (Article 21).
The decision
The Court held that the 'procedure established by law' under Article 21 cannot be arbitrary - it must be fair, just, and reasonable. It ruled that Articles 14, 19, and 21 are not water-tight compartments but an interconnected 'golden triangle', and that the right to life means far more than mere animal existence - it includes the right to live with dignity.
What it changed
This case transformed Article 21 from a narrow guarantee into the engine of almost every modern right in India. By reading due process into Indian law, it opened the door to later rights to privacy, livelihood, a clean environment, legal aid, and a speedy trial. Virtually every rights-expanding judgment since traces its logic back to Maneka Gandhi.