In India, the indira gandhi vs raj narain case was a historic court case with significant political ramifications. The case concerned the 1971 Indian general election, in which Indira Gandhi, the prime minister at the time, ran from the Uttar Pradesh constituency of Raebareli. In an election appeal against Indira Gandhi, another candidate running in the same constituency, Raj Narain accused her of a number of electoral transgressions, including utilizing official resources for political ends and spending more money on campaigns than was allowed. Ultimately, the matter came before the Allahabad High Court, which decided in Raj Narain’s favor, annulling Indira Gandhi’s election victory and barring her from taking public office for a term of six years.
indira gandhi vs raj narain Case Facts
- Following the ruling by the Allahabad High Court that indira gandhi’s election was invalid due to corrupt activities, Gandhi filed an appeal. Since the Supreme Court had been on vacation at the time, she was granted a conditional stay.
- An emergency was then proclaimed as a result of an internal disturbance. While this was going on, Indira Gandhi approved the 39th constitutional amendment, adding article 392a to the indian constitution.
- Article 392A declared that the only forum for contesting the Speaker’s and Prime Minister’s election is before a committee established by the Parliament itself, not in any court of law.
- Preventing the Supreme Court from rendering a decision in Indira Gandhi’s case. As a result, there was debate over the 39th Amendment’s constitutionality.
indira gandhi vs raj narain Issues
- Is article 392a to the indian constitution Clause (4) Valid?
- Are the Election Laws (Amendment) Act of 1975 and the Representation of People’s (Amendment) Act of 1974 constitutionally valid?
- Is the indira gandhi’s election legitimate or invalid?
Contentions by the Parties
Petitioner:
- The petitioners argued that it is not appropriate to use the Kesvananda Bharti judgment’s majority ruling as a guide to determine whether the elections would be fair and free.
- They claimed that although the constitutions of other nations delegate election issues to their legislatures, our own contains a number of articles that demonstrate the exclusion of judicial review as a matter of principle in specific circumstances.
- Returning to the historic case, they discussed how Kesvananda Bharti and Shankari Prasad addressed the definition of “amendment” rather than the scope of electoral conflicts.
- Finally, they contended that the rule of law is not a component of the fundamental structure and that neither the equality theory nor the rule of law is recognized by our Constitution outside of Article 14.
Respondent:
- The petitioner’s primary point of contention was that the 39th constitutional amendment unfairly stripped the judiciary of its jurisdiction over election petitions and altered the “basic structure of the Constitution.”
- They made the argument that the Legislature’s role is to enact laws and that it has the authority to do so. Nonetheless, the judiciary has the authority to determine whether a statute is constitutional.
- Article 14 guarantees equality before the law and equal protection under it. When the President enacted such a statute, he unjustly elevated himself and other individuals above the law. As declared in the Fundamental Rights Case, the rule of law and judicial review are essential components of the constitution and cannot be changed.
- When the majority of MPs in the house were unable to vote either in favor of or against the amendment, it was passed. Finally, Article 368 does not provide Parliament the authority to change the Constitution in order to determine the outcome of an election.
indira gandhi vs raj narain Judgment
- The ruling was rendered by the constitutional bench on November 7, 1975. The supreme court backed Raj Narain’s argument and ruled that Article 329A’s contested clause 4 was invalid.
- According to Mathew J., Article 329A (4) damaged the fundamental framework of the Constitution, which called for resolving an electoral dispute by determining the appropriate laws and adjudicative facts.
- According to him, the possibility of free and fair elections is necessary for a healthy democracy to function. The challenged amendment, in his view, eliminated that opportunity and breached the fundamental provisions of the Constitution.
- According to Chandrachud J., the 39th constitutional amendment intentionally gave the legislative control over a solely judicial role, infringing on the concept of the separation of powers. Furthermore, he was positive that the aforementioned modification violated Article 14 since it pitted some members against others.
- Justice Khanna concluded that the amendment had broken the standards of free and fair elections, while Ray C.J. ruled that the change had undermined the rule of law, another fundamental component.
- The bench further determined that the aforementioned amendment was unconstitutional because it deprives the person contesting the election of the members it mentions of a fair trial, in violation of the audi altrem partem natural justice principle.
- One fundamental aspect of the Indian Constitution is democracy. The legislature lacks the authority to enact a bill retroactively recognizing a void election. This activity is nothing more than a manifestation of the tyrannical abuse of absolute authority.
- Thus, for a number of reasons, the court declared the 39th (Amendment) Act, 1975 invalid and in violation of the fundamental provisions of the Constitution. Additionally, the Supreme Court overturned the verdict of the Allahabad High Court, clearing Indira Gandhi of all corruption-related accusations and restoring the legitimacy of her election.
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