Regarding the extent and bounds of the President’s authority under article 356 of the indian constitution, the state of rajasthan v uoi case from 1977 produced a significant ruling. In the event that the constitutional machinery fails, the President may establish president rule in a state under this article. The issue started when the national government threatened to impose president rule after the Congress party lost state elections. Rajasthan was one of the states that contested this threat.
state of rajasthan v uoi Case Facts
- The Janata Party decisively defeated the Congress Party in several states during the 1977 Lok Sabha elections.
- The central government was established as a result of the Janata Party’s win.
- Several states at the time had Congress Party governments in place that had not yet finished their terms in office.
- Central Home Minister Charan Singh advised state chief ministers in letters to dissolve state legislatures and run for re-election from the electorate.
- In accordance with article 131 of the indian constitution, the State of Rajasthan and other impacted states brought an initial lawsuit against the Union of India.
- The case asked the court to declare that the Central Home Minister’s instruction was unlawful and unconstitutional.
state of rajasthan v uoi Issues
- Whether the judiciary can examine the establishment of President rule in states?
Contentions by the Parties
Petitioner:
- Under Article 356, the President’s proclamation may only be dissolved with the support of both Houses of Parliament.
- Although a proclamation under Article 356 required the consent of both Houses of Parliament, the Article did not specifically state that consideration by either House was a prerequisite for the President to use Article 356(1)’s authority to dissolve State Legislative Assemblies.
- The argument that the action under Article 356 was not forbidden only because both Houses of Parliament did not approve it was made by citing Article 356(3).
- There was a claim that the Union Government’s threat to dissolve state legislatures was untrue.
- The plaintiffs alleged mala fides, contending that the intimidating use of authority was done so for an objective other than what the authority had been granted for.
Respondent:
- It is not subject to judicial review whether a circumstance existed that would have made an article 356 action appropriate.
- It is not possible to indirectly challenge the President’s non-justiciable final action by raising doubts about the procedure that may or may not produce the intended outcome.
- It was argued that the Plaintiffs had no cause of action because the Letter and the Law Minister’s Statement did not go beyond the parameters of Article 356.
- The Respondent contends that the mere allegation of facts does not support the behaviour that Article 356 forbids.
state of rajasthan v uoi Judgment
- The Supreme Court ruled that the seized proclamation would be legitimate and dismissed the lawsuit. The Court took the stance that, absent a violation of a constitutional requirement, it could not intervene with the Centre’s exercise of its authority under Article 356 only because it supported political and executive policy and expediency.
- It was underlined that until the use of article 356(5) of the indian constitution is determined to be “grossly perverse and unreasonable” to represent patent abuse of the law, the court cannot challenge the President’s satisfaction on any basis.
- The proclamation, the court concluded, is meant to serve as a safety net against a state’s constitutional machinery breaking down or to restore the damage caused by one. Furthermore, it was noted that the President’s satisfaction as defined under Article 356 is purely subjective and cannot be evaluated in light of any objective standards.
- The court is not authorized to assess the accuracy or sufficiency of the facts and circumstances. It was claimed that the government might take preventive or curative action under Article 356, therefore in this particular circumstance, it was not impossible that the State Government had lost the trust of the public.
- The most notable aspect of the ruling is the nearly unanimous statement by the justices that, notwithstanding the expansive authority granted by Article 356, if power was used dishonestly or for purposes that are illegal or unconstitutional, a presidential proclamation might be overturned.
- It was noted that article 356 requires the President’s “satisfaction” as a prerequisite to the use of power. It was decided that upholding democratic standards could not be justified as a mere pretext for the use of declaratory authority. As a result, the Home Minister’s letter was described as advisory rather than malicious.
- Concerning the issue of whether State government was included in the term “state” as defined in article 131(a) of the indian constitution, it was decided that a disagreement between the Central and State governments over a legal right fell fully within the purview of Article 131.
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