Which one of the following statements with regard to Maneka Gandhi vs. Union of India case, 1978 is not correct?
It was held that Article 19 and Article 21 are not watertight compartments.
It was held that a law coming under Article 21 may not satisfy the requirements of Article 19.
A fair trial eliminates the biases against the accused in the trial.
The right to life under Article 21 does not include the right to die.
Answer is Right!
Answer is Wrong!
This question was previously asked in
UPSC CAPF – 2021
A) It was held that Article 19 and Article 21 are not watertight compartments: This is correct. The court held that the fundamental rights are not isolated but form an integrated scheme. Any law that restricts personal liberty under Article 21 must also satisfy the requirements of Article 19 (where applicable) and Article 14.
B) It was held that a law coming under Article 21 may not satisfy the requirements of Article 19: This is incorrect. The judgment precisely held the opposite. The ‘procedure established by law’ under Article 21 must be fair, just, and reasonable, and it must also pass the test of the freedoms guaranteed under Article 19 (like freedom of movement if a passport is impounded) and the equality principle under Article 14.
C) A fair trial eliminates the biases against the accused in the trial: While the case primarily dealt with passport impoundment, the broader impact of the judgment was to introduce the concept of procedural due process into Article 21. Fair trial is a core component of a just and reasonable procedure, aiming to eliminate biases. This statement reflects the spirit of the expanded interpretation of Article 21, although not the direct context of passport impoundment.
D) The right to life under Article 21 does not include the right to die: This is correct. The Supreme Court has consistently held that the right to life under Article 21 does not extend to the right to commit suicide or the right to die.
Since the question asks for the statement that is *not* correct, option B is the answer.
– It established the interconnectedness of Articles 14, 19, and 21.
– Procedure under Article 21 must be ‘fair, just, and reasonable’.
– A law under Article 21 must also satisfy the requirements of Article 19 and 14.