The Prime triangle of the constitution of India is the linkage between three
most important Articles of the Constitution namely 14,19 and 21.The development
opened an immense possibility. Justice Bhagwati made an eye opening verdict
which interconnected Articles 14, 19 and 21
Article 14, 19 and 21
Article 14 Equality before law:
The State shall not deny to any person equality
before the law or the equal protection of the laws within the territory of
Protection of certain rights regarding freedom of speech, etc.
Reasonable Restrictions from 19(2)-(6)Article
21 Protection of life and personal liberty – No person shall be deprived of
his life or personal liberty except according to procedure established by law.
can be classified into two eras, period before and after the
development of the judgement. The development of the Golden Triangle
made in the case of Maneka Gandhi .v. Union of India.
- Before the Judgement
During this period the jurist took the literal meaning of Art. 21
Case: A.K Gopalan .v. State of Madras (1950 AIR 27, 1950 SCR 88)
It is one of the important judgements as the apex court took more than one
articles at the same time to compare and give the verdict. The court took the
literal meaning of Article 21. Nearly after 30 years the view of the court was
A.K Gopalan was a communist leader. He was detained in jail under 'Prevention of
Detention Act'. He moved with a writ petition under Article 32(1) and challenged
his detention for violation of Article 21. The apex court by taking the literal
meaning of Art. 21 held that the protection under the Article is only available
to a person who is free and not in jail. The court gave importance to Art. 19
rather than Art. 21.
- After the Judgement
The judgement made development with respect to the fundamental rights guaranteed
under the constitution. The judgement was a transformation which gave ensured
the personal liberty.
Case: Maneka Gandhi .v. Union of India (1978 SC 597)
Passport Authority of India asked Maneka Gandhi to surrender her passport under
s. 10(3)(c) of Passport Act, 1967. She was not given the right to be heard she
filed a writ petition under Art. 32 and challenged the decision of the passport
authority to be violative of Art. 21.Justice Bhagwati held that Art. 14, 19 and
21 are not exclusive of each other and the three are interconnected to form
a Golden Triangle
. The procedure established by law in Art. 21 should be fair,
just and reasonable and should not be arbitrary or oppressive in nature and it
should fulfil Art. 19 and not be violative of Equality before law in Art. 14.
The decision of the apex court made an eye opening development, earlier in the
case of A.K Gopalan .v. State of Madras
, the court held the view that
the personal liberty and right to life is subjected to procedure established by
law. The view has been changed in the case of Maneka Gandhi .v. Union of
. The decision made an interconnection between three articles which
opened a new view. The essence of law is with the right way of interpretation
which opens immense number of possibility.