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Maneka Gandhi v. Union of India

Supreme Court of India · 25 January 1978 · 7-judge bench · (1978) 1 SCC 248

Constitutional LawFundamental Rights

Supreme Court held passport impoundment without reasons violates Article 21 and that procedure under Art. 21 must satisfy Articles 14, 19 and 21 read together.

Ratio Decidendi

Articles 14, 19 and 21 of the Constitution are not mutually exclusive but form an integrated scheme. Any law or procedure depriving a person of personal liberty under Article 21 must also satisfy the requirements of Article 14 (non-arbitrariness) and Article 19 (reasonable restriction of freedoms). A procedure that is arbitrary, unfair or unreasonable does not qualify as 'procedure established by law' within Article 21.

Pg 78
Article 21 requires that the procedure must be right and just and fair and not arbitrary, fanciful or oppressive; otherwise it would be no procedure at all and the requirement of Article 21 would not be satisfied.

Arguments

Petitioner / Appellant

The right to travel abroad is a component of personal liberty protected under Article 21 and cannot be curtailed without procedure that is fair, just, and reasonable.

Satwant Singh Sawhney v. D. Ramarathnam (1967)
Pg 18
The right of a citizen to go abroad is a fundamental right falling within the meaning of the expression 'personal liberty' in Article 21.

The denial of reasons for impoundment violates the audi alteram partem principle, a basic requirement of natural justice that must be read into any statute.

Ridge v. Baldwin [1964] AC 40 (HL)
Pg 22
The principle of audi alteram partem is so deeply embedded in our jurisprudence that it must be imported into every proceeding affecting the rights of a citizen even where the statute is silent.

Respondent / State

Section 10(3)(c) of the Passports Act expressly empowers the Passport Authority to impound a passport 'in the interests of sovereignty and integrity of India' and no further procedure is mandated.

Pg 45
The statute itself is the procedure. Once Parliament has prescribed the grounds for impoundment, there is no additional procedural requirement to be implied.

A.K. Gopalan correctly holds that Articles 14, 19 and 21 are independent guarantees; Art. 21 is satisfied once there is a law authorising the procedure regardless of its content.

A.K. Gopalan v. State of Madras AIR 1950 SC 27
Pg 48
Article 21 says 'procedure established by law' not 'procedure that is just, fair and reasonable'. The legislature is the judge of the reasonableness of the law.
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Legal Issues

Whether the right to travel abroad is a part of 'p…Whether the procedure established by law under Art…Whether the impoundment of passport under s.10(3)(…

These are real extractions from your actual system. Not curated examples.

The extraction schema

16 key legal fields. Extracted from every judgment.

Not summaries. Not guesses. Structured legal insights — fully grounded in the original text and ready for litigation.

One-line summary
≤25 words. Who won and why.
Brief summary
3-sentence narrative for quick context.
Detailed summary
Full 10-sentence analysis.
Procedural history
Every court this case passed through.
Material facts
Only facts that changed the outcome.
Legal issues
Each issue typed and decided.
Petitioner arguments
Every argument, with supporting precedents.
Respondent arguments
Every argument, with supporting precedents.
Amicus curiae
Arguments of court-appointed friends.
Court's reasoning
The logical chain, step by step.
Ratio decidendi
The binding rule. Pinned to the paragraph.
Obiter dicta
Persuasive observations, significance-rated.
Dissenting opinions
Which judge disagreed and exactly why.
Holding
The outcome and the specific order.
Precedents cited
Treatment: followed / distinguished / overruled.
Statutes cited
Each provision + how the court interpreted it.

Source-pinned, not summarised

Every field links back to the exact page in the judgment. Not an AI guess — an extraction with an address.

Built for the way lawyers actually work

You don't read a judgment top to bottom. You jump to the ratio, check what the other side argued, look for distinguishing facts. The schema matches that workflow.

Dissents matter. We extract them.

No other platform in India automatically extracts dissenting and concurring opinions as structured fields. In a 7:6 split decision, the minority is half the judgment.

What changes for you

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State of Punjab v. Baldev SinghDismissed
Arnab Goswami v. Union of IndiaAllowed
K.S. Puttaswamy v. UOIAllowed
Both sides' arguments — mapped

Know what they'll argue before they say it

Every argument the other side has made in similar cases, structured by party, with the cases they cited for each argument and the page number where the court addressed it.

Petitioner
Fundamental right violated
Maneka Gandhi
Art. 21 applies
Maneka Gandhi
Respondent
State interest prevails
A.K. Gopalan
Procedure followed
A.K. Gopalan
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Every extracted principle shows the exact paragraph it came from. One click copies the citation-ready text: case name, citation, paragraph reference. No more manual hunting.

Ratio Decidendi

Right to privacy is a fundamental right under Article 21 of the Constitution of India.

Para 83 · K.S. Puttaswamy (2017) 10 SCC 1

How we compare

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FeatureCaseIntelSCC Online AI ProManupatra FILACCaseMine AMICUS
Upload any judgment (source-agnostic)YesNoNoNo
Ratio decidendi — extracted and pinned to paragraphYesPartialPartialPartial
Petitioner vs respondent arguments — separatedYesNoPartialPartial
Dissenting opinions — structured extractionYesNoNoNo
Amicus curiae identificationYesNoNoNo
Procedural historyYesNoPartialNo
Source paragraph pinning on every fieldYesNoNoNo
One-line triage summaryYesNoNoNo
Confidence scoring on extractionsYesNoNoNo
Works on District Court judgmentsYesNoNoPartial

Source: public product documentation and direct platform testing, April 2026.

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summary levels — one-line to detailed
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source-pinned — every claim cited

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