1. What is the State of Rajasthan vs. Union of India Case all about?
The State of Rajasthan vs. Union of India case in 1977 was a landmark judgement dealing with the scope and limits of the President’s power under Article 356 of the Indian Constitution. This article allows the President to impose President’s Rule in a state if there is a failure of constitutional machinery. The case arose when several states, including Rajasthan, challenged the central government’s threat to impose President’s Rule following the defeat of the Congress party in state elections.
2. Facts of the State of Rajasthan vs. Union of India Case Relevant for UPSC
- Parties Involved: State of Rajasthan and other states (petitioners) vs. Union of India (respondent).
- Legal Questions:
- Whether the President’s satisfaction under Article 356 is subject to judicial review.
- The extent to which the central government can exercise its power to dismiss state governments.
- Noteworthy Events:
- Following the defeat of the Congress party in several state elections, the central government, led by the Congress, threatened to impose President’s Rule in these states.
- The states of Rajasthan, Madhya Pradesh, and Punjab, among others, filed petitions challenging this threat, arguing that it was politically motivated and not based on any genuine constitutional breakdown.
3. What are the Major Judgements/Changes Brought by State of Rajasthan vs. Union of India Case?
The Supreme Court’s judgement provided significant clarity on the use of Article 356:
- The Court held that the President’s satisfaction under Article 356 is not beyond judicial review. It can be examined if it is based on irrelevant or extraneous considerations or if it is malafide.
- The Court emphasized that the power under Article 356 should be used sparingly and only in cases where there is a genuine breakdown of constitutional machinery in the state.
- It was established that the imposition of President’s Rule cannot be based on mere political considerations or electoral defeats.
4. What was the Impact of State of Rajasthan vs. Union of India Case on Indian Constitution?
- Judicial Review of President’s Rule: The case reinforced the principle that the imposition of President’s Rule is subject to judicial review, thus preventing its arbitrary use by the central government.
- Strengthening Federalism: It bolstered the federal structure by ensuring that state governments cannot be dismissed on flimsy or politically motivated grounds, thus protecting the autonomy of states.
5. Was this State of Rajasthan vs. Union of India Case Challenged/Reversed in Future?
The principles established in the State of Rajasthan vs. Union of India case have been upheld in subsequent cases, including the landmark S.R. Bommai vs. Union of India (1994) case. The ruling continues to serve as a crucial precedent in matters involving the imposition of President’s Rule and the interpretation of Article 356.
6. Doctrines/Theories/New Concepts
- Doctrine of Judicial Review of President’s Rule: The case underscored that the exercise of power under Article 356 is subject to judicial scrutiny to ensure it is not misused for political purposes, thereby upholding constitutional propriety and the federal structure of India.