1. What is the S.R. Bommai vs. Union of India Case all about?
The S.R. Bommai vs. Union of India case is a landmark judgement in 1994 that significantly impacted the application of President’s Rule under Article 356 of the Indian Constitution. The case arose after the dismissal of the Janata Party government led by S.R. Bommai in Karnataka, which was accused of losing the majority support in the legislative assembly. The central issue was the misuse of Article 356 by the central government to dissolve state governments, and the Supreme Court’s verdict aimed to curb this misuse.
2. Facts of the S.R. Bommai vs. Union of India Case Relevant for UPSC
- Parties Involved: S.R. Bommai (former Chief Minister of Karnataka) and the Union of India.
- Legal Questions:
- Whether the President’s Rule imposed in Karnataka was constitutionally valid.
- The extent of judicial review over the President’s proclamation under Article 356.
- Noteworthy Events:
- S.R. Bommai’s government was dismissed on the grounds that it no longer enjoyed the majority in the state assembly.
- Bommai challenged the dismissal in the Karnataka High Court, which was later escalated to the Supreme Court.
- The case consolidated several similar instances of dismissal of state governments.
3. What are the Major Judgements/Changes Brought by S.R. Bommai vs. Union of India Case?
The Supreme Court’s verdict laid down significant guidelines for the imposition of President’s Rule:
- The President’s proclamation of emergency under Article 356 is subject to judicial review.
- The validity of the proclamation can be challenged if there is no relevant material or if the material is irrelevant, arbitrary, or mala fide.
- A floor test in the assembly is the appropriate method to test the majority of a government.
- The power under Article 356 should be used sparingly and only when there is a genuine breakdown of constitutional machinery in the state.
4. What was the Impact of S.R. Bommai vs. Union of India Case on Indian Constitution?
- Judicial Review: The case reinforced the principle that the President’s Rule is subject to judicial review, thereby preventing its arbitrary use.
- Federalism: Strengthened the federal structure by ensuring that state governments cannot be dismissed by the central government without substantial grounds.
- Democratic Norms: Emphasized the importance of democratic processes, such as the floor test, to determine the majority in the legislature.
5. Was this S.R. Bommai vs. Union of India Case Challenged/Reversed in Future?
The principles established in the S.R. Bommai case have not been reversed and continue to serve as a crucial precedent in matters related to the imposition of President’s Rule and the functioning of federalism in India.
6. Doctrines/Theories/New Concepts Introduced by S.R. Bommai vs. Union of India Case
- Judicial Review of President’s Rule: The case established that the imposition of President’s Rule under Article 356 is subject to judicial review, ensuring that such power is not misused.
- Floor Test Doctrine: Introduced the concept of using a floor test in the legislative assembly to ascertain the majority support for the state government, promoting transparency and democratic principles in legislative procedures.