Indian Journal for Research in Law and Management

The Indian Journal for Research in Law and Management

Advancing Law and Management

ISSN No. : 2583-9896

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The Indian Journal for Research in Law and Management

ISSN No. : 2583-9896

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Maenka Gandhi v. Union of India

Authors
Mahak Raikwar
Avantika University
Published August 17, 2026
Volume Volume III
Issue Issue 10
DOI https://doi.org/10.5281/zenodo.21985384

Cite this Article

Mahak Raikwar (2026). Maenka Gandhi v. Union of India. The Indian Journal for Research in Law and Management, Volume III(Issue 10). Retrieved from https://ijrlm.com/journal/maenka-gandhi-v-union-of-india/

Abstract

This commentary analyzes the historic 1978 Supreme Court judgment triggered by the arbitrary seizure of journalist Maneka Gandhi's passport in 1977. The court established the "Golden Triangle Rule," linking Articles 14, 19, and 21 to rule that fundamental rights are interdependent rather than mutually exclusive. It expanded "personal liberty" under Article 21 to include the right to travel abroad and declared that any legal procedure depriving a person of liberty must be "reasonable, fair, and just," effectively absorbing the principle of natural justice (Audi Alteram Partem) into Indian jurisprudence.

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