State of Rajasthan v. Union of India

Facts

After the 1977 general elections, the Union Home Minister wrote to several Congress-ruled States advising the Chief Ministers to seek dissolution of their Legislative Assemblies and a fresh mandate, on the basis that the parties in power in those States had lost the people's confidence. The States, apprehending invocation of President's Rule under Article 356, invoked the Supreme Court's original jurisdiction under Article 131 to restrain the Union. This raised, for the first time at this level, the scope of judicial scrutiny over Article 356.

Issues

• Whether the President's satisfaction under Article 356(1) is justiciable and to what extent.
• Whether the threatened invocation of Article 356 against the petitioning States could be restrained by the Court.

Arguments

The States argued that dissolving duly elected Assemblies merely because the ruling party fared poorly in parliamentary elections was an unconstitutional abuse of Article 356 violating federalism. The Union argued that the satisfaction under Article 356 was subjective and political, beyond the reach of judicial review, and that loss of popular confidence was a relevant ground.

Held

The Court declined relief to the States, taking the view that the satisfaction of the President under Article 356 was essentially a political and subjective matter into which the Court could not ordinarily inquire. Judicial review was confined to a very narrow band, namely where the action was shown to be mala fide or based on wholly extraneous or irrelevant grounds. The Court thus accepted, in principle, a limited justiciability of the power while in practice giving the Union wide latitude.

Ratio decidendi

The President's satisfaction under Article 356 is primarily political and subjective, and is open to judicial review only on the narrow grounds of mala fides or reliance on wholly extraneous or irrelevant considerations.

Significance

The principal pre-Bommai authority on the justiciability of President's Rule, marking the deferential 'political question' approach to Article 356. It was the doctrinal stepping-stone later expanded and substantially superseded by the more robust judicial-review standard in S.R. Bommai (1994), which entrenched floor tests and basic-structure limits.

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