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Types of Legal Research Needed For Law R
Types of Legal Research Needed For Law R
J, Page 1 of 28
UNIVERSITY OF LUCKNOW
SUBMITTED TO :- DR.
LLB(HONS):- SEC -A
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INTRODUCTION
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WHAT IS RESEARCH?
John W Best has rightly said “The secret of our cultural development has been
research, pushing back the areas of ignorance by discovering new truth, which, in turn,
leads to better ways of doing things and better products”.
DEFINITIONS:
OBJECTIVES OF RESEARCH:
Right from the evolution of human society, intellectuals of the society are always
inclined to probe for facts of the empirical world and to reveal the truth, “Every aspect of
human behaviours or facts of life has a problem. In 'society there were problems, there
are problems and there will be problems, we have to find out answer to those problems.
Hence this is the requirement of the society to conduct research2.
1. Legal Education and Research Methodology by Dr. Mono Purohit, Central Law Publications
2. Khan, J.A. 2007 P-1
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The research has its functions and uses. We conduct research either to enhance the
efficiency of our system, increase the volume and quality of information, to add on to
what already exists or for creating material conditions of comfort. This also makes us
become a class apart. In other words research has got to be meaningful.
One of the reasons for conducting legal research is to analyse the law by reducing,
breaking and separating the law into separate elements. It can be as simple as examining
and explaining new statutes and statutory schemes or as complex as explaining,
interpreting and criticising specific cases or statutes.
Another reason is “to fuse the disparate elements of cases and statutes together
into coherent or useful legal standards or general rules”.
The product of this research is legal standard that is consistent with, explains, or
justifies a group of specific legal decisions.
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Historical Research means “Finding out the previous law in order to understand
the reasons behind the existing law and the course of its development.”
P.M.Bakshi in his essay “Legal Research and Law Reform” stated Historical
Research as “On the Archives Building in Washington, there is a famous inscription
which reads:
“ALL THAT’S PAST IS PROLOGUE”.
These are pregnant words and not mere rhetoric. The past often explains the
present, most vividly”.
Historical research in this context is not meant a discussion of the history of each
rule of law or of each statutory provision for the sake of mere intellectual delight or for
mere record. Like all other types of research required for the purpose of law reform,
historical research is useful in law where the present statutory provision or rule of law has
raised meaningful queries and it becomes necessary to explore the circumstances in
which the present position came about.
Not unoften, an exploration of the historical material gives a clue to the reasons
why a particular provision was framed in the form in which it now appears. This often
removes certain doubts, or even supplies to the researcher the reasons that justify the
present provision - reasons which may not otherwise be apparent. Obviously, where such
a fruit is yielded by historical research, it has its own utility. It prevents one from making
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a suggestion for change in the law which one was tempted to make (before knowing the
past), but which now appears to be unnecessary.
Secondly, historical research may often reveal that alterations in the law on
particular lines which are now tentatively under consideration had already been thought
of in the past also, in the earlier attempts at reform of the law, but had been rejected for
sound and valid reasons.
Thirdly, historical research would often show that a particular existing provision,
fully justifiable at the time when it was introduced, is no longer so justifiable because the
reasons that justified the original inclusion of that provision are no longer valid.
Historical research reveals the reasons, which might otherwise remain obscure.
Finally, on more general level, when the history of a particular idea which has
been given a concrete shape in the law is studied in depth, it shows the gradual evolution
of the law on certain lines, thus showing the general trend of change. It is true that some
jurists fight shy of history3.
Jeremy Bentham stated “we are told, had scant respect for history and
contributed little to an understanding of legal and social change in a continuum.”
But it is now well recognised that in many cases there is certain logic in the way
in which the law evolves, even though, in some other cases, one may, no doubt, find that
the law had in the past developed rather on haphazard lines.
Of course, when one speaks of historical research, one is not confined to pure law.
Even though the material directly under study may be legal, that is to say, the source to be
consulted may be a traditional legal source, the factual material that comes to light and
the knowledge of ideas gathered from such a source, may often have an interest that
transcends the exclusively legal field. In fact, social and legal factors cannot be always
reduced to water tight compartments. Any adequate appraisal of the precise nature and
rate of change in a particular country must also pay special attention to the effect of
relevant physical, demographic, technological and ideological variables4.
What, then, are the sources from which historical material may be drawn? Here
the legal researcher sometimes feels a handicap. Notwithstanding the availability of
general books on Indian legal history and Indian constitutional history, the researcher will
find that when he sits down to tackle a particular subject assigned to him in a project of
law reform, the historical material is not easily traceable. At least, it is not as easily
traceable as Precedents.
So far as pure statute law goes, some of the commentaries, no doubt, supply the
reader with the text of the corresponding provisions in earlier statutes. But this does not
always fully satisfy the curiosity of the researcher, and may not, in every case, yield
sufficient light as to why a certain provision was phrased in a certain manner in the
corresponding earlier statute.
For this purpose, he will have to consult the relevant legislative debates.
Fortunately, so far as central Acts go, these are excellently preserved in the national
archives or state archives in regard to the older Acts. If the researcher finds it necessary
(as he often may) to know the contemporaneous judicial understanding or exposition of
the earlier provision, he will certainly like to go to the sources that contain such
exposition. Experience has shown that one of the best sources to be consulted for this
purpose are the earlier' commentaries on the particular statute5.
Introduction:
5. P.M.Bakshi, Legal Research and Law Reform, ILI, First Reprint 2006.
6. Prof (Dr.) Kushal Vibhute & Filipos Aynalem, Legal Research Methods, 2009
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The conventional legal approach to the law is all about doctrine. Legal academics
understand that the language of judicial opinions represents the law. The classical form of
legal scholarship was doctrinal research, in which a researcher examined the content of a
legal opinion to evaluate whether it was effectively reasoned or to explore its implications
for future cases. Doctrinal research was grounded in a descriptive premise that reasoned
argument from doctrinal premises actually explained judicial decisions. In other words
this type of research may also be called as “Traditional Research”.
This kind of research is carried on by all the Judges, Lawyers and Law teachers.
The two most important examples of traditional research are the Law of Torts and
Administrative law. These two areas of law have been developed by the Judges rather
than the theoretical researchers. According to Cardozo8 “law or legal propositions are not
final or absolute. They are in the state of becoming. Accepted norms or principles
whether Statutory or as principle of justice, equity and good conscience are applied again
and again to test its veracity or authenticity as a true principle of Law. If it is found to be
Unjust, it may be modified or changed to meet the present requirement.
For example, the Indian Penal Code, 1860 has declared that an attempt to commit
suicide is an offence and the person attempting to do so is punishable under that law. But
in Nagbushan Patnaik’s Case9 the Supreme Court had declared this provision is
unconstitutional as it is in violation of Article 21 of the Constitution of India which
confers on the people, the right to personal liberty. As interpreted by the Supreme Court
the right to personal liberty under Article includes the right to die as well and hence a
person attempting to commit suicide cannot be punished under the section of the Indian
Penal Code.
As the latest decision of the Supreme Court on the point, Gian Kaur v. State of
Punjab10, lays down, life is considered the most precious commodity and every effort has
to be made to preserve it. The Court, in the instant case, made it clear that the right to life,
including the right to live with human dignity would mean the existence of such right
upto the end of natural life. This also includes the right to a dignified life upto the point of
death including a dignified procedure of death. The Supreme Court also reversed its
earlier judgement in the Rathinam Case11 and held that the right to life does not include a
right to die.
Apart from this our statutory law, is replace with such phrases or Vocabularies
which have no definite answer for all situations. The Courts have been given the
discretion to interpret and apply them so as to sub serve the social need, e.g., ‘just and
equitable’, `public order’, ‘reasonable Opportunity of being heard’, ‘reasons to believe’,
‘rash or negligence act’, ‘reasonable apprehension’, ‘industry’, etc. while interpreting
these phrases the judiciary itself has evolved certain norms which are vague and
flexible13. Which can be made certain and workable by evolving principle on the basis of
research.
If the researcher happens to be a judge he can give concrete shape and stability to
the legal principles by applying the principle of review or revision or overruling. A good
14
number of cases may be cited to substantiate this point of view, e.g. Shankeri Prasad
and Sajjan Singh’s Cases15 were overruled by Golak Nath Case16 which was
subsequently overruled in Keshavanand Bharati case17. Similarly a definite shape was
provided by the Supreme Court to the right of personal liberty as given in Article 21 of
the Constitution in A.K.Gopalan’s case18. But its scope was widened in Menaka Gandhi19
and in subsequent other cases because the Court was convinced that with the passage of
time the meaning and scope of the right to personal liberty has considerably widened
since its decision in A.K.Gopalan’s case.
The Court has introduced changes not only in the area of Constitutional Law, but
also in the area of Labour law, Criminal law as well as Property Law. The Courts have
held that death sentence should not be imposed in all cases in which the offence of
murder is established, but only in rarest of rare cases. Death penalty is now an exception,
life imprisonment is the rule20. Not only the execution of death sentence in public has
been held to be a barbaric act and that the person sentenced to death to also entitled to
procedural fairness till the breath of his life21.
The Court has also recognized the right to die and hence an attempt to commit
suicide is more an offence. Although in a recent judgment in Gyan Kaur v. State of
Punjab and others, the Supreme Court has reversed this judgment and has held that the
attempt to commit suicide is a punishable offence.
Most of the works of doctrinal researchers result in some concrete proposals for
problems in hand, but sometimes, it fails, especially when the subject is growing very fast
or when the research was undertaken merely to test the logical consistency and technical
soundness of a proposition.
These tools, depending upon the nature of information they contain, may be re-
categorized into primary and secondary sources of information. National Gazette and
Case Reports fall in the first category, while the rest fall in the latter.
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Introduction:
However, in the recent past, doctrinal legal research has received a severe jolt due
to change in the political philosophy of law from the laissez faire to the welfare state
envisaging socio-economic transformation through law and legal institutions, the
consequential new substantive and functional facets of law, and certain compelling
pragmatic considerations arising from this metamorphosis.
Prominent reasons and arguments stressing the need for inquiry into social facets of law
are:
a. The emergence of sociological jurisprudence23 and its underlying philosophy
assigned ‘law’ the task of ‘social engineering’.
b. In the light of such a role assigned to law, it is argued, it becomes necessary to
look into the ‘factors’ or ‘interests’ of the Legislature that play significant role in
setting the legislative process in motion and in identifying the beneficiaries
thereof and the reasons there for.
c. It becomes necessary to carry out frequent attitudinal studies of those whose legal
position is sought to be modified by a given law as well as of those who are
vested with the power of interpreting and implementing it so that the Legislature,
armed with this feedback, can fulfill its job in a more satisfactory manner.
d. A number of facts or factors that lie outside a legal system may be responsible for
non-implementation or poor implementation of a given piece of social legislation.
e. There is nearly always a certain ‘gap’ between actual social behaviour and the
behaviour demanded by the legal norm and certain ‘tension’ between actual
behaviour and legally desired behaviour.
Sociology of Law:
From where does a doctrinal researcher get his social policy, social facts and
social values? The answer is his own experience, observation, reflection and study of
what others have done before him in a similar or same kind of situation. However, it will
certainty add value to his research if he gets an opportunity to test his ideas by
sociological data. In other words, the sociology of law tries to investigate through
Empirical Data how law and legal institutions affect human attitudes and what impact on
society they create. The sociology of law also concerns itself with the identification and
creating an awareness of the new problems which need to be tackled through law.
Just as a matter of semantics, the author will use the term “sociology of law (or)
Socio-Legal” where the major tools of a legal researcher are “empirical and sociological
data”. This is to be distinguished from sociological jurisprudence and, as stated earlier, a
doctrinal researcher has to be but a sociological jurist because of the wide discretion
available to him in modern times to make his value choices.
Though sociology of law may have great potentialities, yet a few caveats must be
entered here.
Firstly, sociological research is extremely time consuming and costly, It has been
stated “Socio legal research is more expensive, it calls for additional training; and it
entails great commitments of time and energy to produce meaningful results, either for
policy-makers or theory-builders”.24
The decisions in human affairs. However, cannot await the findings of such
studies and must constantly be made, and herein comes the value and utility of doctrinal
research. Thus, “Doctrinal legal research...has had the practical purpose of providing
lawyers, judges and others with the tools needed to reach decisions on an immense
variety of problems, usually with very limited time at disposal”.25
24. International Legal Center, Law and Development, 10, (New York, 1974)
25. Vilhelm Aubert (Ed.), Sociology of Law 9 (1969)
26. Upendra Baxi, Socio-Legal Research in India: A Programs rift 7 (ICSSR, 1975)
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The reason is simple. The primary objectives of the sociology of law are to reveal,
by empirical research. How law and legal institutions operate in society, to improve the
contents of law, both in substantive and procedural aspects, to improve the structure and
functioning of legal institutions whether engaged in law administration, law enforcement,
or settlement of disputes.
Thirdly, sociological research may help in building general theories, but it seems
inadequate where the problems are to be solved and the law is to be developed from case
to case. For instance, as a matter of general theory it is axiomatic that governmental
powers need to be checked as “power corrupts and absolute power corrupts absolutely”,
but too much check may result in governmental ineffectiveness. This necessitates that
when a case comes before a court in which abuse of power by the executive is alleged,
pragmatic considerations ought to control the decision-making. Since the law to control
governmental action develops from case to case, it will not do to theorise that either there
should be no control over governmental action or there should be adequate control. That
is why it has been said about the ultra vires doctrine, which is the basis of judicial review
in case of writs:
The ultra vires doctrine provides a half way basis of judicial review between
review in appeal and no review at all.... The half way review, the extent of which is not
always clear, creates uncertainty about judicial intervention in administrative action.
Sometimes, the courts may feel like intervening because they feel strongly about the
injustice of the case before them; sometimes they are not sure of injustice and wish to
give due deference to the expertise of the administration and uphold the decision.27 It is
beyond the comprehension of the author how we can improve the contents of the ultra
vires doctrine by sociological research.
Fourthly, the function of law in society is not only to follow or adapt itself to
public opinion but also to give a lead and mould public opinion. When the law should
follow one course or the other may not always be answered on the basis of sociological
data but on the basis of one’s maturity of judgment, intuition, and experience, though
sociological research may be of some informational value to the decision-maker.
Kelsen Says: “The issue between liberalism and socialism, for instance, is, in
great part, not really an issue over the aim of society, but rather one as to the correct way
of achieving a goal as to which men are by and large in agreement, and this issue cannot
be scientifically determined, at least not today”.28
He further says:
I. It lays down a different and lesser emphasis upon legal doctrines and concepts,
II. It seeks answers to a variety of broader questions,
III. It is not anchored exclusively to appellate case reports and other traditional legal
sources for its data, and
IV. It invariably involves the use of research perspectives, research designs,
conceptual frameworks, skills, and training not peculiar to law trained
personnel.31
Basic Tools:
1. There are several ways of collecting empirical data for social-legal research. The
required information can be collected from the identified respondents in a face-to-
face interaction by administrating them a set pre-determined question or through
sketchy questions prepared by the respondent. These methods of data collection
are known as ‘interview’ and ‘schedule’ respectively.
2. The pre-determined questions can also be administered to the respondents
indirectly through post, fax, emails or any other appropriate methods of
communication. This method of data collection is known as ‘questionnaire’.
3. A socio-legal researcher can also collect the required information by systematic
‘observation’ of a phenomenon, behavior of his respondents or institutions that
constitute focus of his study or by studying other existing records that reflect the
phenomenon under his inquiry.
(1) It is time consuming and costly. It calls for additional training, great commitment of
time and energy, for producing meaningful result.
(2) It needs a strong base of doctrinal research. The researcher must have strong base of
legal doctrines, case law and legal institutions.
(3) It is extremely weak in solving a problem in hand; similarly it is not effective where
the law is to be developed from case to case.
(4) It cannot give a direction as to what course the law should follow to be useful.
(5) It cannot remain unaffected from human vices, upbringing and thinking because
acceptance of a new system of law in India depends on many factors such as
awareness, value, capability and pattern of adaption.
The comparative legal research is used to study legislative texts. Jurisprudence and also
legal doctrines, particularly of foreign laws. It stimulates awareness of the cultural and
social characters of the law and provides a unique understanding of the way law develops
and works in different cultures33. It also facilitates better understanding of the functions
of the rules and principles of laws and involves the exploration of detailed knowledge of
law of other countries to understand them. To preserve them, or to trace their
evolution34.Accordingly, comparative legal research is beneficial in at legal development
process where modification, amendment and changes to the law are required.
Nowadays, comparative approach also refers to the study of specific aspects of the
law from the perspective of Shari’ah37 in comparison to civil law.
So far as the countries which may be chosen for the purpose of comparison it
must be kept in mind that most of our present day laws have been borrowed from the
English Law and we are well acquainted with that system. Therefore, we can have
recourse, very often to the English law. We can also leave recourse to the laws of the
countries belonging to common Wealth e.g. Australia, Canada, Newzeland, etc..
Recourse to the law of United States of America and continental countries e.g. France,
Germany, Switzerland and Sweden can also be had. Here again it could not be out of
context to refer that as regards interpretation of Constitutional and Administrative Laws,
we rely heavily on U.S., French and British practice. The material which should be
accepted for comparison should be generally the codified law.
But in case of secondary and tertiary sources their authenticity must be checked
and rechecked two or more primary, secondary and tertiary sources may be checked with
each other.
If these handicaps are properly handled, this method of research is very useful for
suggesting reform in law. However, in the name of reform, foreign legal system should
not be imported in this country blindly. Only such reforms are suggested as suits to the
Indian ethos and which is necessary for the progress and development of the country.
37. The code of Law derived from the Koran and from the teachings and example of Mohammed.
Shariah is only applicable to Muslims.
“Types of Legal Research needed for Law Reform” by Sanjeyvignesh.J, Page 21 of 28
1) The choice between induction and deduction depends on a series of factors, but above
all on the objectives of our study. It can also be linked to and determine the
differences between qualitative and quantitative methods.
2) In law both approaches are used:
1) General proposition or premise : To steal is an act contrary to Sec.1 of the Theft Act,1978.
2) Minor proposition : Anne has stolen a book.
3) Conclusion : Anne has acted contrary to Sec.1 of the Theft Act, 1978.38
38. Hanson, Sharon, Legal Method and Reasoning (London: Cavendish, 2003) pp. 215-268
“Types of Legal Research needed for Law Reform” by Sanjeyvignesh.J, Page 22 of 28
Applied research (or) Action Research aims at finding a solution for an immediate
problem. Here the researcher sees his research in a practical context. While in
Fundamental Research (or) Pure Research (or) Basic Research, the researcher is mainly
concerned with generalization and with the formulation of a theory. He undertakes
research only to derive some increased knowledge in a field of his inquiry. He is least
bothered about its practical context or utility. Research studies concerning human
behavior carried on with a view to making generalizations about human behavior fall in
the category of fundamental or pure research. But if the research (about human behavior)
is carried out with a view to solving a problem (related to human behavior), it falls in the
domain of applied or action research.
The central aim of applied research is to discover a solution for some pressing
practical problem, while that of fundamental research is to find additional information
about a phenomenon and thereby to add to the existing body of scientific knowledge. The
‘applied’ scientist is thus works within a set of certain values and norms to which he feels
committed. A sociologist, for example, when works with a social problem to find solution
therefor and proposes, through a systematic inquiry, a solution or suggests some
measures to ameliorate the problem, his research takes the label of ‘applied’ or ‘action’
research. But when he undertakes a study just to find out the ‘what’, ‘how’ of the social
problem, his inquiry takes the nomenclature of ‘pure’ or ‘fundamental’ research.
2. Statistical Research:
activity; cannot undertake this kind of research. However, in limited areas requiring
simple statistics, this process may be applied, e.g., in the area of land reform; disposal of
pending cases by the court enhancement in wages, and other monetary benefits etc.,
In order to collect statistics, field research in the form of sample survey , opinion
polls, questionnaires etc is conducted and it can be conducted efficiency only by a
qualified person with an aptitude for research and having professional training and legal
knowledge. In case, the person conducting statistical research has no legal knowledge, the
involvement of persons from the area of law is must as it facilitates the smooth conduct
of the work for the purposes of law reform. Since law is a behavioural science, therefore
statistical research should be applied with caution and only where it is necessary to do so.
3. Critical research:
As we know that the objective of legal research is not only to propose suggestions
for legal reform. It may be carried on for many other purposes as well. Where, however,
the object of research is only to indicate in which way it is to be carried on, such a
research is termed as critical research because in such cases the objective is to ascertain a
common principle or norm and hence, it is also termed as ‘normative research’ . In this
kind of research gathered material is thoroughly examined and a common thread is
ascertained which ultimately becomes the basic norm.
For the purposes of critical research, the necessary material is obtained from
codified law, judicial observations and pronouncements and academic Writings. In
matters of critical research, public opinion also plays an important role and public
opinion must be ascertained in a proper manner.
‘Case-Law’ consists of rules and principles stated and acted upon by the Judges in
giving decisions. Like English Law, Indian Law also is largely a system of Case Law.
That is the decision in a particular case constitutes ‘Precedent’. According to the
‘Doctrine of Precedent’ it is not everything said by a Judge, when giving judgement that
constitutes precedent. But only the reason of the decision given in the judgement
constitutes precedent. So the reason stated in the judgement of an appeal case becomes a
necessary subject matter of inquiry and analysis by a lawyer. This requires identification
of the most important parts of the judgement40. They are:
(1) A statement of the significant facts of the dispute before the court – the facts that
are necessary to an understanding of the dispute and of the court’s decision, those
that influenced the court’s reasoning and decision.
(2) A statement of a relevant procedural details such as the explanation of the legal
nature of the controversy and of the remedy sought,. The actions and the ruling of
the lower court.
(3) A statement of narrow legal question or issue(s) that the appellate court was asked
to resolve.
(4) A brief statement of the Appellate Court’s decision, both procedural and
substantive.
(5) An explanation of court’s reasoning in reaching its decision.
In modern times, case-law based research is concerned to a very large extent with
considerations of social value, social policy and the social utility of law and any legal
proposition. It is naive to think that the task of a doctrinal researcher is merely
mechanical – a simple application of a clear precedent or statutory provision to the
problem in hand, or dry deductive logic to solve a new problem. He may look for his
value premises in the statutory provisions, cases, history in his own rationality and
meaning of justice. He knows that there are several alternative solutions to a problem
(even this applies to a lawyer who is arguing a case before a court or an administrative
authority) and that he has to adopt one which achieves the best interests of the society.
The judges always unconsciously or without admitting think of the social utility of their
decisions, but cases are also not infrequent when the Indian Supreme Court has
consciously and deliberately incorporated social values in the process of its reasoning. To
take a few examples here, in Bengal Immunity Co. v. State of Bihar, 41 the court, while
overruling State of Bombay v. United Motors, 42 stated:
All big traders will have to get themselves registered in each State, study the Sales
Tax Acts of each State, conform to the requirements of all State laws which are by no
means uniform and, finally, may be simultaneously called upon to produce their
books of account in support of their returns before the officers of each State. Anybody
who has any practical experience of the working of the sales tax laws of the different
States knows how long books are detained by officers of each State during assessment
proceedings.... The harassment to traders is quite obvious and needs no exaggeration.
The criteria for determining the degree of restriction on the right to hold property
which would be considered reasonable, are by no means fixed or static, but must
obviously vary from age to age and be related to the adjustments necessary to solve the
problems which communities face from time to time.... lf law failed to take account of
unusual situations of pressing urgency arising in the country, and of the social urges
generated by the patterns of thought-evolution and of social consciousness which we
witness in the second half of this century, it would have to be written down as having
failed in the very purpose of its existence.... In the construction of such laws and
particularly in judging of their validity the Courts have necessarily to approach it from
the point of view of furthering the social interest which it is the purpose of the legislation
to promote, for the courts are not, in these matters, functioning as it were in vacuo, but as
parts of a society which is trying, by enacted law, to solve its problems and achieve social
concord and peaceful adjustment and thus furthering the ,moral and material progress of
the community as a whole.
In the famous Golak Nath v. State of Punjab, 44 Subba Rao, C.J., said:
But, having regard to the past history of our country. it could not implicitly believe
the representatives of the people, for uncontrolled and unrestricted power might lead to
an authoritarian State lt. therefore, preserves the natural rights against the State
encroachment and constitutes the higher judiciary of the State as the sentinel of the said
rights and the balancing wheel between the rights, subject to social control.
The court’s concern with social justice is depicted forcefully in following observations of
Bhagwati, J., in Kanwarlal v. Amarnath45
Would result in serious discrimination between one political party or individual and
another on the basis of money power, and that in its turn would mean that “some
voters are denied an 'equal' voice and some candidates are denied an ‘equal Chance’”.
The democratic process can function efficiently and effectively for the benefit of the
common good and reach out of the benefits of self government to the common man
only if it brings about a participatory democracy in which every an, however lowly or
humble he may be, should be able to participate on a footing of equality with others.
Individuals with grievances, men and women with ideas and vision are the sources of
any society’s power to improve itself.
CONCLUSION
BIBLIOGRAPHY:-
1) P.M.Bakshi, Legal Research and Law Reform, ILI, First Reprint 2006.
2) Prof (Dr.) Kushal Vibhute & Filipos Aynalem, Legal Research Methods, 2009
3) S.N.Jain, Doctrinal and Non-Doctrinal Legal Research, 14 J ILI 487 (1972)