FACTS:

The S.R. Bommai case (S.R. Bommai vs. Union of India, 1994) involved the dismissal of the
Karnataka state government in 1989.
1. Dismissal of Karnataka Government:
 In April 1989, the Governor of Karnataka submitted a report to the President
of India, recommending the imposition of President's Rule (under Article 356
of the Indian Constitution) in the state. The report alleged that the government
in Karnataka had failed to comply with constitutional provisions.
2. Grounds for Dismissal:
 The central government, led by Prime Minister Rajiv Gandhi, dismissed the
elected government in Karnataka, citing reasons such as corruption,
maladministration, and breakdown of constitutional machinery.
3. Legal Challenge:
 The dismissed Chief Minister of Karnataka, S.R. Bommai, challenged the
dismissal in the Supreme Court, arguing that the action was politically
motivated and violated the principles of federalism.
4. Judicial Review:
 The primary issue before the Supreme Court was whether the President's
action under Article 356 was immune from judicial review, or if the court
could examine the validity of the grounds for dismissal.
5. Supreme Court's Decision:
 The Supreme Court, in its landmark judgment in 1994, ruled that the
President's action under Article 356 was subject to judicial review. The court
asserted that it could examine whether the material considered by the
President and the satisfaction arrived at were based on relevant and valid
grounds.
6. Guidelines for Imposing President's Rule:
 The court laid down guidelines to be followed before resorting to Article 356.
It emphasized that the power should be used sparingly and only in situations
where the government in a state is unable to function according to
constitutional provisions.
7. Protection of Federal Structure:
 The judgment reinforced the principles of federalism and protected the
autonomy of state governments from arbitrary dismissals by the central
government.
8. Restoration of S.R. Bommai's Government:
  As a result of the Supreme Court's decision, the dismissed government in
Karnataka was restored, and S.R. Bommai was allowed to resume his position
as Chief Minister.

ISSUES INVOLVED:

The S.R. Bommai case raised several critical constitutional issues, and the Supreme Court
addressed them in its landmark judgment. The key issues raised in the case include:
1. Judicial Review of Article 356:
 One of the primary issues was whether the President's action under Article
356, leading to the dismissal of a state government, was immune from judicial
review. The court had to determine whether it could examine the validity of
the grounds on which the President's satisfaction was based.
2. Scope of Presidential Discretion:
 The case delved into the extent of discretionary power that the President could
exercise under Article 356 when dismissing a state government. The court had
to clarify the limits of this discretion and whether it was subject to any
constitutional restrictions.
3. Misuse of Article 356:
 The court examined the circumstances under which Article 356 could be
invoked. It aimed to address the issue of potential misuse of this constitutional
provision for political reasons rather than genuine concerns about the
breakdown of constitutional machinery.
4. Protection of Federalism:
 The case raised questions about the protection of federalism in the Indian
Constitution. It sought to establish the balance between the powers of the
central government and the autonomy of state governments, ensuring that the
federal structure of the Constitution was not undermined.
5. Constitutional Principles:
 The court had to interpret and apply various constitutional principles,
including those related to democracy, rule of law, and the distribution of
powers between the center and the states, in order to determine the
constitutional validity of the dismissal of the Karnataka government.
6. Guidelines for Imposing President's Rule:
 The court addressed the need for clear guidelines to be followed by the central
government before resorting to Article 356. It aimed to prevent arbitrary use
 of the provision and ensure that the dismissal of a state government was based
on valid and relevant grounds.

JUDGEMENT:
In the S.R. Bommai vs. Union of India case, the Supreme Court of India delivered a landmark
judgment on March 11, 1994. The judgment was authored by Justice Kuldip Singh. Here are
the key points and conclusions from the judgment:
1. Judicial Review of Article 356
- The Supreme Court held that the President's satisfaction under Article 356, leading to the
dismissal of a state government, is not beyond judicial review. The court can examine
whether the material considered by the President and the satisfaction arrived at were based on
relevant and valid grounds.
2. Scope of Presidential Discretion
- The court clarified that while the President's satisfaction is subjective, it is not immune
from judicial scrutiny. The discretionary power of the President under Article 356 is not
absolute, and its exercise must conform to constitutional principles.
3. Misuse of Article 356
- The judgment emphasized that Article 356 should be used sparingly and in extreme cases
where there is a breakdown of constitutional machinery in a state. The court declared that the
power conferred by Article 356 should not be used for political purposes or to serve the
interests of a particular party.
4. Protection of Federalism
- The Supreme Court underscored the importance of federalism and held that the dismissal
of a state government under Article 356 interferes with the federal structure of the
Constitution. The court aimed to strike a balance between the powers of the center and the
autonomy of state governments.
5. Guidelines for Imposing President's Rule
- The judgment laid down specific guidelines that the central government must follow
before imposing President's Rule in a state. These guidelines include the need for the central
government to have reliable and concrete material to support the claim of a breakdown of
constitutional machinery in the state.
6. Role of Governor
- The judgment highlighted the role of the Governor in the dismissal process. It stated that
the Governor's report is not immune from judicial review, and the court can examine whether
the material forming the basis of the report is relevant and valid.

7. **Restoration of the Dismissed Government:**

 - As a consequence of the judgment, the dismissed government in Karnataka led by S.R.
Bommai was restored, and Bommai was allowed to resume his position as Chief Minister.

In summary, the S.R. Bommai case established important legal principles regarding the use of
Article 356 and its implications on federalism. The judgment provided a framework to
prevent the arbitrary use of President's Rule and emphasized the need for constitutional
adherence in such matters.