GOLDEN TRIANGLE OF I.

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The relationship between Articles 14, 19, and 21 of the Indian Constitution,
often referred to as the "Golden Triangle," is further elucidated through
landmark case laws that have shaped the interpretation and application of
these fundamental rights.
Article 14 (Equality Before Law)
Case Law: Maneka Gandhi v. Union of India (1978): In this case, the Supreme
Court expanded the scope of Article 14 by interpreting it as embodying the
concept of "substantive due process." The court held that the procedure
established by law must be fair, just, and reasonable, ensuring that it is not
arbitrary or whimsical.

Article 19 (Protection of Certain Rights)

Case Law: State of Madras v. V.G. Row (1952): This case established that the
freedom of speech and expression under Article 19(1)(a) includes the right to
criticize the government constructively. The court emphasized the importance
of this freedom in a democratic society while recognizing the need for
reasonable restrictions to maintain public order and decency.

Article 21 (Protection of Life and Personal Liberty)

Case Law: K.S. Puttaswamy v. Union of India (2017): In a landmark judgment,
the Supreme Court recognized the right to privacy as a fundamental right
under Article 21. This case affirmed that privacy is intrinsic to personal liberty
and dignity, extending the protection of Article 21 to encompass informational
privacy and autonomy over personal data.

Interplay and Significance

- The interplay between these articles is crucial in ensuring a balance between
individual rights and the state's authority. Article 14 ensures equality and non-
arbitrariness in state actions, Article 19 protects freedoms essential for
democratic participation, and Article 21 safeguards the core aspects of life and
personal liberty.
- The Golden Triangle formed by Articles 14, 19, and 21 represents the
foundational principles of justice, equality, and liberty in the Indian
constitutional framework. Their harmonious interpretation and application by
the judiciary uphold the rights and dignity of citizens while guiding the state in
governance and law-making.

By examining these case laws and their implications, we gain a deeper

understanding of how the Golden Triangle of the Indian Constitution operates
in practice, ensuring that fundamental rights are not just theoretical concepts
but tangible guarantees that shape the fabric of Indian democracy.

 One significant legal case where the Golden Triangle of the Indian
Constitution, encompassing Articles 14, 19, and 21, was applied is the
Maneka Gandhi v. Union of India (1978) case. In this landmark judgment,
the Supreme Court of India emphasized the interconnectedness of these
fundamental rights and their collective importance in safeguarding
individual liberties.
Case Overview: Maneka Gandhi's passport was impounded by the government
without providing her with a fair hearing or explanation. She challenged this
action, asserting violations of her rights under Articles 14, 19, and 21 of the
Constitution.
Application of the Golden Triangle: The court ruled that Articles 14, 19, and 21
form a "Golden Triangle" and are interlinked. It held that any law or action
infringing upon these rights must pass a test where provisions do not violate
these fundamental rights. The judgment underscored the significance of due
process of law in upholding individual freedoms and ensuring justice.
Judicial Interpretation: The court's decision in the Maneka Gandhi case
expanded the scope of Article 21 to include procedural fairness and
substantive due process. It highlighted that personal liberty encompasses more
than mere physical freedom and extends to a life of dignity and meaning.

This case exemplifies how the Golden Triangle principles were invoked to
protect an individual's rights against arbitrary state action, setting a precedent
for future interpretations of fundamental rights in India.