THE PRESIDENT OF INDIA IMPEACHMENT

Author(s): V. N. Srivastava
Source: The Indian Journal of Political Science , December 1980, Vol. 41, No. 4 (December
1980), pp. 803-814
Published by: Indian Political Science Association

Stable URL: https://www.jstor.org/stable/41855058

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 THE PRESIDENT OF INDIA IMPEACHMENT
V. N. Srivastava

In almost all republics and in England for all persons except for
the king who "can do no wrong", a system of impeachment1 prevails
the trial of the Head of the State, In England, impeachments have
now fallen into disuse2 and lost their value because the House of
Commons has become powerful enough to control and review the con-
duct of Ministers as to make it impossible for them to conduct busi-
ness without a parliamentary majority.3 Even though there can be
no impeachment of the British Monarch, he is still removable. He
remains on the Throne for life but as he owes his Crown to the good-
will of the Parliament, any untoward, unconstitutional or improper
action makes him liable to abdication. This has been established
by the case of king Edward VIII, who, as Prince of Wales had earned
the title of "Prince Charming", was a very popular.

The Constitution of India, on the other hand, provides that "the

President may, for violation of the Constitution, be removed from
office by impeachment".4

"When a President is to be impeached for violation of the Constitution,

the charge shall be preferred b> either House of Parliament. No such
charge shall be preferred unless the proposal to prefer such charge is

1 It has been borrowed by almost all the countries in the w rid from England
where it originated.
2 The last impeachments in England were those of Warren Hasting» ( 1788-95) and
Lord Melville (1805).
3 Anson: THE LAW AND THE CUSTOM OF THE CONSTITUTION, vol- I
(1935) p. 407.
4 Art. 56 (i) (b).

803

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í 04 INDIAN JOURNAL OF POLITICAL SCIENCE

contained in a resolution which has been moved afier at least fouiUen

day's notice in writing signed by not less than one fourth of the total
number of members of the House has been given of their intention
to move the resolution and such resolution has been passed by a majority
of not less than two-thirds of the total membership of the House. When
a charge has been so preferred by either House of Parliament, the other
House shall investigate the charge or cause the charge to be investigated
and the President shall have the right to appear and to be represented at
such investigation. If as a result of the investigation a resolution
is passed by a majority of not less than two-third* of the total member-
ship of the House by which the charge was investigated or causcd to be
investigated, declaring that the charge preferred against the President
has been sustained, such resolution shall have the effect of removing the
President from his office as from the date on which the resolution is so
passed".5

This procedure is almost identical to that in the Unrted States of

America, except for some major differences.

In the United States of America, to start with, some members of

the House of Representatives bring charges against the President on
the floor of the House. These charges, if the House believes that they
are deserving of investigation, are then refrerred to a Special Commi-
ttee of the House The Committee after looking into the .matter, may
recommend to the whole House that the charges be incorporated in
articles of imperchment and transmitted to the Senat« for action.
After that, all further proceedings rest with the Senate. The
House has no part in determining the verdict. The Senate has the sole
power to try impeachments (Art. 1, Section 3 (6) ). Thus, the Senate
h^ars the impeachment as a regular trial where witnesses are called
and the accused is permitted to be represented by a counsel.

In contrast, any one cf the Houses in India can impeach the

President by drawing up charges and the other Houso^ither sits as the
Court of investigation or causes the charges preferred by the other
House to be investigated either by a Court of law or by an ed hoc
Tribunal appointed by the House for that purpose. The latter alter-
native is preferable for the purpose of securing a non- political and
judicial investigation. American arrangement is sviperior to the
Indian arrangement in this respect. In the U. S. A. the nation
5 Art. 61 (1)- (4).

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 THE PRESIDENT OF INDIA -IMPEACHMENT 805

represented in the House of Representatives charges the erri

dent and the States through their representatives in the Sen
if the charges are true. It can, however, be safely assume
India charges arc most likely to be framed always by the
for the simple reason that the Government which decides to
a President can more easily command a majority in that
than in a semi-permanent Rajya Sabha .

In the USA, while transacting the judicial business of

ment, the Senators remain on oath and the Chair is taken by
Justice of the Supreme Court. This extraordinary arrang
intended to insure fairness in trial; for according to the
Constitution, in the event of successful impeachment of the
the Vice President who is the Chairman of the Senate is
Presidentship for the unexpired portion of the presidential
it is but natural that be might out of human weakness use h
manship in the Senate for furthering his own chances of ge
the White House. A two-thirds of ihe votes of the Senators
at the impeachment is necessary for conviction.

In India, on the other hand, when the charge is investiga

House of Parliament, the Speaker of the Lok Sabha or the
of the Rajya Sabha which means the Vice-President of In
case may be, will presidet The final decision to remove the
requires "a majority of not less thaa two-ihirds of the total
ship of the House by which the charge was investigated or c
be investigated". Here, a lacuna is noticeable in the w
cedure. There is no provision for suspension of the presi
impeachment ; he is entitled to hold office for five year
resigns or is removed by impeachment. He continues in
even when he is under charge and investigation and as the w
precedence puts him higher than anybody else in the U
open to question if he can objectively and in person exercise
of defence in either House with Vice-President or the Speak
Chair or even before any other tribunal. The American
having the Chief Justice of Supreme Court, who is the
Judiciary in the country -a separate and 'equal' organ of Go
in the Chair seems to be a more reasonable arrangement. T

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g<>6 INDIAN JOURNAL OF POLITICAL SCIENCE

India, it remains to be seen as to how -if at all the President defends

himself in the Lok Sabha or Rojya Sabha sitting as a court of
investigation with his subordinate, the Vice-President, or the Speaker
lower in rank to the President, in the Chair.

Grounds of Impeachment

The President of índia can be impeached only for the "violation

of the Constitution", whatever that might mean. The Constitution
does not define what is meant by this expression. In comparison,
the Constitution of the Union of Burma explicitely and rather
elaborately states the grounds of impeachment.

Article 54 (1) of that Constitution provides that "the President

may be impeached for (i) high treason (ii) violation of the Con-
stitution or (iii) gross misconduct". The Italian Constitution of
1947, in its Article 85, prescribes impeachment of the President for
"high treason or violation of the Constitution". Article 42 of Fourth
French Republic Constitution says that "the President of the Republic
may not be tried except for high treason." Article 12(10) of the
Constitution of Eire (1937) says "the President may be impeached for
the stated misbehaviour." And finally, Article 11, Section 4 of the
Constitution of the U.S A. lays down:

"the President, Vice-President, and all Civil Officers of the United

States, shall be removed from office on impeachment for and conviction
of, treason, bribery or other high crimes and misdemeanours'*.

There is a consrdesable difference of opinion in India regarding

the interpretation of the phrase "Violation of the Constitution" on
which ground alone the President can be impeached. It is widely
held that the President can be impeached only when an express pro-
vision of the Constitution is violated. Some believe that even if the
President chooses to effectively exercise some of hi« powers indepen-
dent of the Council of Ministers, he will not be guilty of violating
the Constitution. The Constituent Assembly Debates show that
even the Founding Fathers were not quite clear on this point. An
amendment was moved in the Constituent Assembly to include treason
and bribery but was lost due to opposition of Ambedkar on the

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 THE PRESIDENT OF INDIA -IMPEACHMENT 807

ground that they were implied in the phrase.6 Later, Aliad i Krishn-
aswamy Aiyar in the Assembly pointed out that disregarding the
advice of the Ministers amounted to violation of the Constitution but
many others did not accept his viewpoint.7

The vital point in this context is : what constitutes a 'Violation

of the Constitution' ? What is the scope of impeachment ?

In England, impeachment is, of course, a judicial and not like

the Bill of Attainder, a legislative proceeding against a Lord or a
Commoner. The person may be accused of treason or felony or other
high crimes and misdemeanours.8 The words 'treason' and 'felony'
mean offences under statutory or common law; but "high crimes or
misdemeanours" are offences for which no definition is to be found
in the statutory or the Common Law.' May says :

"Impeachment by the Commons for high crime and misdemeanours

beyond the reach of the law or which no authority in the state will
prosecute, is a safeguard of liberty".*0

It was a procedure for trying "great political offenders whom

the ordinary powers of law failed to reach".11 Anson says that it
was one of the main weapons of the Commons to gain "control over
the conduct of the Ministers of the Crown" and in the seventeenth
century it was freely used "as a check on Ministers whose policy
displeased thetp".1* According to Keith it was used "as a means of

6 CAD, vol. VII, p. 1081.

7 Ibid., vol. VIII, p. 216.
S Halsbury: LAWS OF ENGLAND, vol. XXVI, pp. 214-16; Chalmers & Hood:
CONSTITUTIONAL LAWS (1946) pp. 46-48; Wade & Philips: CONSTITUTI-
ONAL LAWS (1946) p. 206.
9 Craics, W.F, "Misdemeanour" in ENCYCLOPAEDIA BRITANNICA, vol.
XVIII, Xlth edition, pp. J77-78.
10 May: PARLIAMENTARY PRACTICE, XHth edition, pp. 588-91.
11 ENCYCLOPAEDIA, op. cit., XI Vth edition, vol. XII, p. 120; Keith, A B:
ENGLISH CONSTITUTIONAL LAW (1931) p, 116.
12 Anson : THE LAW AND THE CUSTOU OF THE CONSTITUTION vol.1
(1935) p, 407.

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 808 INDIAN JOURNAL OF POLITICAL SCIENCE

bringing Ministers of the Crown to account for conduct opposed t

the welfare of the State".1'

The practice in America is the same as in England. In 1805,

Justice Chase of U.S. Supreme Court was charged with misdemea-
nours, i. e , for conducting himself 'ina manner highly arbitrary,
oppressive and unjusť, for disregarding his judicial functions etc. In
1862, Judge Humphreys was impeached, convicted and removed from
office for favouring the cause of the Confederacy. In 1868, President
Andrew Johnson was charged with 'high crimes,' 'misdemeanours',
'delivering harangues' making 'unconstitutional declarations' etc. He
vras no doubt acquitted, as had Justice Chase been earlier. But five
of the eleven articles charged him with the "violation of the Consti-
tution" an expression which occurs in our Constitution. Ben Butler,
oppearing on behalf of the prosecution said

"We define therefore, an impeachable high crime or misdemeanour to be

one in its nature or consequences subversive of Government or highly
prejudicial to the public interest and this may consist of a violation of
the Constitution, of law, of an official oath or of duty, but an act commi-
tted or omitted, of without violating a positive law, by the abuse of dis-
cretionary powers from improper motives, or for any improper
purpose".**

Again, in 1913, Judge Archibald of the Commerce Court was

removed by impeachment for soliciting for himself and friends
valuable favours from railroad companies while they were litigants
in his court. In 1936, Judge Ritter of Florida District Court was
removed for "want of integrity" though he was acquitted of the spe-
cific charges against him. Under such circumstances, it appears
beyond dispute that "high crimes and misdemeanours" include what
is called "lack of good behaviour" or "any act of willful misconduct
of any act which tends to put the office in disrepute", in the words of
Story, "for subverting Constitution and introducing arbitrary power".

13 Ridge's CONSTITUTIONAL LAW OF ENGLAND, 5th edition, p. 230.

14 Dewitt, DM.: THE IMPEACHMENT AND TRIAL OF ANDREW JOHNSON ,
Vol. I, p. 88; also Mclaughlin, Andrew C: A CONSTITUTIONAL HISTORY OF
THE UNITED STATES (1935), pp. 320-23, 669-675.

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 THE PRESIDENT OF INDIA - IMPEACHMENT 809

Whether an offence is impeachable or not is for the House of

Representatives to decide in the first instance, and for the Senate to
decide finally, and, as Corwin15 points out, "from this decision there
is no appeal". But Corwin, subscribing to the view of former Justice
R. Curtis Benjamin, who had acted as one of President Johnson's
counsels, holds the expression "high crimes and misdemeanours"
differently in another book of his16 to mean "offences against th
laws of the United States".

This is obviously not tenable. As T.M. Cooley17 remarks:

"Impeachment is for the purpose of punishing misconduct.. .it is often
found that offences ot a very serious nature, by high officer« are not
offences against the criminal court, but consists in abuses or betryals of
trust or inexecusible neglects of duty which are dangerous and criminal
because of the immense interest involved and the greatness of the trust,
which has not been kept. Such cases must be left to be dealt with on
their own facts and judged according to their apparent deserts".

As regards the use of impeachment for trying political offences,

Joseph Story writes clearly :

"Politicai offences are of so various and complex a character, so utterly

incapable of being defined or classified that the task of positive legisla-
tion would be impracticable, if it were not almost absured to attempt it
(S. 797)... Congress has unhesitatingly adopted ! the conclusion that
no previous statute is necessary to authorise an impeachment for any
official misconduct." (S. 799)

After mentioning several impeachable offences like malversations

and neglects in office, attempt to subvert the constitution and intr-
oduce aibitrary power etc. , Story concludes that
"One cannot but be struck in this slight enumeration with the utter
unfitness of the common tribunals of justice to take cognisance of such
offences and with the entire propriety of confiding the jurisdiction over
them to a tribunal capable of understanding and reforming and scruti-
nizing the polity of the state and of sufficient dignity to maintain the
independence and reputation worthy of public officers (S. 800)*'. 18

15 THE CONSTITUTION , What it Means Today (1948)

16 THE PRESIDENT , Office & Powers ( 1948)
17 Cooley, T,M. : THE GENERAL PRINCIPLES OF CONSTITUTIONAL LAW
(1931) pp. 204-205.
18 STORY ON THE CONSTITUTION (IV ed., 1873), Vol. I, pp. 561-566 : Also,
Willoughby, W.W.: PRINCIPALS OF CONSTITUTIONAL LAW OF THE UNITED
STATES (1930), p. 610.

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glo INDIAN JOURNAL OF POLITICAL SCIENCE

Munro's opinion that "General incompetence or bad judgement

of the unwise use of discretion" are not grounds for impeachment, is,
therefore, neither correct nor in consonance with the practice that
obtains either in England or in the U.S.A. As great an authority as
Hamilon wrote as early as 1 788 that the subjects of the jurisdiction
of the Court of Impeachment "are those offences which proceed from
the misconduct of public men or in other words, from the abuse or
violation of some public trust". They are of a nature which may with
peculiar propriety be denominated political "as they relate chiefly to
injuries done immediately to the society itself". This is still the last
word on impeachable offences.

Thus, Ambedkar's view expressed in the Constituent Assembly

that the phrase "violation of the Constitution" is quite comprehensive
and may will include "treason, bribery and other high crimes or mis-
demeanours" seems pertinent. Further, the grounds and proceedings
of impeachment that have occurred in England and the US, and the
expert opinions stated above, also lend weight to the view that the
connotation of "violation of the Constitution" is wide enough to
cover cases of trial of President on charges of bribery, corruption,
nepotism, favouritism, i.e., want of integrity, treason, felony, high
crimes or misdemeanours, malversations ; violation of an express
provision of the Constitution, of laws of the land, of official oath ;
on account of an act committed, or omitted, or -without violating a
positive law- by the abuse of discretionary powers from improper
motives or for improper purpose ; for subverting the constitution
and introducing arbitrary powers ; on account of an act of willful
misconduct or an act which tends to put the office in disrepute ; for
abuses or betrayals of public trust or inexecusable neglects of duty ;
and for political offences in so far as they relate chiefly to injuries
done immediately to the society itself, etc. Whether any such offence
is impeachable or not, it is to be decided in the first instance by either
House of Parliament which prefers the charge supported by a majority
of not less then two-thirds of its total membership, and for the other
House which investigates the charge or causes the charge to be in-
vestigated, to decide finally by a majority of not less then two-thirds

19 THEFEDERALIST (No. 65) Ed. by Max Beioff (1948), p. 334.

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 THE PRESIDENT OF INDIA - IMPEACHMENT 811

of its total membership ; and on this decision there is no appeal.

Whatever be the original intentions, where legislature is the judge,
the issue will be decided essentially on a political plane where party
considerations alone would count. We can expect that in India,
as perhaps elsewhere too, the whole business of impeachment would
really be a political affair rather than a regular trial in a court of law.

What is the object of impeachment of President under our Con-

stitution ? It can either be for punishing or for removing the Presi-
dent For want of a clear statement in the Constitution, the object
has to be inferred indirectly. The specific language of the Article in
the Constitution, and the instances of impeachent elsewhere, lead one
to think that the object of impeachment in India would generally be to
remove from office an obstructive President who is either disregarding
ministerial advice or is withholding assent from bill; under the circum-
stances the President must be removed immediately before further
damage is caused to the nation and the administration. If the
activities of political parties, which draw inspiration from foreign
lands, are taken into account the chances of impeaching a President
by way of punishment cannot entirely be ruled out in this country.

Loop-holes in the procedure of Impeachment

Is the procedure prescribed by our Constitution conducive to

this purpose ? Às has already been noted, the procedure involves the
following stages : (i) the charge may bé preferred by either House of
Parliament ; (ii) the proposal to prefer such a charge must be contai-
ned in a resolution to be moved after atleast fourteen days* notice in
writing of their intention to move the resolution ; (iii) the resolution
must be signed by not less than one-fourth of the total number of
members of the House ; (iv) the concerned House if not already in
session, to be summoned if for passing the resolution by a majority
of not less than two-thirds of the total membership of the House; (v)
the resolution then goes to the other House which shall investigate
the charge or cause the charge to be investigated and at this stage the
President has the right to appear and to be represented at such
investigation; (vi) the body investigating the charge will then deliver
its verdict; and finally, (vii) "If as a result of the investigation a

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812 INDIAN JOURNAL OF POLITICAL SCIENCE

resolution is passed by a majority of not less than two thirds of

total membership of the House by which the charge was investig
or caused to be investigated, declaring that the charge preferr
against the President has been sustained, such resolution shall have
the effect of removing the President from his office as from the date
on which the resolution is so passed."

Apparently, impeachment is not going to be a simple affair in

India. It is likely to involve long proceedings and may actually prove
ineffective in realising the objective. The Constitution expects the
President to submit himself to this process tamely after he has inten-
tionally and deliberately violated the same while the door is open
wide to him to adopt all possible ways to escape !

Under Art. 85 (i) (2) the President from time to time is to

summon each House of Parliament to meet at such time and place
as he thinks fit but six months shall not intervene between its last
sitting in one session and the date appointed for its first sitting in the
next Session. He may from time to time (a) prorogue the Houses
or either House (b) dissolve the House of the People.

So, when he finds that a move is afoot to impeach him, the Presi-
dent may just not summon the Houses for less than six months in the
first instance ; and if they are already in session, he may prorogue or
even dissolve the House of the People. He could thus cause
delay at the investigating stage also. Supposing that stage is
reached and a verdict given that the President is guilty but the
resolution declaring sustenance of .charge preferred against the
President is not passed by a majority of two-thirds of the total
membership of the House concerned. In the event, we will be
having a President in India, who is adjudged guilty by the investiga-
ting body but not removed from office because a resolution declaring
that the charge prefered against the President has been sustained, is
not passed by a majority of two-thirds of the total membership of
of the House concerned with investigation. Curiously, such an
awkward situation was not visualized by the Founding Fathers.

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 THE PRESIDENT OF INDIA - IMPEACHMENT 813

Moreover, it will not be easy in practice to obtain two-thirds m

against the President.20 The person to hold the office of the P
would be a man of considerable following. If this were not
could not be elected by the members of a rather large electoral
college such as has been provided by our Constitution. It is quite
conceivable that President elected by the college will easily be in a
position to command the support of a little more than one-third
majority of the total membership at least in one House of Parliament.
One wonders as to why the second House is brought into the picture
at all to pass another resolution with two-third majority when the
investigation is over and guilt has been adjudged. It is here that
the Founding Fathers seem to have erred and made the procedure
of impeachment of our President somewhat strange, if not virtually
ridiculous. How could they make a legal matter investigated by a
judicial body to be decided by a political jury?21 Hamilton was
aware of the possible degeneration of an essenially legal matter
into a political issue and realised the "greatest danger that the
decision shall be regulated more by the comparative strength of
parties than by the mere demonstration of innocence or guilt".22

Thus it is clear that impeachment of President under our Consti-

tution is, to use the words of a serious student of Indian political

20 Impeachment of American Presiden» Johnson, 1868, in Munro : CONSTITU-

TION OF THE UNITED STATES , op. cit.t p. 16.

Interestingly enough all the charges against him were of a political nature and
could not bs carried through because of just one vote in the Congress. In the
Indian context, consider the enormous difficulties bound to be encountered if a
Nehru, a Patel or a Rajendra Prasad -all of the same party, and with deep roots
and a wide following there- get under impeachment. If it is remembered that
Rajendra Prasad was elected President of the Constituent Assembly and later of
the country allegedly against the wishes of Nehru, the leader of the Congress Le-
gislative Party, who wanted C Rajagopalachari for these positions, the difficulties
in impeaching Prasad become still more sharply prominent : a Prime Minister in
such a situation of a divided party maj well not succeed in mustering the iequisite
two-thirds majority of the total membership of Parliament.
21 Rao, K V : PARLIAMENTRY DEMOCRACY OF INDIA (1961) p. 43.
22 FEDERALIST No. 65, op. cit .

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814 INDIAN JOURNAL OF POLITICAL SCIENCE

system,18 "a slow and cumbersome process to be used onl

desperate expedient, absolutely ineffective in achieving the objec
and definitely impossible to use".

Suggestions fer Improvement

In order that the process of impeachment of president under

Constitution be effective, the following changes in the proce
may be suggested : (i) A notice of Impeachment, if signed b
majority of members of any House, shall have the automatic e
of summoning that House to meet only for that purpose ; (ii
House shall be in continuous session till the proceedings are comp
and the President shall not have the power to exercise his pow
dissolution, etc.; (iii) The passing of the resolution in this H
shall mean the automatic summoning of the other House and
it will be in continuous session free from the President; and (iv)
House shall appoint a Committee of its own members, elected
proportional basis with the Chief Justice of India as Chairman and
its verdict shall be final if decided by 2/3 majority"."

An impeachment is not like a Vote of no-confidence, which

involves no disgrace or imputation of moral turpitude but only the
disapproval of the Government's policy. If the President is con-
victed on a motion of impeachment, it will practically lead to the
ruination of his political career. Though the President will not be
impeached frequently, he will always work under the sword of
of Damocles hanging over his head. During a decade or two the
President, the Lok Sabha and the nation will certainly remain fully
conscious of this sword. But with the passage of time and the
growth of democratic usages this awareness is likely to fade away
from public memory. Impeachment will then fare the same fate in
India as it has done in Great Britain. The President, like the Queen
in England, will be the symbol of national unity, the fulcrum of our
political and social activities, theoretically vested with multitude of
powers but actually exercising only a few of them, and those too,
very rarely and invariably in accordance with the Constitution.
23 Rao, op. cit.. p. 43.
24 Ibid, p. 44.

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