Case Summary: SR Bommai v. Union of India

• Case Title: SR Bommai v. Union of India
• Citation: AIR 1994 SC 1918, (1994) 3 SCC 1
• Court: Supreme Court of India
• Bench: Nine-judge Constitution Bench led by Chief Justice M.N. Venkatachaliah
• Date of Judgment: March 11, 1994
• Relevant Provisions: Articles 356, 352, and 365 of the Constitution of India

Brief Facts:

The central government dismissed several state governments by imposing President’s Rule under Article 356 of the Constitution. The dismissed governments challenged these actions, claiming they were politically motivated and lacked sufficient grounds. The Supreme Court took up the matter to determine the scope of Article 356 and whether its use could be reviewed by courts.

Issues:

• Is the imposition of President’s Rule under Article 356 subject to judicial review?
• What limitations exist on the central government’s power to dismiss elected state governments?
• How does Article 356 interact with India’s federal structure and democratic principles?

Arguments:

Petitioners argued that Article 356 should not be used arbitrarily and must be exercised based on clear evidence of governance failure. They maintained that the central government’s actions needed to be checked by the judiciary to protect federalism and democracy.

The Union government contended it had the authority and discretion to impose President’s Rule whenever the state machinery fails or governance breaks down.

Judgment:

The Supreme Court held that the use of Article 356 is subject to judicial review, meaning courts can examine whether its invocation was justified. The Court ruled that the central government’s power to dismiss a state government is not absolute and must be based on relevant material demonstrating a failure of constitutional machinery. Arbitrary or mala fide dismissals are unconstitutional. The judgment reinforced the federal nature of India’s political system by protecting states from unjustified central intervention.

Ratio Decidendi:

Article 356’s imposition of President’s Rule must be backed by valid, relevant material proving the failure of governance in the state and can be reviewed by courts to prevent misuse.

Obiter Dicta:

The Court emphasized that the judiciary plays a key role in maintaining the balance between the Centre and states, ensuring democracy is not undermined by political misuse of Article 356.

Final Decision:

The judgment restricted the scope of central power under Article 356, making its use justiciable and protecting the autonomy of state governments as an essential part of India’s federal democracy.