S.R. Bommai vs. Union of India| AIR 1994 SC 1918| Case Summary|

S.R. Bommai vs. Union of India

AIR 1994 SC 1918

(From: AIR 1990 Karnataka 5 (FB))

|Presidential Rule, Judicial Review, Federalism, State Government, Dismissal|

CASE SUMMARY

Facts:

The case arose out of the dismissal of the Janata Dal government in Karnataka in 1989 by the then Governor, Rameshwar Thakur, on grounds of loss of majority. The dismissal was followed by the imposition of President's Rule under Article 356 of the Constitution. The state government challenged the dismissal and imposition of President's Rule in the Supreme Court.

Issues:

1. Scope of Article 356: The Court had to determine the circumstances under which Article 356 could be invoked and whether the dismissal of the state government was justified.

2. Judicial Review: The Court had to decide whether the President's decision under Article 356 was subject to judicial review and, if so, to what extent.

3. Federalism: The case involved questions of federalism and the relationship between the Centre and the States.

   
   

Relevant Articles:

Article 356: This article empowers the President to impose President's Rule in a state if the Governor reports that the government of the state cannot be carried on in accordance with the provisions of the Constitution.

Article 74: This article deals with the Council of Ministers and provides that the President shall act in accordance with the advice of the Council of Ministers.

Judgment:

The Supreme Court in S.R. Bommai v. Union of India held that the President's decision under Article 356 of the Constitution, which allows for the imposition of President's Rule in a state, is subject to judicial review. This means that the Court can examine whether the conditions precedent to the issuance of the Proclamation have been satisfied and whether the decision was taken in good faith and on relevant considerations.

The Court laid down guidelines for the exercise of power under Article 356. It emphasized that the power should be used only in exceptional circumstances and not as a tool for political gain. The decision to impose President's Rule should be based on objective evidence and not on subjective satisfaction. The Court also reaffirmed the principles of federalism, stressing the importance of maintaining a balance between the Centre and the States. It held that the Centre cannot interfere with the internal affairs of a state unless there is a breakdown of constitutional machinery.

In essence, the judgment in S.R. Bommai v. Union of India strengthened the position of state governments and limited the arbitrary use of Article 356. It also reaffirmed the principles of judicial review and the role of the courts in upholding the Constitution. The case has had a significant impact on Indian federalism and has served as a precedent for future cases involving the imposition of President's Rule.