Background of the Case: S. R. Bommai v. Union of India is a landmark case that deals with the issue of misuse of Article 356 of the Indian Constitution, which empowers the President to impose President’s Rule (central rule) in a state on grounds of failure of constitutional machinery. The case originated from the dismissal of the state government of Karnataka by the central government under Article 356 in 1989. The dismissed Chief Minister, S. R. Bommai, challenged the imposition of President’s Rule, contending that it was unconstitutional and amounted to a violation of federal principles.
Key Issues Raised:
Whether the power of the President to impose President’s Rule under Article 356 of the Indian Constitution is subject to judicial review?
Whether the exercise of discretion by the central government in invoking Article 356 is subject to certain constitutional limitations?
Whether the imposition of President’s Rule in a state can be challenged on grounds of political partisanship or mala fides (bad faith) by the central government?
Arguments from Both Sides:
S. R. Bommai: He argued that the central government’s decision to impose President’s Rule in Karnataka was politically motivated and violated the principles of federalism and democracy. He contended that Article 356 should be exercised sensibly and only in cases of actual breakdown of constitutional machinery, as determined by objective criteria.
Union of India: The central government defended its decision to impose President’s Rule, asserting that it was justified due to the breakdown of law and order and political instability in Karnataka. It argued that the imposition of central rule was a discretionary power of the President, and the central government’s actions were immune from judicial review.
Judgement: In 1994, the Supreme Court of India delivered a landmark judgement in S. R. Bommai v. Union of India, significantly restricting the discretionary power of the central government to impose President’s Rule under Article 356. The court held that the imposition of President’s Rule was subject to judicial review and could be struck down if found to be mala fide, arbitrary, or based on irrelevant grounds. The court laid down specific guidelines and principles to determine the validity of invoking Article 356, emphasizing the need for objective assessment and compliance with constitutional norms.
The judgement also affirmed the principles of federalism and parliamentary democracy, holding that state governments should not be dismissed or destabilized for political reasons. It established the supremacy of the Constitution and the rule of law over executive discretion, thereby enhancing the accountability of the central government in its dealings with the states.
Significance: S. R. Bommai v. Union of India is a landmark case that strengthened the principles of federalism, democracy, and the rule of law in India. The judgement significantly curtailed the arbitrary use of Article 356 by the central government and provided greater protection to state governments against undue interference. It underscored the importance of constitutional safeguards and judicial review in upholding the integrity of democratic institutions and maintaining the balance of power between the center and the states. The case remains a precedent in Indian constitutional law, shaping the relationship between the union and the states and reinforcing the principles of cooperative federalism.