PROTECTION OF PERSONAL LIBERTY UNDER ARTICLE 21

ABSTRACT

This article provides an in-depth analysis of the protection of personal liberty under Article 21 of the Indian Constitution, which asserts that “No person shall be deprived of his life or personal liberty except according to procedure established by law.” Originally limited in scope, the interpretation of Article 21 has been vastly expanded by judicial rulings, transforming it into a dynamic provision that now encompasses a range of rights integral to individual autonomy and dignity. Through landmark cases, such as Maneka Gandhi v. Union of India and Puttaswamy v. Union of India, the Indian judiciary has broadened the meaning of personal liberty to include the right to privacy, freedom from arbitrary detention, a fair and speedy trial, health, and dignified living. This article explores these judicial interpretations and their impact on citizens’ lives, emphasizing the judiciary’s role in protecting individual freedoms against excessive state action. It also examines the challenges to personal liberty, especially with recent legislative developments and surveillance concerns, which test the balance between individual rights and state interests. Through a critical examination, the article argues that Article 21 stands as a powerful safeguard for personal freedom, reinforcing the principles of justice, equality, and democracy in India’s constitutional framework. Ultimately, this analysis underscores the ongoing relevance of Article 21 in shaping a society where the protection of personal liberty is fundamental, urging continuous vigilance and adaptation to uphold the democratic values it embodies.

Keywords

Article 21, Personal liberty, Right to life, Indian Constitution, Judicial interpretation, Fundamental rights, Maneka Gandhi Judgement, Puttaswamy Judgement, Human dignity, Supreme Court of India, Constitutional law.

INTRODUCTION

The protection of personal liberty is a cornerstone of democratic societies, serving as a foundation for individual rights and freedoms. Article 21[1] of the Indian Constitution, which provides that “No person shall be deprived of his life or personal liberty except according to procedure established by law,” enshrines this right as one of the most fundamental protections for citizens. Initially, Article 21’s scope was narrowly defined, emphasizing procedural safeguards rather than substantive freedoms. However, through years of judicial activism and progressive interpretation, Article 21 has expanded to include a comprehensive array of rights vital to human dignity and autonomy. The significance of Article 21 extends beyond mere protection against arbitrary deprivation of life or liberty; it has become a dynamic provision that upholds principles of justice, fairness, and equality, embodying the spirit of the Indian Constitution. The expansion of Article 21 began with the Supreme Court’s landmark decision in Maneka Gandhi v. Union of India (1978), where the Court recognized that “personal liberty” entails a broad interpretation that encompasses essential freedoms necessary for living a life with dignity. This judgment transformed Article 21 from a limited procedural right into a gateway for numerous rights, such as the right to privacy, health, livelihood, and education. Subsequent cases have further reinforced this inclusive view, making Article 21 one of the most interpreted and evolving provisions within the Indian legal framework. Notably, in the Puttaswamy v. Union of India (2017) decision, the Supreme Court declared the right to privacy as intrinsic to personal liberty, marking a significant milestone in the protection of individual freedoms in the digital age.

The evolution of Article 21 highlights the judiciary’s role in balancing personal liberty with state interests. The Court has frequently acted as a guardian of individual freedoms, intervening when state actions or legislation threaten to infringe upon the rights guaranteed by Article 21. For instance, the principle of “procedure established by law”[2] has been interpreted to mean that laws restricting personal liberty must not only follow due process but must also be fair, just, and reasonable. This principle has set a high standard for legislative and executive actions, ensuring that personal liberty cannot be arbitrarily curtailed. In recent years, the scope of Article 21 has come under renewed focus as emerging issues like data privacy, digital surveillance, preventive detention, and anti-terrorism laws raise questions about the extent of personal liberty. This article explores the vast expanse of Article 21, tracing its journey from a basic procedural guarantee to a constitutional provision that encompasses the essential components of human life and dignity. It examines the key judicial interpretations that have shaped Article 21, scrutinizes contemporary challenges to personal liberty, and considers the future trajectory of Article 21 in light of ongoing social, political, and technological changes. By delving into the complexities of Article 21, the article aims to shed light on the importance of safeguarding personal liberty as a fundamental right in India’s democratic framework, while emphasizing the judiciary’s crucial role in adapting these protections to the evolving needs of society.

BACKGROUND AND SCOPE OF ARTICLE 21

Article 21 of the Indian Constitution reads, “No person shall be deprived of his life or personal liberty except according to procedure established by law.” This seemingly straightforward provision carries profound implications for individual rights in India. Originally, Article 21 was viewed as a procedural safeguard, intended to protect individuals from state actions that could threaten life or personal liberty without lawful justification. This narrow view was influenced by the framers’ cautious approach toward individual freedoms in a newly independent India, where the need to establish order and prevent potential misuse of freedom was prioritized.

Initially, Article 21 was interpreted strictly, focusing on “procedure established by law” as a means of ensuring that state actions followed lawful processes, regardless of the substantive justice or fairness of the law itself. This narrow approach, exemplified in the early case A.K. Gopalan v. State of Madras (1950)[3], essentially limited Article 21 to procedural due process, allowing state actions as long as they followed the established legal procedure, even if that procedure was unfair or arbitrary. This interpretation was criticized for failing to protect individuals from potential misuse of state power, as it allowed any law to curtail personal liberty as long as procedural formalities were met. The scope of Article 21 began to expand significantly with the landmark case Maneka Gandhi v. Union of India (1978)[4]. In this case, the Supreme Court redefined the meaning of “procedure established by law” to include a requirement that the law be fair, just, and reasonable. The Court ruled that Article 21 cannot be isolated from other fundamental rights and established that the procedure depriving someone of liberty or life must align with principles of natural justice. This transformative interpretation shifted Article 21 from a narrow procedural right to a broader constitutional safeguard encompassing substantive due process, effectively linking it with Articles 14 (right to equality) and 19 (freedom of speech and expression).

With the Maneka Gandhi judgment, the Supreme Court set the precedent for future interpretations that recognized numerous rights under the scope of Article 21. This shift marked the beginning of an era where Article 21 was seen as a “right to dignified life,” embodying all rights essential to human dignity, autonomy, and a meaningful existence. Judicial interpretation over the years has further expanded Article 21 to include rights such as the right to health, the right to privacy, the right to a fair trial, the right to education, and the right to a clean environment, among others.

The inclusion of such rights underscores the view that the “right to life” is not merely about physical survival but about living a life with dignity, as highlighted in cases like Francis Coralie Mullin v. Union Territory of Delhi (1981)[5] and Bandhua Mukti Morcha v. Union of India (1984)[6]. In Francis Coralie Mullin, the Court held that the right to life under Article 21 includes the right to live with human dignity, which encompasses basic necessities of life such as adequate nutrition, clothing, shelter, and facilities for reading and writing. This view expanded Article 21 to embrace socio-economic rights essential to the well-being of individuals.

More recently, the scope of Article 21 has evolved to address the complexities of modern society, particularly with the landmark decision in Justice K.S. Puttaswamy v. Union of India (2017)[7], where the Supreme Court recognized the right to privacy as a fundamental right under Article 21. This case was significant not only for recognizing privacy as intrinsic to personal liberty but also for affirming Article 21’s adaptability to contemporary challenges, especially in the digital age. The progressive evolution of Article 21 underscores its critical role in India’s constitutional framework as a living provision that continuously adapts to the changing needs of society. The judiciary has interpreted Article 21 to go beyond mere procedural protection, transforming it into a robust guarantee of substantive rights essential to a dignified life. In doing so, Article 21 has become a foundational element of the Indian Constitution, embodying the principles of fairness, justice, and respect for individual autonomy in a democratic society.

THE GOLDEN TRIANGLE CONCEPT

The Supreme Court has recognized that Articles 14, 19, and 21 are interconnected and must be read together to protect the essence of fundamental rights. This interlinking, referred to as the “Golden Triangle” creates a comprehensive safeguard for individual rights, as each article reinforces the others. For instance, Article 21’s protection of life and personal liberty would be incomplete without the equality guaranteed by Article 14 or the freedoms assured by Article 19. Together, they enable citizens to live with dignity, exercise their rights freely, and ensure fair treatment under the law.

1. Article 14: Right to Equality

Article 14 guarantees the right to equality before the law and equal protection of laws to every individual within the territory of India. It mandates that no person should be discriminated against or treated arbitrarily by the state. The judiciary has interpreted Article 14 not merely as formal equality but also as requiring substantive equality, demanding fairness and justice in both lawmaking and its application.

2. Article 19: Freedom of Expression and Movement

Article 19 enshrines several freedoms, including the freedom of speech and expression, the right to assemble peacefully, the freedom to form associations, the freedom to move freely throughout the country, and the right to practice any profession. These freedoms are essential for individual autonomy and play a central role in ensuring a democratic society. However, Article 19 also allows for reasonable restrictions, meaning that while freedoms are protected, they are subject to regulation for broader public interest.

3. Article 21: Right to Life and Personal Liberty

Article 21, one of the most important articles, ensures that “no person shall be deprived of his life or personal liberty except according to procedure established by law.” Initially interpreted narrowly, the Supreme Court has, over time, expanded its scope to include various dimensions of life and liberty, such as the right to live with dignity, the right to privacy, and the right to education.

LANDMARK JUDGEMENTS

Maneka Gandhi v. Union of India: Overview

Background: Maneka Gandhi, a journalist and activist, had her passport impounded by the Indian government under the Passport Act, 1967[8], without a proper hearing or explanation. This action was taken “in the interest of the general public.” Gandhi challenged this decision, arguing that it violated her fundamental rights under Articles 14 (right to equality)[9], 19 (freedom of speech and movement)[10], and 21 (protection of life and personal liberty) of the Indian Constitution.

Key Legal Issues:

1. Whether the impounding of her passport constituted a violation of her personal liberty under Article 21.

2. Whether “procedure established by law” in Article 21 required the procedure to be fair, just, and reasonable.

3. Whether Article 21 should be interpreted in conjunction with Articles 14 and 19.

Supreme Court Ruling: The Supreme Court delivered a landmark judgment with several critical findings:

1. Expansion of Article 21: The Court ruled that “procedure established by law” must be fair, just, and reasonable. This broadened the scope of Article 21, ensuring that personal liberty cannot be curtailed by arbitrary or oppressive laws.

2. Linking with Other Rights: The Court held that Article 21 is interconnected with Articles 14 and 19. Any law depriving personal liberty must also respect the principles of equality and freedom guaranteed by these articles.

3. Principle of Natural Justice: The Court emphasized the necessity of adhering to natural justice principles, asserting that individuals must be given a fair opportunity to defend themselves against state actions.

Significance: The Maneka Gandhi judgment significantly transformed the interpretation of Article 21 from a procedural safeguard to a robust protection of substantive rights. It established that personal liberty is a fundamental aspect of human dignity and laid the groundwork for future interpretations that include various rights essential for a dignified life, such as the right to privacy and the right to health. This case is pivotal in Indian constitutional law, reinforcing the judiciary’s role in protecting individual freedoms against arbitrary state action.

Justice K.S. Puttaswamy v. Union of India: Overview

Background: Justice K.S. Puttaswamy, a retired High Court judge, challenged the constitutional validity of the Aadhaar scheme, implemented by the Indian government. He argued that the mandatory linking of Aadhaar numbers to various services and benefits violated the right to privacy, which he contended was an intrinsic part of the right to life and personal liberty under Article 21 of the Indian Constitution.

Key Legal Issues:

1. Whether the right to privacy is a fundamental right protected under the Constitution of India.

2. Whether the Aadhaar scheme, which requires individuals to provide biometric data, infringes upon this right.

3. The extent to which the state can impose restrictions on personal liberty in the context of privacy.

Supreme Court Ruling: The Supreme Court delivered a unanimous verdict with significant findings:

1. Recognition of the Right to Privacy: The Court declared that the right to privacy is a fundamental right guaranteed under Article 21 of the Constitution. This landmark ruling established privacy as an integral component of personal liberty, affirming that individuals have a right to control their personal information and make autonomous choices.

2. Aadhaar and Personal Liberty: The Court held that while the state has an interest in collecting data for welfare programs, any intrusion upon individual privacy must meet the standards of legality, necessity, and proportionality. The judgment emphasized that individuals must have the right to choose whether to share their biometric data, and that the Aadhaar scheme must not be mandatory for accessing essential services.

3. Limitations on State Power: The ruling underscored the need for a proper legal framework to govern data collection and surveillance, emphasizing that state power must always be exercised within the bounds of fundamental rights.

Significance: The Puttaswamy judgment is a landmark ruling that fundamentally reshaped the legal landscape regarding privacy rights in India. By recognizing the right to privacy as a fundamental right, the Supreme Court strengthened the protection of personal liberty under Article 21. This case set a precedent for future legal challenges related to data privacy, surveillance, and individual autonomy, marking a critical turning point in the recognition of personal freedoms in the context of modern technology and governance. The decision has significant implications for the ongoing discourse surrounding individual rights in an increasingly digital world.

COMPONENTS OF PERSONAL LIBERTY UNDER ARTICLE 21

Over the years, judicial interpretations have expanded the meaning of “personal liberty” to encompass a broad range of rights essential for a dignified life. Here are the key components of personal liberty under Article 21:

1. Right to Privacy

The landmark ruling in Justice K.S. Puttaswamy v. Union of India (2017) recognized the right to privacy as a fundamental right under Article 21. This right encompasses an individual’s autonomy in controlling personal information, making choices regarding personal relationships, and living without unwarranted interference from the state. The recognition of privacy as a component of personal liberty underscores the importance of individual dignity and freedom in a democratic society.

2. Right to Life with Dignity

Judicial interpretations have established that the right to life under Article 21 includes the right to live with dignity. The Supreme Court in Francis Coralie Mullin v. Union Territory of Delhi (1981) asserted that this right encompasses the provision of basic necessities such as adequate food, clothing, and shelter, as well as access to healthcare and a clean environment. The emphasis on dignity reflects the understanding that mere existence is insufficient; individuals should have the means to lead a fulfilling life.

3. Right to Health

The right to health has been recognized as an essential component of the right to life. In cases such as Paschim Banga Khet Mazdoor Samity v. State of West Bengal (1996)[11], the Supreme Court ruled that the government has an obligation to provide adequate healthcare services to ensure the well-being of its citizens. This right obliges the state to create a conducive environment for good health and access to medical care.

4. Right to Livelihood

The Supreme Court, in Olga Tellis v. Bombay Municipal Corporation (1985)[12], held that the right to livelihood is integral to the right to life. The judgment established that deprivation of livelihood could amount to a violation of Article 21, as it affects an individual’s ability to support themselves and their family. This right emphasizes the connection between economic security and personal liberty.

5. Right to Education

The right to education is also considered a fundamental right derived from Article 21. The Supreme Court recognized this right in Mohini Jain v. State of Karnataka (1992)[13], ruling that access to education is essential for individual development and empowerment. Subsequently, the Right of Children to Free and Compulsory Education Act (2009)[14] established education as a fundamental right for children aged 6 to 14 years.

6. Right to a Fair Trial

The right to a fair trial is an essential aspect of personal liberty under Article 21. This includes the right to legal representation, the right to be heard, and the right to be presumed innocent until proven guilty. The judiciary has emphasized the importance of ensuring that legal proceedings uphold the principles of justice and fairness, preventing arbitrary detention and unjust treatment.

7. Protection Against Arbitrary Detention

Article 21 provides a safeguard against arbitrary detention by requiring that any deprivation of personal liberty must be conducted according to a fair and just legal process. This means that preventive detention laws must be applied judiciously and cannot be used to circumvent the fundamental rights of individuals.

CHALLENGES TO PERSONAL LIBERTY AND STATE INTERVENTION

While Article 21 of the Indian Constitution serves as a robust safeguard for personal liberty, several challenges arise from state intervention that can infringe upon these rights. These challenges reflect the tension between individual freedoms and the state’s responsibilities to maintain order, security, and public welfare. Key challenges to personal liberty include:

1. Arbitrary Detention and Preventive Detention Laws

One of the most significant challenges to personal liberty is the potential for arbitrary detention by the state. Preventive detention laws allow authorities to detain individuals without trial under the pretext of maintaining public order or preventing crime. Although the Constitution provides for preventive detention, it is subject to strict safeguards; in practice, these safeguards are often circumvented, leading to misuse of power. Cases of wrongful detention without adequate justification highlight the need for rigorous checks to prevent violations of Article 21.

2. Surveillance and Privacy Invasion

In the digital age, state surveillance has become a pressing concern that poses a direct threat to personal liberty. Government initiatives, such as the Aadhaar project, raise issues of data privacy and individual autonomy. The collection and storage of biometric data without stringent data protection measures can lead to unauthorized surveillance and misuse of personal information. The lack of comprehensive data protection laws exacerbates these challenges, making individuals vulnerable to violations of their privacy rights.

3. Legislative Overreach

State intervention can also manifest through legislation that limits individual freedoms. Laws aimed at national security, public morality, or social order may inadvertently infringe on personal liberty. For instance, laws regulating freedom of speech and expression can suppress dissent and curtail the right to criticize the government. While the state may argue such measures are necessary for public order, they can be misused to silence legitimate voices, thereby undermining democratic principles.

4. Social and Economic Inequalities

Personal liberty is often compromised for marginalized communities due to systemic social and economic inequalities. Discrimination based on caste, religion, gender, or economic status can lead to arbitrary state actions, such as police brutality or exclusion from welfare programs. These inequities create a disparity in the protection of rights, making it difficult for vulnerable groups to assert their personal liberties effectively.

5. Law Enforcement Practices

Abusive practices by law enforcement agencies, such as custodial violence and extrajudicial killings, pose significant threats to personal liberty. Instances of police misconduct, including torture and harassment, undermine the legal protections guaranteed under Article 21. Such practices often go unpunished, creating an environment of fear and mistrust between citizens and the state.

6. Judicial Delays and Access to Justice

The effectiveness of Article 21 in safeguarding personal liberty is hampered by delays in the judicial system. Prolonged legal proceedings can lead to individuals being incarcerated for extended periods without a fair trial, effectively infringing upon their right to life and personal liberty. Access to legal representation and justice remains a significant challenge, particularly for economically disadvantaged individuals who may lack the resources to navigate the legal system.

FUTURE OF ARTICLE 21: ADAPTING TO EMERGING CHALLENGES

As new issues arise, Article 21 must adapt to ensure that personal liberties are safeguarded while balancing the state’s responsibilities. Key areas of adaptation include:

1. Digital Privacy and Data Protection

With the rapid advancement of technology and the proliferation of digital data, the right to privacy has become a significant concern. The Supreme Court’s recognition of privacy as a fundamental right in the Puttaswamy case highlights the need for comprehensive data protection laws. Future adaptations of Article 21 will likely involve establishing robust frameworks to protect individuals from unauthorized surveillance and data breaches, ensuring that personal information is handled with transparency and consent.

2. Addressing Technological Surveillance

As governments increasingly deploy surveillance technologies, such as facial recognition and AI-based monitoring systems, the potential for abuse poses a challenge to personal liberty. Article 21 will need to evolve to incorporate safeguards against invasive state surveillance practices. Legislative measures and judicial oversight will be essential to ensure that technological advancements do not infringe upon the fundamental rights of citizens.

3. Rights of Marginalized Communities

Article 21 must adapt to address the unique challenges faced by marginalized and vulnerable communities. Ensuring equitable access to justice and safeguarding their rights against discrimination will be crucial. The future of Article 21 may involve enhancing legal protections and affirmative action measures that specifically target systemic inequalities, thus promoting a more inclusive interpretation of personal liberty.

4. Balancing National Security and Personal Liberty

In an era marked by global threats, the state’s interest in national security can sometimes conflict with individual freedoms. Article 21 must adapt to delineate clear boundaries on how far the state can intervene in personal liberties under the guise of security. Legislative frameworks should ensure that any restrictions imposed in the name of security are necessary, proportionate, and subject to judicial review.

5. Access to Justice and Judicial Reforms

Delays and access issues within the judicial system continue to hinder the effective enforcement of Article 21. The future will necessitate reforms aimed at expediting judicial processes and improving access to legal representation for all citizens, particularly for economically disadvantaged groups. Strengthening legal aid services and promoting alternative dispute resolution mechanisms can help ensure that personal liberties are upheld in practice.

6. Environmental Rights and Personal Liberty

As climate change and environmental degradation increasingly affect human lives, there is a growing recognition that the right to a healthy environment is linked to the right to life under Article 21. Future interpretations may expand Article 21 to encompass environmental rights, ensuring that individuals can live in a safe and sustainable environment. This shift may require stronger legal frameworks for environmental protection and accountability for polluters.

CONCLUSION

The article on the “Protection of Personal Liberty under Article 21” explores the fundamental significance of this constitutional provision in safeguarding individual rights in India. Article 21, which guarantees that no person shall be deprived of life or personal liberty except according to the procedure established by law, has been pivotal in shaping the landscape of personal freedoms through progressive judicial interpretations. Landmark cases like Maneka Gandhi v. Union of India and Justice K.S. Puttaswamy v. Union of India have expanded the scope of personal liberty to include various rights such as privacy, dignity, health, and education, emphasizing that personal liberty extends beyond mere existence to encompass a dignified and meaningful life. However, the article also highlights the myriad challenges that threaten these liberties, including arbitrary detention, invasive state surveillance, and socio-economic inequalities that disproportionately affect marginalized communities. As technology evolves and societal norms shift, it is crucial for Article 21 to adapt to emerging challenges, ensuring robust protections against state overreach.

The future of personal liberty under Article 21 hinges on the collective responsibility of the judiciary, legislature, and civil society to uphold and reinforce these rights. A proactive approach to legislation, vigilant judicial oversight, and an engaged citizenry are vital to protect personal liberties and ensure that every individual in India can exercise their rights freely and live with dignity. The ongoing dialogue surrounding Article 21 will be essential in fortifying the foundations of democracy and ensuring that the promise of personal liberty remains a lived reality for all citizens.

The continued commitment to upholding Article 21 demands vigilance from all arms of the government and civil society. Lawmakers must craft policies that are in harmony with the core values of liberty and dignity, while courts should remain proactive in defending these rights. As global influences and technological advancements bring new challenges to personal liberty, Article 21 must serve as a living testament to India’s dedication to human rights, ensuring that every individual’s freedom is both respected and protected, now and in the future. In essence, Article 21 stands not only as a constitutional mandate but as a profound reminder of the intrinsic value of human dignity and freedom in a democratic society.

REFERENCES

[1] INDIAN CONST. art. 21, amended by The Constitution (One Hundred and Fourth Amendment) Act, 2019.

[2] IPLEADERS, https://blog.ipleaders.in/procedure-established-by-law/, (last visited Oct 30, 2024).

[3] A.K. Gopalan v. State of Madras, 1950 AIR 27, 1950 SCR 88, AIR 1950 SUPREME COURT 27, 1963 MADLW 638.

[4] Maneka Gandhi v. Union of India, 1978 AIR 597, 1978 SCR (2) 621.

[5] Francis Coralie Mullin v. Union Territory of Delhi, 1981 AIR 746, 1981 SCR (2) 516, AIR 1981 SUPREME COURT 746, 1981 (1) SCC 608, 1981 (2) SCR 516, 1981 CRIAPPR(SC) 112, 1981 SCC(CRI) 212, (1981) MAD LJ(CRI) 331, (1981) 2 SCJ 18, (1981) 19 DLT 271, 1981 CRI. L. J. 306, (1981) 2 SCR 516 (SC) 1981 CRILR(SC MAH GUJ) 437, 1981 CRILR(SC MAH GUJ) 437.

[6] Bandhua Mukti Morcha v. Union of India, 1984 AIR 802, 1984 SCR (2) 67, AIR 1984 SUPREME COURT 802, 1984 LAB. I. C. 560, 1984 SCC (L&S) 389, (1984) 2 LAB LN 60, 1984 (3) SCC 161.

[7] Justice K.S. Puttaswamy (Retd.) v. Union of India, (2017) 10 SCC 1, AIR 2017 SC 4161.

[8] The Passport Act, 1967, No. 15, Act of Parliament, 1967 (India).

[9] INDIAN CONST. art. 14, amended by The Constitution (One Hundred and Fourth Amendment) Act, 2019.

[10] INDIAN CONST. art. 19, amended by The Constitution (One Hundred and Fourth Amendment) Act, 2019.

[11] Paschim Banga Khet Mazdoor Samity v. State of West Bengal, 1996 AIR SC 2426/ (1996) 4 SCC 37.

[12] Olga Tellis v. Bombay Municipal Corporation, 1986 AIR 180, 1985 SCR SUPL. (2) 51, AIR 1986 SUPREME COURT 180, 1986 CRILR(SC&MP) 23, 1985 (3) SCC 545, (1985) 2 BOM CR 434.

[13] Mohini Jain v. State of Karnataka, 1992 AIR 1858, 1992 SCR (3) 658, AIR 1992 SUPREME COURT 1858, 1992 AIR SCW 2100, 1992 (2) UJ (SC) 331, 1992 (2) UPLBEC 1198, (1992) 4 JT 292 (SC), (1992) 3 SCR 658 (SC), 1992 (3) SCC 666, (1993) 1 SCT 377, (1992) 3 SCJ 152, (1992) 5 SERVLR 1, (1992) 2 UPLBEC 1198, (1992) 2 APLJ 22.

[14] The Right of Children to Free and Compulsory Education Act 2009, No. 35, Act of Parliament, 2009 (India).

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