Indira Gandhi v. Raj Narain is a landmark judgment of the Supreme Court of India that was delivered in 1975. The case arose out of a challenge to the election of Indira Gandhi, the then Prime Minister of India, to the Lok Sabha (the lower house of the Parliament) from the Rae Bareli constituency in 1971. The appellant, Raj Narain, contested the election as an independent candidate and challenged the validity of Indira Gandhi’s election on the grounds that she had used the office of the Prime Minister to influence the election process and had violated the provisions of the Representation of the People Act, 1951.
The Supreme Court, in its judgment, upheld the challenge and declared the election of Indira Gandhi to be void. The Court observed that Indira Gandhi had used the government machinery to her advantage during the election campaign and had violated the provisions of the Representation of the People Act. The Court also imposed a ban on Indira Gandhi from contesting any election for a period of six years.
The judgment of the Supreme Court in the Indira Gandhi case was a significant development in the Indian constitutional law, as it established the principle that the office of the Prime Minister is subject to the rule of law and that no person, irrespective of their position, is above the law. It also reaffirmed the independence and impartiality of the judiciary and the principle of the rule of law.
The Indira Gandhi case was also significant in the context of the Doctrine of Basic Structure, which is a judicial doctrine that limits the power of the Parliament to amend the Constitution of India. The Doctrine of Basic Structure was first introduced in the landmark judgment of Kesavananda Bharati v. State of Kerala in 1973, in which the Supreme Court held that the Parliament’s power to amend the Constitution is not absolute and is subject to certain limitations.
The Doctrine of Basic Structure has played a crucial role in upholding the sovereignty, democracy, and secularism of the Indian Constitution. It has protected the fundamental rights of the citizens, the independence of the judiciary, and the federal structure of the government.
The Indira Gandhi case was significant in the context of the Doctrine of Basic Structure, as it involved the amendment of the Constitution through the Constitution (Twenty-fifth Amendment) Act, 1971. The Twenty-fifth Amendment was enacted to nullify the judgment of the Supreme Court in the Indira Gandhi case and to validate the election of Indira Gandhi as the Prime Minister.
The Supreme Court, in its judgment in the Indira Gandhi case, upheld the Doctrine of Basic Structure and held that the Twenty-fifth Amendment was unconstitutional and violated the basic structure of the Constitution. The Court observed that the Twenty-fifth Amendment had the effect of nullifying the judgment of the Court and was therefore violative of the independence and impartiality of the judiciary.
The Indira Gandhi case is a landmark judgment that has had a significant impact on the Indian constitutional law and has reaffirmed the principle of the rule of law and the independence and impartiality of the judiciary. It has also played a crucial role in the development of the Doctrine of Basic Structure, which has helped to protect the core principles of the Constitution of India from any amendment by the Parliament.