S.R. Bommai v.
Union of India: A Case Study for Law Students
The S.R. Bommai case, decided by a nine-judge bench of the Supreme Court of
India on March 11, 1994, is a landmark judgment in Indian constitutional law
concerning the imposition of President's Rule under Article 356 of the Constitution.
This case significantly curtailed the arbitrary use of Article 356 and reaffirmed the
principles of federalism and secularism as part of the Basic Structure of the Indian
Constitution.
Background
Article 356 allows the President to impose President's Rule in a state if the state
government cannot function according to the Constitution. Before the Bommai
judgment, this article was often used to dismiss state governments for political
reasons. Dr. B.R. Ambedkar had hoped it would be used sparingly.
Facts of the Case
In 1989, the S.R. Bommai-led Janata Dal government in Karnataka was dismissed
under Article 356. The Governor recommended President's Rule due to party
defections, despite Bommai wanting a floor test. Similar dismissals happened in
other states. Bommai challenged the decision in court.
Legal Issues
Key questions in the case included:
The scope of the President's power under Article 356.
Whether judicial review applies to the President's decision to impose President's
Rule.
The conflict between the Governor's assessment and a floor test for determining a
government's majority.
The necessity of Parliamentary approval before dissolving the Legislative Assembly.
The impact of President's Rule on federalism and democracy.
Supreme Court's Judgment
The Supreme Court established important principles regarding Article 356:
Judicial Review: The Court ruled that the President's action under Article 356 can
be judicially reviewed to check the basis of the decision and detect misuse of
power.
Floor Test Mandate: It mandated that a government's majority must be proven on
the Assembly floor, not based on the Governor's opinion.
Parliamentary Approval Required: The Court stated that dismissal should only occur
after parliamentary approval; until then, the Assembly can only be suspended.
Restoration of Dismissed Government: An unconstitutional dismissal allows for the
reinstatement of the state government.
Federalism and Secularism as Basic Features: The Court reaffirmed federalism and
secularism as fundamental parts of the Constitution's basic structure.
Significance and Impact
The Bommai judgment significantly impacted center-state relations by reducing the
arbitrary use of Article 356 and promoting stability. It strengthened democratic
processes by emphasizing the floor test and reinforced federalism by upholding
state autonomy. The ruling clarified the limited circumstances for using Article
356 according to a Drishti IAS article.
Conclusion
The S.R. Bommai case highlights the judiciary's role in protecting constitutional
principles and democratic federalism in India. By providing clear guidelines for
Article 356, the Supreme Court fostered a more balanced relationship between the
central and state governments.
