Maneka Gandhi v. Union of India
Passport impoundment; fair procedure; Article 21 read with Articles 14 and 19.
IRAC Analysis
Whether impounding a passport under the Passports Act without adequate hearing violates Article 21.
The Court expanded Article 21 beyond mere animal existence to require procedure that is fair, just, and reasonable. Restrictions on personal liberty must satisfy Articles 14 and 19 as well. The passport impoundment was remitted for fresh consideration on whether the procedure complied with these standards.