RIGHT TO LIVELIHOOD

ARTICLE 21 OF CONSTITUTION OF INDIA AND RIGHT TO

LIVELIHOOD
Neepa Jani
Visiting Faculty
Sir L.A. Shah Law College, and
I. M. Nanavati Law College, Ahmedabad.

Voice of Research
Vol. 2 Issue 2,
September 2013
ISSN No. 2277-7733

Abstract

In any organized society, right to live as a human being is not ensured by meeting only the animal needs of man. It is
secured only when he is assured of all facilities to develop himself and is freed from restrictions which inhibit his
growth. All human rights are designed to achieve this object. Right to live guaranteed in any civilized society implies
the right to food, water, decent environment, education, medical care and shelter. The word life as employed by Article
21 takes in its sweep not only the concept of mere physical existence by also all finer values of life including the right
to work and right to livelihood. This right is a fundamental right guaranteed to all persons residing in India, citizens
and non-citizens alike. right to life including right to livelihood and work as guaranteed by Article 21 is not reduced
to a mere paper platitude but is kept alive, vibrant and pulsating so that the country can effectively march towards the
avowed goal of establishment of an egalitarian society as envisaged by the founding fathers while enacting the
Constitution of India along with its Preamble.
Keywords: Article 21, constitution of India, right to
that a short provision they were embodying in the
livelihood
Constitution has so much potentiality. Hardly ever such a
provision has made so long strides as this Article. Dr.
Article 21 is one of the prime Articles comprised in Part III
Ambedkar and a large part of the Constituent Assembly
of the Constitution of India dealing with fundamental
who has felt dissatisfied with the reach of Article 15, as
rights. Fundamental rights listed in Part III are enforceable
was Article 21 numbered in the draft constitution, to
against State as defined by Article 12 of the Constitution
compensate which Article 15A was inserted, must be
of India. State includes the Government and Parliament of
feeling happy in the heaven because of the immense
India and the Government and the Legislature of each of
content poured in Article 21 by lesser mortals. The journey
the States and all local or other authorities within the
is continuing in al its majesty. Law is never still; it cannot
territory of India or under the control of the government of
be. It has also to be moulded by deft hands to meet the
India. As laid down by Article 13 laws inconsistent with or
challenge of time, as, it has been well said that life of law is
in derogation of fundamental rights to the extent of such
not logic, it is experience.
inconsistency or derogation are treated to be void. The
State is also enjoined not to make any law which takes
Article 21 in Constitutional Settings: This Article is
away or abridges the rights conferred by Part III of the
couched in a negative form and enjoins the State not to
Constitution of India and any law made in contravention
deprive any person not necessarily only a citizen, of his
of Article 13 shall, to the extent of the contravention, be
life or personal liberty except according to procedure
void. So far as Article 21 is concerned it lays down that no
established by law. It is axiomatic that the State can
person shall be deprived of his life or personal liberty
deprive any person of his life or personal liberty only
except according to procedure established by law. The
through the medium of operation of any law which is a
moot question is what is the correct connotation of the
valid law. If any procedural law can validly deprive any
word life as encompassed by the said Article. Will it
person of his life or personal liberty it should comply with
include right to livelihood or right to work or will it
the requirement s such: The procedure laid down by the
connote only bare physical existence? In this connection it
said law should be as a result of valid exercise of
is profitable to keep in view the pertinent observations
legislative power by the concerned law making authority.
made by learned author Justice B. L. Hansaria in the
In other words only a competent legislature can enact
Introduction to his book:1
such law. If the procedure laid down by such law is found
to be established by an incompetent legislature such law
The fundamental right to life which Article 21 deals with
would be a still-born one or an incompetent one and ultra
is the most precious human right and forms the arc of all
vires the powers of the concerned legislature. Result
other rights. What is more, this Article has given to the
would be that such a procedure flowing grom such invalid
people of India as much they have wanted from it. We are
law will have no effect on the life or personal liberty of any
sure, it is capable of giving more, if they would so want in
person governed by the sweep of Article 21; and Even
future. The founding fathers has perhaps not visualized
though the procedure established by law is found to have
1 Right to Life and Liberty under the Constitution, Ed. 1993
been laid down by a legislature which is competent to
published by N. M. Tripathi Pvt. Ltd., Bombay.
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RIGHT TO LIVELIHOOD

enact such a law, if such law is found to conflict with any

of the fundamental rights guaranteed by Part III of the
Constitution then such law would become void and in that
eventuality such law enacted by competent legislature
would yet be invalid and would be treated as still-born
having no impact on the deprivation of life and liberty of
the deprivation of life and liberty of the concerned person
and Article 21 would fully protect suchlife and personal
liberty of that person.
So far as this second type of infirmity is concerned the
relevant Articles which would govern such law as
contemplated by Article 21 and in whose light such law
will have to be tested are Articles 14, 19 and 22 of the
Constitution of India. Article 14 guarantees equality before
law or equal protection of law to every person in India. If
the procedure laid down by the concerned law does not
stand the test of Article 14 such law will not be of any avail
to the State for depriving the person concerned of his life
or personal liberty as guaranteed under Article 21. Similarly
under Article 19(1)(g) all citizens of India amongst others
have a right to practice any profession or carry on any
occupation, trade or business. Of course, such a right is
subject to Sub-article (6) of Article 19 which lays down
that nothing in the said sub-clause shall affect the
operation of any existing law in so far as it imposes, or
prevent the State from making any law imposing, in the
interest of general public, reasonable restrictions on the
exercise of the right conferred by the said sub-clause, and
in particular, nothing in the said sub-clause shall aggect
the operation of any existing law in so far as it related to,
or prevent the State from making any law relating to the
professional or technical qualifications necessary for
practicing any profession or carrying on any occupation,
trade or business, or the carrying on by the State, or by a
corporation owned or controlled by the State, of any trade,
business, industry or service, whether to the exclusion,
complete or partial, of citizens or otherwise.
Similarly Article 22 lays down the procedure which should
be followed before any arrest or detention of any person is
to be effected. If the procedure laid down by any law
enacted by the competent legislature falls short of the
requirements of Article 22 it will have no effect so far as
the deprivation of life and personal liberty of the person
concerned is on the anvil. In short in such a case the
fundamental right guaranteed under Article 21 will stand
untouched so far as such person is concerned. Article 21
also will have to be read in the light of relevant directive
principles of State Policy found in Part IV of the
constitution of India. As laid down by Article 37 the
provisions contained in Part IV shall not be enforceable by
any court, but the principles therein laid down are
nevertheless fundamental in the governance of the
country and it shall be the duty of the State to apply these

principles are beckon lights for the State both in its

executive as well as legislative capacity to be guided by
them and these functions of the State have to monitored in
the light of these directive principles. The relevant
directive principles for our purpose are found in Articles
39(a) and 41. Article 39(a) lays down that State shall, in
particular, direct its policy towards securing, (a) that the
citizens, men or women equally, have the right to an
adequate means of livelihood; while Article 41 provides
that the State shall, within the limits of its economic
capacity and development, make effective provision for
securing the right to work, to education and to public
assistance in cases of unemployment, old age, sickness
and disablement, and in other cases of undeserved want.
We have to cull our the correct connotation of the term
life as employed by Article 21 keeping in view the
constitutional duty of the State as flowing from the
aforesaid directive principles of State Policy under Articles
39(a) and 41. A conjoint reading of these provisions,
therefore, clearly indicates that it is the obligation of the
State while enacting laws in connection with deprivation
of life of any person which is protected by Article 21 to see
to it that it does not falter in its constitutional obligation of
making effective provisions for securing right to work and
also for providing adequate means of livelihood to its
citizens. It is in the background of the aforesaid
constitutional scheme that we now turn to tackle the moot
question as to whether right to livelihood or work is
covered by the sweep of Article 21 or not.
Salient Features of Article 21: It is true that originally
when this Article was cleared by the Constituent
Assembly for its inclusion in the Constitution the
founding fathers emphasized the term life or the term
personal liberty with special reference to incarceration as
per the established procedure under any legal and valid
law. But the term deprivation of life as employed by
Article 21 in its present form cannot necessarily mean total
extinction of only physical existence. The term life as
employed by Article 21 has received an expanded meaning
in the light of a series of decisions of Supreme Court. Life
can be extinguished or become worthless for anyone who
cannot have adequate monetary support or economic
sustenance. If a person is hungry and starving life for him
is not worth living. He may be only breathing but he
would not be living life. Such hungry people are prone to
commit any type of misdeed for eking out their miserable
existence. It is with a view to avoid such hunger of
persons residing in India that the founding fathers can be
said to have enacted Article 21 enjoining upon the State
not to deprive any person of his life except by procedure
established by law. Therefore, the term life as found in
Article 21 must necessarily encompass with its fold right
to adequate livelihood and work so that the concerned

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RIGHT TO LIVELIHOOD

person is not reduced to the shadow of his real self and

does not merely remain a breathing skeleton. It is of course
true that Article 21 is couched in a negative term as
contrasted with Article 19(1)(g) which is in positive terms.
However that would not whittle down the efficacy and the
parameters of Article 21 which guarantees by way of
fundamental right to every person residing in India the
right to effective and dignified existence with a view to
leading a happy and a healthy life. This in its turn would
necessarily imply the guarantee of being ensured adequate
means of livelihood and work. As Article 21 itself includes
a mandate to the State not to tinker with the fundamental
rights of persons entitled to lead a healthy life except by
enacting valid laws, the directive principles as enshrined in
the aforesaid Articles which also operate in the very same
field of legislative exercise by the State must necessarily
have to be read in conjunction with the mandate of Article
21 and not dehors it. When so read it becomes obvious
that it will be the duty of the State to see to it that every
person residing in India is enabled to enjoy a healthy life
by being provided with adequate means of livelihood and
right to work. It is of course true that such right to work
and guarantee of adequate means of livelihood as enjoined
by Article 21 cannot permit any citizen to insist on carrying
of any work which is obnoxious by itself or which is illegal
as that would cut across Article 19(1)(g) read with Article
19 sub-clause 6 and also Article 14 of the Constitution of
India which covers non-citizens as well. Right to work and
to carry on any legally permissible occupation or
avocation in life with a view to enjoy adequate means of
livelihood for leading a healthy and meaningful life would
remain well sustained on the combined operation of
Articles 14, 19(1)(g) and 21. It is also trite to say that the
procedure established by law for cutting across the right
of any person to be supplied adequate means of livelihood
or adequate opportunities for work by the State also
cannot be a procedure which falls foul on the altar of
Article 14. Thus before a person can be deprived of his life
and personal liberty as guaranteed by Article 21 by any
procedure established by law, such law must steer cleat of
all the restrictions imposed by Articles 14 and 19(1)((g) on
the power of the concerned Legislature to enact such laws.
If there is any head-of collision of such procedural law
with any of the aforesaid fundamental rights Article 13
would start clicking and would invalidate such procedural
law.
Article 21 has one more salient feature, namely, Article 21
is available to all persons residing in India whether citizens
or not while the positive right guaranteed under Article
19(1)(g) is only available to citizens of India and not to
outsiders. In other words the negative injunction
contained in Article 21 has a wider field to operate upon
and it takes in its sweep even non-citizens while the

positive mandate of Article 19(1)(g) caters to a smaller

section of the residents in India. Article 21 knows of no
exceptions and is not subject to any proviso unlike Article
19. It takes car or every person living in India, no matter he
is a citizen of India unlike Article 19. It opened with an
emphatic not. Use of the words shall and except makes
the command of the people of India the sovereign
absolute.
Judicial Review on Article 21: In the case of Kharak Singh
v. State of U.P.2 a Constitutional Bench of the Supreme
Court observed We shall now proceed with the
examination of the width, scope and content of the
expression personal liberty in Art. 21. Having regard to
the terms of Art. 19 (l) (d), we must take it that that
expression is used as not to include the right to move
about or rather of locomotion. The right to move about
being excluded its narrowest interpretation would be that it
comprehends, nothing more than freedom from physical
restraint or freedom from confinement within the bounds
of a prison; in other words, freedom from arrest and
detention, from false imprisonment or wrongful
confinement. We feel unable to hold that the term was
intended to bear only this narrow interpretation but on the
other hand consider that personal liberty is used in the
Article as a compendious term to include within itself all
the varieties of rights which go to make up the personal
liberties of man other than those dealt with in the several
clauses of Art. 19 (1).In other words, while Art.19 (l) deals
with particular species or attributes of that freedom,
personal liberty in Art. 21 takes in and comprises the
residue. We have already extracted a passage from the
judgment of field, J. in Munn v. Illinois,3 where the learned
Judge pointed out that life in the 5th and 14th
amendments of the U.S. Constitution corresponding to
Art. 2, means not merely the right to the continuance of a
persons animal existence, but a right to the possession of
each of his organs - his arms and legs etc. We do not
entertain any doubt that the word life in Art 21 bears the
same signification and in this way Supreme Court
earmarked a very wide field for the operation of Article 21
for the concept of life and liberty as enshrined therein.
While giving an answer to the question that whether the
term life as found in Article 21 would include right to
work or right to be assured of adequate means of
livelihood Supreme Court in the case of Olga Tellis and
others v. Bombay Municipal Corporation and others4
reiterated that, As we have stated while summing up the
petitioners case, the main plank of their argument is that
the right to life which is guaranteed by Art. 21 includes the
right to livelihood and since, they will be deprived of their
2
3
4

AIR 1963 SC 1295 para 17

(1876) 94 US 113 at p.142
AIR 1986 SC 180 para 32-33

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RIGHT TO LIVELIHOOD

livelihood if they are evicted from their slum and pavement

dwellings, their eviction is tantamount to deprivation of
their life and is hence unconstitutional. For purposes of
argument, we will assume the factual correctness of the
premise that if the petitioners are evicted from their
dwellings, they will be deprived of their livelihood. Upon
that assumption, the question which we have to consider
is whether the right to life includes the right to livelihood.
We see only one answer to that question, namely, that it
does. The sweep of the right to life conferred by Art. 21 is
wide and far-reaching. It does not mean merely that life
cannot be extinguished or taken away as, for example, by
the imposition and execution of the death sentence, except
according to procedure established by law. That is but one
aspect of the right to life. An equally important facet of
that right is the right to livelihood because, no person can
live without the means of living, that is, the means of
livelihood. If the right to livelihood is not treated as a part
of the constitutional right to life, the easiest way of
depriving a person of his right to life would be to deprive
him of his means of livelihood to the point of abrogation.
Such deprivation would not only denude the life of its
effective content and meaningfulness but it would make
life impossible to live. And yet, such deprivation would
not have to be in accordance with the procedure
established by law, if the right to livelihood is not regarded
as a part of the right to life. That, which alone makes it
possible to live, leave aside what makes life livable, must
be deemed to be an integral component of the right to life.
Deprive a person of his right to livelihood and you shall
have deprived him of his life. Indeed, that explains the
massive migration of the rural population to big cities.
They migrate because they have no means of livelihood in
the villages. The motive force which propels their
desertion of their hearths and homes in the village is the
struggle for survival, that is, the struggle for life. So
unimpeachable is the evidence of the nexus between life
and the means of livelihood. They have to eat to live :
Only a handful can afford the luxury of living to eat. That
they can do, namely, eat, only if they have the means of
livelihood. That is the context in which it was said by
Douglas J. in Baksey5, that the right to work is the most
precious liberty that man possesses. It is the most
precious liberty because, it sustains and enables a man to
live and the right to life is a precious freedom. Life, as
observed by Field, J. in Munn v. Illinois6, means something
more than mere animal existence and the inhibition against
the deprivation of life extends to all those limits and
faculties by which life is enjoyed. This observation was
quoted with approval by this Court in Kharak Singh v.
5
6
7

(1954) 347 M.D. 442

Supra
Supra

State of U.P.
33. Article 39(a) of the Constitution, which is a Directive
Principle of State Policy, provides that the State shall, in
particular, direct its policy towards securing that the
citizens, men and women equally, have the right to an
adequate means of livelihood. Art. 41, which is another
Directive Principle, provides, inter alia, that the State shall,
within the limits of its economic capacity and
development, make effective provision for securing the
right to work in cases of unemployment and of undeserved
want. Article 37 provides that the Directive Principles,
though not enforceable by any Court, are nevertheless
fundamental in the governance of the country. The
Principles contained in Arts. 39(a) and 41 must be regarded
as equally fundamental in the understanding and
interpretation of the meaning and content of fundamental
rights. If there is an obligation upon the State to secure to
the citizens an adequate means of livelihood and the right
to work, it would be sheer pedantry to exclude the right to
livelihood from the content of the right to life. The State
may not, by affirmative action, be compellable to provide
adequate means of livelihood or work to the citizens. But,
any person, who is deprived of his right to livelihood
except according to just and fair procedure established by
law, can challenge the deprivation as offending the right,
to life conferred by Art. 21.
The same view was taken by the Supreme Court while
rendering decision in the case of Delhi Transport
Corporation D.T.C v. Mazdoor Congress and Others8 as
The right to life includes right to livelihood, The right to
livelihood therefore cannot hang on to the fancies of
individuals in authority. The employment is not a bounty
from them nor can its survival be at their mercy. Income is
the foundation of many fundamental rights and when work
is the sole source of income, the right to work becomes as
much fundamental. Fundamental rights can ill-afford to be
consigned to the limbo of undefined premises and
uncertain applications. That will be a mockery of them.
Both the society and the individual employees, therefore,
have an anxious interest in service conditions being welldefined and explicit to the extent possible. The arbitrary
rules, such as the one under discussion, which are also
sometimes described as Henry VIII Rules, can have no
place in any service conditions.
K. Ramaswamy J. in his concurring judgment in the very
same case laid down in para 267 that Before depriving an
employee of the means of livelihood to himself and his
dependents, i.e. job, the procedure prescribed for such
deprivation must, therefore, be just, fair and reasonable
tinder Arts. 21 and 14 and when infringes Art. 19(1)(g)
8
9

AIR 1991 SC 101 para 223

AIR 1963 SC 109 Para 13

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RIGHT TO LIVELIHOOD

must be subject to imposing reasonable restrictions under

Art. 19(5). Conferment of power on a high rank officer is
not always an assurance, in , particular when the moral
standards are generally degenerated that the power would
be exercised objectively, reasonably, conscientiously, fairly
and justly without inbuilt protection to an employee. Even
officers who do their duty honestly and conscientiously
are subject to great pressures and pulls. Therefore, the
competing claims of the public interest as against
individual interest of the employees are to be
harmoniously blended so as to serve the societal need
consistent with the constitutional scheme.
In this connection a judgment rendered by the Supreme
Court in the case of The Board of Trustees of the Port of
Bombay v. Dilipkumar R. Nadkaarni and ors.9 must be
referred which has been made in connection with Article
21: Article 21 mandates that no one shall be deprived of
his life or liberty except in accordance with the procedure
prescribed bylaw. The expression life has a much wider
meaning. Where therefore the outcome of a departmental
enquiry is likely to adversely affect reputation or
livelihood of a person, some of the finer graces of human
civilization which make life worth living would be
jeopardized and the same can be put in jeopardy only by
law which inheres fair procedures.
As laid down by Bhagawati, J. in the case of Smt. Maneka
Gandhi v. Union of India & Anr.10 the law envisaged by
Article 21 must stand the test of Article 14 and procedure
laid down by Article 21 must answer the test of
reasonableness in order to be in conformity with Article 14.
It must be right and just and fair and not arbitrary, fanciful
or oppressive, otherwise it would be no procedure at all
and the requirement of Article 21 would not be satisfied.
In case of LIC of India and another v. Consumer Education
& Research Centre and others11 Supreme Court again
reiterated the very same principle and observed in para 14
the Article 19 assures freedoms with right to residence and
settlement in any part of the country and At 21 by
receiving expansive interpretation of right to life extends to
right to livelihood. In the case of M.J. Sivani & Ors. v.
State of Karnataka & Ors.12 Court held that right to life
under Article 21 does protect livelihood but added a rider
that its deprivation cannot be extended too far or projected
or stretched to the avocation, business or trade injurious
to public interest or has insidious effect on public moral or
public order. It was, therefore, held that regulation of video
games or prohibition of some video games of pure chance
or mixed chance and skill are not violative of Article 21 nor
is the procedure unreasonable, unfair, or unjust. A Bench
10
11
12
13

AIR 1978 SC 597

(1995) 5 SCC 482
(1995)6 SCC 289
(1996)2 SCC 549

of three learned Judges of the Supreme Court in the case

of Chameli Singh & Ors. v. State of U.P. and Anr.13 had to
examine the question whether the term life as found in
Article 21 would include all the components of right to life.
Answering the question in the affirmative the following
pertinent observations were made in para 8 of the
judgment:
In any organized society, right to live as a human being is
not ensured by meeting only the animal needs of man. It is
secured only when he is assured of all facilities to develop
himself and is freed from restrictions which inhibit his
growth. All human rights are designed to achieve this
object. Right to live guaranteed in any civilized society
implies the right to food, water, decent environment,
education, medical care and shelter.
The same view was reflected while delivering the judgment
by the Supreme Court in Dr. Haniraj J. Chulani v. Bar
Council of Maharashtra & Goa14that right to live as
mentioned in Article 21 includes right to livelihood.
However on facts it was in that case that the said right is
not denied to a person who is already carrying on a
profession of a medical practitioner and who is not
permitted to simultaneously practice law. This discussion
may be closed by citing a decision of the Apex Court in
Narendra v State of Haryana15 wherein the similar view has
been taken. It, therefore, must be taken as a settled legal
position that Article 21 guarantees to all persons residing
in India right to lead dignified life which would include
right get adequate livelihood and work and no procedural
law can deprive them of this right unless such a law is
enacted by competent legislature and is not violative of
any the other fundamental rights especially Article 14 and
19(1)(g) of the Constitution of India. Article 21 along with
Article 14 and 19, therefore, must be treated as a trinity of
rights projecting a golden triangle ensuring a healthy and
effective life to all the residents in India including its
citizens. These three Articles project an assurance that the
promise held forth by the Preamble will be performed by
ensuring an egalitarian era within the discipline of
fundamental rights.
Conclusions: Now is the time to take stock of the situation
for bringing down the curtain. As seen above by a catena
of decisions of the Supreme Court spread over decades it
is now well settled that the word life as employed by
Article 21 takes in its sweep not only the concept of mere
physical existence by also all finer values of life including
the right to work and right to livelihood. This right is a
fundamental right guaranteed to all persons residing in
India as contradistinguished with only citizens covered by
the sweep of Article 19(1)(g). This right cannot be
interfered with by the State save and except by a
1 4 (1996)3 SCC 342
1 5 AIR 1995 SC 519

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RIGHT TO LIVELIHOOD

procedure emanating from a valid law which should be

passed by a competent legislature and which should not
come in conflict in any of the other fundamental rights
especially those guaranteed under Article 14 and 19(1)(g)
in so far as they are available to concerned person
invoking such a fundamental right. Though Article 19(1)(g)
caters to the needs of only citizens, Article 14 is available
to all persons and not necessarily only to citizens.
Therefore, Article 21 goes hand in hand with Article 14 and
both of them serve the same class of humanity residing in
India both citizens and non-citizens. It is of course true
that Article 21 is couched in a negative form and cannot be
enforced in absolute terms by way of a substantive
provision as is the case with the fundamental right under
Article 19(1)(g) available to citizens of India. Still, however,
the fact remains that the State is prohibited from tinkering
with right to work or tight to livelihood guaranteed under
Article 21 to all residents of India, citizens and non-citizens
alike save and except by enacting a procedural law which
stands the test of Part III of the Constitution of India and
the State has also a positive duty to be guided by the
provisions of Articles 39(a) and 41 for making the right to
life as envisaged by Article 21 more effective and kicking.
It has also to be kept in view that Article 21 is neither
suspendable during emergency nor capable of being
abrogated or amended and , therefore, the State being
governed and guided by the provisions of Article 21 in
Part III and the Directive Principles in Part IV in this
connection has to see to it that right to life including right
to livelihood and work as guaranteed by Article 21 is not

reduced to a mere paper platitude but is kept alive, vibrant

and pulsating so that the country can effectively march
towards the avowed goal of establishment of an egalitarian
society as envisaged by the founding fathers while
enacting the Constitution of India along with its Preamble.
References
Kharak Singh v. State of U.P. AIR 1963 SC 1295 para 17
Munn v. Illinois (1876) 94 US 113 at p.142
Olga Tellis and others v. Bombay Municipal Corporation
and others AIR 1986 SC 180 para 32-33
Baksey (1954) 347 M.D. 442
Delhi Transport Corporation D.T.C v. Mazdoor Congress
and Others AIR 1991 SC 101 para 223
The Board of Trustees of the Port of Bombay v. Dilipkumar
R. Nadkaarni and ors. AIR 1963 SC 109 Para 13
Smt. Maneka Gandhi v. Union of India & Anr. AIR 1978 SC
597
LIC of India and another v. Consumer Education &
Research Centre and others (1995) 5 SCC 482
M.J. Sivani & Ors. v. State of Karnataka & Ors. (1995)6
SCC 289
Chameli Singh & Ors. v. State of U.P. and Anr. (1996)2 SCC
549
Dr. Haniraj J. Chulani v. Bar Council of Maharashtra & Goa
(1996)3 SCC 342
Narendra v State of Haryana AIR 1995 SC 519
Right to Life and Liberty under the Constitution Justice
B.L. Hansaria , Ed. 1993 published by N. M. Tripathi
Pvt. Ltd., Bombay.

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