Maneka Gandhi v Union of India (1978)

Administrative Law · Exceptions to Natural Justice & Effect of Non-Compliance

Facts.

Maneka Gandhi’s passport was impounded “in the public interest” without giving her any reasons or an opportunity to be heard.

Issue.

Must an administrative order affecting personal liberty follow natural justice even where the statute prescribes no hearing?

Held.

Yes. Article 21’s “procedure established by law” must be fair, just and reasonable, which imports natural justice. Articles 14, 19 and 21 are a connected web; a hearing (at least post-decisional, in urgency) is required, and reasons must be given.

Why it matters.

It constitutionalised natural justice — fair procedure is now part of the fundamental right to liberty. It is the single most-cited case for reading a fair hearing into any administrative power.

📄 Full Administrative Law notes + Question Bank (₹199) — every topic in depth, model answers to all past exam questions, in one printable PDF. Get the bundle · All landmark cases · All Administrative Law topics