Case Summary: State of Rajasthan and Others vs Union of India and Others
**Case Stats:**
Case Name: State of Rajasthan and Others vs Union of India and Others
Citation: AIR 1977 SC 1361; (1977) 3 SCC 592; (1978) 1 SCR 1
Case No: Original Suits 1 to 6 of 1977 and Writ Petitions 67 to 69 of 1977
Date of Decision: 06-05-1977
Court: Supreme Court of India
Bench: M. Hameedullah Beg, C.J.; Y. V. Chandrachud, J.; S. Murtaza Fazal Ali, J.; P. N. Bhagwati, J.; P. K. Goswami, J.; N. L. Untwalia, J.; A. C. Gupta, J.
Final Decision: Overruled
[Judgment Source]
https://www.courtkutchehry.com/Judgement/Search/AdvancedV2?docid=291057
Name of the Court
Supreme Court of India
All Citations
AIR 1977 SC 1361; (1977) 3 SCC 592; (1978) 1 SCR 1
Facts of the Case
Six States—Rajasthan, Madhya Pradesh, Punjab, Bihar, Himachal Pradesh, and Orissa—filed suits under Article 131 of the Constitution challenging a letter dated 18 April 1977 from the Union Home Minister, Shri Charan Singh, advising dissolution of their Legislative Assemblies following the defeat of the ruling party in the Lok Sabha elections. The States claimed the directive was unconstitutional and sought injunctions to prevent action under Article 356 based solely on this advice. Three MLAs from Punjab filed writ petitions under Article 32, alleging violation of their right to property due to impending dissolution.
Law Points Raised
1. Whether the Union's directive to dissolve State Assemblies based solely on the ruling party's defeat in Lok Sabha elections is within the purview of Article 356.
2. Whether dissolution requires prior ratification by both Houses of Parliament under Article 356(3).
3. Whether such directives constitute mala fide and unconstitutional action.
4. Maintainability of suits under Article 131 for disputes relating to composition of State Governments.
5. Justiciability of the grounds for invoking Article 356.
Acts / Provisions / Articles Referred
• Constitution of India, 1950 — Articles 12, 123, 142(1), 153, 154, 356
• General Clauses Act, 1897 — Sections 3(58), 3(60)
• Government of India Act, 1935 — Sections 204, 72, 93
• Representation of the People Act, 1951
Judgements Referred
The judgment references constitutional precedents on Article 356 and dissolution powers, though no specific case names are cited explicitly in the provided extract.
Obiter Dicta
The Court observed that political changes in Lok Sabha elections do not, by themselves, mandate dissolution of State Assemblies unless there is a constitutional breakdown in governance as envisaged under Article 356.
Ratio Decidendi
The grounds stated in the Home Minister's letter—defeat of the ruling party in general elections—are not sufficient to invoke Article 356. The President's satisfaction under Article 356 is not justiciable unless there is a clear case of constitutional breakdown. Suits under Article 131 challenging such anticipatory actions are not maintainable.
Final Ruling
The Supreme Court dismissed the suits and petitions, holding that there was no justiciable cause of action. The letter did not by itself constitute action under Article 356, and anticipatory injunctions could not be granted.
Summary
This case clarified that Article 356 cannot be invoked merely due to a change in political power at the Centre or electoral defeat of the ruling party in States. Judicial review of the President’s satisfaction under Article 356 is limited, and States cannot seek anticipatory injunctions against potential future constitutional actions based on political advisories.
[Judgment Source]
https://www.courtkutchehry.com/Judgement/Search/AdvancedV2?docid=291057