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In Maneka Gandhi v. Union of India (1978), the Supreme Court established the 'golden triangle' of Articles ______, holding that laws affecting personal liberty must satisfy all three articles, not just Article 21.
- 14, 19, 21
- 15, 16, 17
- 21, 22, 23
- 32, 226, 136
Answer: 14, 19, 21
Maneka Gandhi (1978) golden triangle of Articles: (a) Context: Challenge to impounding of passport under Passport Act without hearing; issue of interrelationship between Fundamental Rights, (b) Supreme Court holding: (i) Articles 14 (equality), 19 (freedoms), 21 (life/liberty) form interconnected 'golden triangle', (ii) Laws affecting personal liberty must satisfy all three articles, not just Article 21, (iii) Procedure under Article 21 must be 'fair, just, and reasonable', not arbitrary or oppressive — importing procedural due process, (c) Applications: (i) Procedural safeguards: Laws affecting liberty must satisfy equality (Article 14), freedoms (Article 19), life/liberty (Article 21), (ii) Rights expansion: Enabled expansion of Article 21 to include privacy, health, environment, livelihood, dignity, (iii) Judicial review: Courts examine laws for compliance with all three articles, ensuring comprehensive rights protection, (d) Subsequent developments: (i) Puttaswamy (2017): Applied golden triangle to privacy recognition — privacy intrinsic to Article 21, also part of Article 19 freedoms, Article 14 equality, (ii) Navtej Singh Johar (2018): Applied golden triangle to LGBTQ+ rights — discrimination violates Articles 14, 15, 19, 21, (e) Rationale: (i) Holistic rights protection: Fundamental Rights interconnected; protecting one requires protecting others, (ii) Constitutional supremacy: Laws must comply with entire constitutional framework, not isolated provisions, (iii) Democratic accountability: Ensures government accountable to Constitution, not arbitrary power, (f) Illustrates transformative constitutionalism: Golden triangle enables comprehensive rights protection; judicial interpretation ensures laws satisfy interconnected constitutional values, not just formal compliance with isolated provisions.