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In SR Bommai v. Union of India (1994), the Supreme Court emphasized that judicial review of Governor's report under Article 356 is limited to examining constitutional compliance, not:
- Re-appreciating material or substituting judicial wisdom for Presidential satisfaction
- Examining procedural compliance
- Examining relevance of material to constitutional breakdown
- Examining constitutional principles compliance
Answer: Re-appreciating material or substituting judicial wisdom for Presidential satisfaction
Judicial restraint under SR Bommai: (a) Context: Challenge to scope of judicial review of Governor's report under Article 356, (b) Supreme Court holding: (i) Judicial review permitted: Courts can examine whether Presidential satisfaction based on objective material, not mala fide or political considerations, (ii) Limited scope: Courts cannot re-appreciate material, substitute judicial wisdom for Presidential satisfaction; review limited to procedural compliance, relevance of material, constitutional principles compliance, (iii) Floor test principle: Courts can examine whether floor test conducted, results respected, as objective verification of majority, (c) Applications: (i) Rameshwar Prasad (2006): Struck down Bihar Assembly dissolution based on unverified media reports, political considerations, but did not re-appreciate material, (ii) Recent Governor cases (2022-2024): Reiterated limited judicial review scope, objective standards, (d) Rationale: (i) Separation of powers: Courts respect executive/legislative domain while ensuring constitutional compliance, (ii) Federal balance: Judicial review protects State autonomy without usurping Presidential discretion, (iii) Democratic legitimacy: Courts ensure Article 356 used for genuine constitutional breakdown, not political ends, (e) Illustrates calibrated judicial review: Courts guard constitutional boundaries without substituting policy judgment; balance between judicial oversight and executive discretion in federal crises.