In SR Bommai v. Union of India (1994), the Supreme Court emphasized that Governor's report recommending President's Rule must promote democratic federalism by protecting State autonomy unless genuine constitutional breakdown occurs.

Democratic federalism under SR Bommai: (a) Context: Challenge to President's Rule imposition violating democratic federalism, (b) Supreme Court holding: (i) Governor's report must promote democratic federalism: State autonomy protected unless genuine constitutional breakdown occurs, (ii) Constitutional breakdown narrowly defined: Genuine inability to function in accordance with Constitution, not mere political instability, (iii) Judicial review: Courts examine whether report promotes democratic federalism, not just procedural compliance, (c) Applications: (i) Post-1994: Courts more willing to strike down Article 356 proclamations violating democratic federalism, (ii) Federal balance: Protects State autonomy against arbitrary Centre overreach via gubernatorial discretion, (d) Rationale: (i) Democratic legitimacy: Elected State governments represent people's will; Article 356 exceptional measure, not routine tool, (ii) Constitutional morality: Governor as constitutional functionary, not political agent, (iii) Judicial oversight: Courts ensure Article 356 used for genuine constitutional breakdown, not political ends, (e) Illustrates constitutional federalism: Democratic federalism requirement protects State autonomy; judicial review ensures Article 356 used for genuine crises, not political convenience.