In Maneka Gandhi v. Union of India (1978), the Supreme Court held that the procedure established by law under Article 21 must be fair, just, and reasonable, importing the concept of ______ due process from comparative constitutional law — a principle Constitutional Morality requires to protect individual dignity against arbitrary state action.

Procedural due process and Constitutional Morality: (a) A.K. Gopalan (1950): Article 21 required only 'procedure established by law'; no substantive due process review, (b) Maneka Gandhi (1978): Overruled Gopalan; held procedure under Article 21 must be 'fair, just, and reasonable', not arbitrary or oppressive; imported procedural due process from American constitutional law, adapted to Indian context, (c) Constitutional Morality application: (i) Enabled judicial review of executive action affecting life/liberty, (ii) Foundation for expanding Article 21 to include privacy, health, environment, livelihood, dignity, (iii) Requires state action to follow fair procedure: notice, hearing, reasoned order, appeal mechanism, (d) Balance: Courts don't substitute wisdom for administrators; check for procedural fairness, rationality, non-arbitrariness — Constitutional Morality guides calibrated oversight respecting separation of powers while protecting individual dignity. Illustrates judicial creativity: adapting foreign concepts to Indian constitutional text while respecting institutional boundaries.