The Indian Constitution is a shining beacon of rights and freedoms and justice. It defines the foundation of India’s democracy and rule of law. Three articles in this vast document stand out because of their interconnectedness and importance as a foundation: Articles 14, 19 and 21.
These three articles collectively are referred to as the “golden triangular” of the Constitution. They embody essential principles that support the dignity, freedom, and equality of all citizens.
This golden triangle is not just a legal concept; it’s the foundation of the individual rights of every citizen and the smooth operation of the democratic system.
Article 14: Right to Equality
Article 14 lays out the principle of equal protection before the law. This article ensures that all individuals, irrespective of their background, are treated equally by state officials and not subjected to arbitrary discrimination.
This article is crucial in establishing that all citizens are equal before the law. It fosters a sense justice and fairness at all levels of the society. Article 14 is a practical way to prevent the state from being biased or arbitrarily treating people, and it demands a reason for any treatment that they give.
The courts have ruled that, while classifications based on relevant differences can be made, they must also be reasonable and serve an appropriate purpose. This is particularly important in cases of discrimination based on socioeconomic status or gender.
Article 19: Right to Freedom
Article 19 establishes a number of freedoms that are fundamental to a democratic society. These freedoms include: the right of speech and expression; the right of peaceful assembly; the right for associations to be formed, as well as the rights to travel freely throughout the country and to settle anywhere within India.
These rights are essential not only for an individual’s development, but also to the functioning of a society that allows ideas and opinions to flourish. These freedoms, however, are not absolute.
They come with some reasonable restrictions. In the interests of public order and security, morality, and decency, the state may limit these rights. Article 19 strikes a balance, therefore, between individual freedom and social welfare. It ensures that freedom doesn’t infringe upon public interests.
Article 21: Right to Life and Personal Liberty
The Indian Constitution’s Article 21, which is often considered one of its most dynamic provisions, guarantees both the right to personal liberty and the right to live.
The Supreme Court of India, over the years has interpreted the article in a way that encompasses a wide range of human rights. Article 21 was originally interpreted as the right not be deprived life or liberty without a fair legal procedure. However, it now includes a wide range of rights, including the right of privacy, to live in dignity and to have a livelihood.
Article 21 has evolved to reflect the progressive nature with which the judiciary protects citizens’ rights. It often adapts to changes in society and changing needs. This article is the foundation of many judicial pronouncements that aim to ensure citizens live lives of dignity and worth.
The Golden Triangle
Interaction of Articles 14 and 19 In the landmark Supreme Court decision *Maneka v. Union of India*, (1978), the Court highlighted this interrelationship by ruling that any law restricting individual liberty must meet the requirements of the three articles.
This judgment was a major shift in Indian Constitutional Law, as it expanded the definition of “personal freedom” under Article 21, and established that this cannot be taken without taking into consideration the principles of equality and freedom (Article 14, and 19).
In the case of *Maneka Ghandi*, the Court ruled that a law can only be used to rob an individual of his or her personal freedom if it is “just, fair and reasonable”, and complies with the principles of equality, reason, and due procedure. The Court ruled that equality, freedom and life rights could not be considered separately but as an integrated unit.
The golden triangle is a system that checks and balances laws to prevent them from being arbitrarily passed or infringing citizens’ rights without valid reasons. The golden triangle ensures individual rights will be upheld if they are in line with equality and freedom principles.
Why the Golden Triangle is Important
The golden triangle in the Indian Constitution acts as a protection against authoritarianism. It ensures that no law, government action, or restriction of freedom or equality can be made without legitimate reasons. The golden triangle provides a framework to encourage judicial activism by allowing courts to interpret the law in a way that is most beneficial for justice and individual rights.
The interconnection of Articles 14, 19 and 21 empowers the judiciary in protecting citizens’ rights and evolving the meaning of constitutional protections to reflect contemporary realities. This doctrine also reinforces the notion that citizens’ entitlements are not compartmentalized, isolated rights, but interconnected.
The golden triangle is a way to ensure constitutional balance. When one right gets compromised, it can affect others.