SR Bommai vs Union of India: Judgement, Significance, SR Bommai Case UPSC

By K Balaji|Updated : January 10th, 2023

SR Bommai vs Union of India Case, a challenge to the Governor's decision, was made by S.R Bommai. He served as the Chief Minister of Karnataka from 13th August 1988 to 21st April 1989. He was a member of the Janata Dal administration. Following Article 356 of the Constitution, his government was overthrown on 21st April 1989. He filed a petition with the Karnataka High Court, which was denied.

SR Bommai vs Union of India PDF

He later appealed his case to India's Supreme Court, popularly known as SR Bommai vs Union of India case. The syllabus for the polity and governance section of the UPSC exam includes SR Bommai vs Union of India, which is an important topic. We have provided detailed UPSC notes below to understand the SR Bommai Case judgment, history, impact, and significance.

Table of Content

SR Bommai vs Union of India

The Supreme Court ruled in the case of SR Bommai vs Union of India (1994) that the Constitution is federal and refers to liberalism as its "basic element." The fact that the Center is granted more authority than the States under the framework of our Constitution does not imply that the States are merely the Center's appendage.

  • According to the constitution, the states are independent.
  • They do not serve as the Center's satellites or agents.
  • The states remain supreme in the space that is assigned to them.
  • The Supreme Court of India made a significant judgment in the case of SR Bommai vs Union of India, in which the Court extensively examined the provisions of Article 356 of the Indian Constitution and related matters.
  • This case greatly impacted Centre-State Relations.
  • SR Bommai vs Union of India judgment tried to stop the flagrant abuse of Article 356 of the Indian Constitution, which permitted the imposition of the President's control over state governments.
  • The former chief minister of Karnataka, S. R. Bommai, is well known for having fought for this significant decision of the Indian Supreme Court, which itself is regarded as one of the most often discussed decisions in the country's political history.

SR Bommai Case History

According to Article 356 of the Constitution, S.R. Bommai's government was overthrown, and President's Rule was implemented, a common tactic to keep opposing parties away. The Bommai government lost its majority due to widespread defections arranged by various party leaders, which was the basis for the removal.

  • SR Bommai served as the chief minister of Karnataka from August 1988 until April 1989.
  • He headed a Janata Dal government, which was overthrown on April 21, 1989, when Karnataka was placed under President's Rule (Article 356).

SR Bommai Case 1994

Previous to the SR Bommai vs Union of India case, it was normal practice to impose Article 356 in states governed by opposing parties to the party in power. In this case, the Bommai-led administration was dissolved because he had lost support due to many resignations.

  • Even though Bommai gave a copy of the resolution adopted by the Janata Dal Legislature Party to the then-Governor P Venkatasubbaiah, he was not given a chance to demonstrate his majority in the house.
  • Bommai first proceeded to the Karnataka High Court to challenge the Governor's decision.
  • The High Court, however, rejected his petition filed.
  • After then, SR Bommai went to the Indian Supreme Court.
  • It took approximately five years to decide this SR Bommai vs Union of India case.
  • A nine-judge constitutional bench of the SC issued the historic decision in March 1994, which would go on to be one of the most frequently referenced ones about Article 356 and its arbitrary interpretation by the Central government.

SR Bommai vs Union of India Judgement

The center could no longer impose the President's Rule on states due to this historic judgment of the SR Bommai case.

  • According to this, the President's power to dissolve a state's government is not absolute.
  • According to the statement, the President should only exercise this authority after receiving unanimous consent from both Houses of Parliament to his proclamation (imposing President's Rule).
  • The Legislative Assembly may only be suspended till that time by the President.
  • The proclamation expires after two months, and the dissolved government is reinstated if both Houses do not approve it.
  • Assemblies are reinstated, including the suspended Legislative Assembly.
  • In addition, the SC declared that a court could examine the declaration imposing Article 356.

SR Bommai vs Union of India - Problems

The declaration of the president's rule in a state has come under scrutiny in light of the case of SR Bommai vs Union of India. The justifications and parameters of imposing the president's rule in a state have to be debated by the Supreme Court. It was also questioned as to whether the President's rule was challengeable.

Contentions from SR Bommai vs Union of India

In SR Bommai vs Union of India, a significant legal issue arose over the President's Rule proclamation and dissolution of the Legislative Assemblies by Article 356 of the Indian Constitution.

  • If the President Declaration under Article 356 had been justiciable, to what extent was the first and most essential point the Supreme Court would have to answer.
  • Second, the question of whether Article 356(1) of the Constitution gives the President unrestricted authority to issue proclamations was raised.
  • It was argued that the President would issue the Proclamation under Article 356 [1] based on the guidance of the Council of Ministers provided under Article 74(1) of the Constitution.
  • Because Clause [2] of the same Article prohibits investigation into whether any and, if so, what advice was offered to the President, judicial supervision of the factors that contributed to the issuance of a Proclamation is also barred, whether the President's declaration to dissolve the Legislature may be overturned to reinstate the Legislature, can the Proclamation issued under Article 356(1) be contested even after it has received the support of both Houses of Parliament?
  • Additionally, it was questioned whether the court could issue an interim stay preventing the holding of new elections whenever the validity of the proclamation was contested.
  • It was argued that whether a president can call a special session of the legislature without getting both houses' consent, a state legislature can be removed from office if it commits nonsecular conduct because secularism is a fundamental aspect of the Constitution.

Significance of SR Bommai vs Union of India Case

This lawsuit ended the practice of the federal government dismissing state governments freely. Previously, political parties used this Constitutional provision to gain political advantage and resolve disputes with opposing parties. SR Bommai vs Union of India decision significantly curtailed this practice.

  • The decision made it crystal clear that the test of a majority in a government should be conducted on the Assembly floor, and it is not dependent on the Governor's opinion.
  • The basic principle idea was used in this instance even though a constitutional amendment was not in question.
  • According to the Supreme Court, using the centralized authority under Article 356 would be legitimate if a state government's policies were directed against a fundamental component of the Constitution.

First Impact of SR Bommai vs Union of India Case Decision

The A.B. Vajpayee administration was compelled to reinstate a government it had overthrown in 1999, which was one of the impacts of SR Bommai vs Union of India due to influence. Other impacts are as follows:

  • The Rabri Devi administration was dismissed on February 12, 1999.
  • On March 8, 1999, it was reinstalled after it became clear that the Central government might lose in the Rajya Sabha due to the matter.
  • The S.R. Bommai Case is still very relevant since it is brought up every time there is a potential conflict of interest between the Chief Minister and the Governor.
  • Additionally, it brought about a system where a government is removed after careful study.

SR Bommai vs Union of India UPSC

One of the Supreme Court's key decisions on the fundamental structure doctrine and the flagrant misuse of Article 356 came from SR Bommai vs Union of India case. It is an important topic in the UPSC polity & governance sections for the IAS exam.

For a clearer understanding of this topic, candidates should know the important facts concerning SR Bommai vs Union of India that are presented below.

  • The S.R. Bommai Case is significant because one of its decisions is the most quoted verdict in Indian politics.
  • Article 356, which relates to the S.R. Bommai Case, has already been misused more than 125 times.
  • The case is associated with SR Bommai, who served as Karnataka's chief minister at the time.
  • The case casts doubt on the declaration of the President's control in a state.
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FAQs on SR Bommai vs Union of India

  • The Significance of SR Bommai vs Union of India case was its decision made it obvious that the President cannot arbitrarily impose Article 356 on a state administration; there must be a good reason for doing so. This judgment substantially ended the arbitrary impositions that had been in place up to that point.

  • Somappa Rayappa Bommai was the 11th Chief Minister of Karnataka, India. He served from From 13 August 1988 to 21 April 1989.

    • He was the United Front government's HRD Minister from 1992 to 1998.
    • He is most recognized for his role in the landmark Supreme Court of India decision on SR Bommai vs Union of India.
  • The SR Bommai case presented one of the Supreme Court's landmark decisions regarding the basic structure ideology and the unjustified misuse of Article 356.

  • The A.B. Vajpayee administration in 1999 was forced to reinstate a cabinet it had sacked, which was one of the first effects of SR Bommai vs Union of India case.

    On March 8, 1999, the Rabri Devi government, which had been overthrown on February 12, was reinstituted after it became evident that the Central administration would lose the Rajya Sabha vote.

  • If civil disturbance breaks out and the state administration lacks the resources to end it, Article 356 grants the Union government the authority to impose its will on a state.

  • Article 356 has been misused several times to overthrow state governments run by political parties that are opposed to the federal dominant party. As stated by B. P. Jeevan Reddy in one of his interviews from 1998, the provision for suspending elected governments has been invoked more than 125 times, and in the majority of those instances, it looked to have questionable constitutional validity.

  • SR Bommai vs Union of India judgement was that the center could no longer charge the President's Rule on states due to the historic judgment of the SR Bommai case. It indicated that the President's power to dissolve a state's government is not unlimited.

  • A nine-judge Constitution Bench of the Supreme Court issued the historic proclamation on March 11, 1994, which terminated the random layoff of State governments under Article 356 by spelling out constraints.

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