Landmark Supreme Court Cases — Set 4

Correct Answer: B. Article 356 — President's Rule in States

S.R. Bommai v Union of India (1994) was decided by a 9-judge constitutional bench and is the most important judgment on Article 356, which allows the President to impose President's Rule in a state. The case arose from the dismissal of the S.R. Bommai government in Karnataka. The court laid down detailed guidelines to prevent the misuse of Article 356 and held that Presidential proclamations under Article 356 are subject to judicial review on grounds of malafides or unconstitutional use.

Correct Answer: C. Article 356

S.R. Bommai v Union of India (1994) held that secularism is an inviolable part of the Basic Structure of the Indian Constitution, in the context of examining Article 356 proclamations. The court held that a state government pursuing anti-secular policies can be dismissed under Article 356, but only if there is adequate material before the President. This ruling was significant because several BJP governments had been dismissed in 1992 after the Babri Masjid demolition, and the court validated those dismissals as justified.

Correct Answer: B. Floor test in State Legislature

S.R. Bommai v Union of India (1994) held that before imposing President's Rule under Article 356, the government of the day must be given an opportunity to prove its majority on the floor of the State Legislative Assembly (floor test). The court rejected the practice of dismissing state governments on the Governor's subjective opinion about loss of majority without testing this in the legislature. This floor test requirement has become the standard safeguard against politically motivated use of Article 356.

Correct Answer: B. Reservations for Other Backward Classes

Indra Sawhney v Union of India (1992) was a landmark 9-judge constitutional bench judgment that upheld the Mandal Commission's recommendation of 27% reservation for Other Backward Classes (OBCs) in central government jobs. The case challenged the V.P. Singh government's implementation of the Mandal Commission report. The court upheld OBC reservations while simultaneously imposing the crucial 50% cap on total reservations and mandating the exclusion of the 'creamy layer' (affluent OBCs) from reservation benefits.

Correct Answer: C. 50%

Indra Sawhney v Union of India (1992) established that the total quantum of reservations cannot ordinarily exceed 50% of available posts or seats in any cadre. The court held that beyond 50%, reservations would violate the right to equality under Article 14 and destroy the merit-based nature of public employment. However, the court allowed for exceptional circumstances in extraordinary situations, which has led to subsequent debates about whether states like Tamil Nadu (69% reservations) can exceed the 50% cap.

Correct Answer: B. Indra Sawhney v Union of India 1992

Indra Sawhney v Union of India (1992) introduced the 'creamy layer' concept, holding that the more affluent and advanced members among OBCs (those above a certain income/status threshold) must be excluded from reservation benefits as they are no longer backward. The court reasoned that reservations are meant to bring the truly backward sections of society into the mainstream and that allowing well-off OBCs to corner reservation benefits defeats the constitutional purpose. This creamy layer exclusion does not apply to SC/ST reservations.

Correct Answer: B. Gang rape of a social worker, leading to sexual harassment guidelines at workplace

Vishaka v State of Rajasthan (1997) arose from the brutal gang rape and murder of Bhanwari Devi, a social worker in Rajasthan who had tried to prevent a child marriage. In the absence of adequate domestic legislation, the Supreme Court issued comprehensive guidelines defining and prohibiting sexual harassment of women at the workplace. These Vishaka guidelines had the force of law and remained binding until the enactment of the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013.

Correct Answer: A. Absolute liability and Polluter Pays principle

MC Mehta v Union of India (various cases from 1986 onwards) saw Justice P.N. Bhagwati develop the doctrine of Absolute Liability in the Oleum Gas Leak case (1986), holding that enterprises engaged in hazardous activities are absolutely liable for any harm caused, without any exceptions. The court also applied and developed the Polluter Pays principle (those who cause pollution must bear the cost of cleaning it up) and the Precautionary principle (act to prevent harm even under scientific uncertainty). These principles transformed Indian environmental law.

Correct Answer: B. Oleum Gas Leak case 1986

MC Mehta v Union of India (1986), the Oleum Gas Leak case, arose from the leakage of oleum gas from the Shriram Food and Fertilizers plant in Delhi. Justice Bhagwati formulated the Absolute Liability doctrine as an Indian development of the English Strict Liability rule from Rylands v Fletcher. Under Absolute Liability, there are no exceptions like act of God, consent of plaintiff, or act of a stranger — any enterprise engaged in a hazardous activity is absolutely liable to compensate victims of any escape of that hazardous material.

Correct Answer: B. Right to None of the Above (NOTA) on ballot

People's Union for Civil Liberties (PUCL) v Union of India (2013) directed the Election Commission to provide a NOTA (None of the Above) option on Electronic Voting Machines, giving voters the right to reject all candidates without abstaining from voting. The Supreme Court held that the right to vote includes the right to reject all candidates and that secrecy of the ballot must be maintained even for negative voting. NOTA was implemented for the first time in five state assembly elections in November 2013.