Landmark Supreme Court Cases — Set 9

Correct Answer: B. Right to life and human dignity under Article 21

Prem Shankar Shukla v Delhi Administration (1980) is a landmark prisoners' rights case in which Justice V.R. Krishna Iyer held that routine handcuffing of undertrial prisoners while being escorted to court is a violation of Article 21's right to live with human dignity. The court held that handcuffing is inherently humiliating and dehumanizing and can only be resorted to in exceptional cases where there is a credible danger of escape or violence, not as a routine practice. The judgment established that prisoners do not forfeit their fundamental rights upon arrest and the state has a duty to treat them with dignity.

Correct Answer: B. Custodial deaths and torture during police custody

D.K. Basu v State of West Bengal (1996) is the definitive judgment on custodial violence in which the Supreme Court issued a comprehensive set of eleven requirements that must be followed by police officers making an arrest. These include: the arresting officer must bear accurate identification, a memo of arrest must be prepared and attested, the arrested person has a right to have a friend or relative informed, a medical examination must be conducted at the time of arrest, and detainees must be produced before a magistrate within 24 hours. Violation of these requirements exposes officers to departmental action and contempt of court.

Correct Answer: B. Sexual Harassment of Women at Workplace Act, 2013

Vishaka v State of Rajasthan (1997) had issued guidelines on prevention of sexual harassment of women at the workplace in the absence of legislation, and these guidelines were to have the force of law until a statute was enacted. The Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 — popularly known as the POSH Act — was enacted to give statutory force to these protections and replaced the Vishaka guidelines. The POSH Act mandates Internal Complaints Committees in all workplaces with 10 or more employees and provides a detailed mechanism for complaints, inquiry, and redressal.

Correct Answer: B. The husband must provide reasonable and fair provision and maintenance for the entire future life of the divorced wife

Danial Latifi v Union of India (2001) upheld the constitutional validity of the Muslim Women (Protection of Rights on Divorce) Act, 1986 but through a creative interpretation that substantially restored the protection granted in Shah Bano. The Supreme Court held that the Act requires the husband to make a 'reasonable and fair provision' for the entire future life of the divorced wife — not just during iddat — through payment within the iddat period. This interpretation effectively nullified the anti-Shah Bano purpose of the Act while preserving its text, and ensured divorced Muslim women received adequate maintenance.

Correct Answer: B. Adultery (Section 497)

Joseph Shine v Union of India (2018) was a unanimous 5-judge constitutional bench judgment that struck down Section 497 IPC (adultery) as unconstitutional. The court held that Section 497 was manifestly arbitrary and violated Articles 14, 15, and 21 as it treated women as property of their husbands and denied women agency over their own sexuality. The court noted that the provision was based on 19th century patriarchal notions of women as subordinate to men and that adultery, while a ground for divorce, cannot be treated as a criminal offence in a constitutional democracy that guarantees dignity and equality.

Correct Answer: B. Offloading of a disabled passenger from a SpiceJet flight

Jeeja Ghosh v Union of India (2016) arose from the incident of a disability rights activist with cerebral palsy being offloaded from a SpiceJet aircraft in violation of the Civil Aviation Requirements for carriage of persons with disabilities. The Supreme Court held that the offloading violated the petitioner's right to life and dignity under Article 21 and the right against discrimination under Article 15. The court imposed a compensation of Rs. 10 lakh on SpiceJet and issued directions for strengthening protection for passengers with disabilities. The case highlighted the importance of equal access to public services for persons with disabilities.

Correct Answer: B. Arms Act — mandatory sentence for possession of unlicensed arms

State of Punjab v Dalbir Singh (2012) is a significant judgment in which the Supreme Court upheld the mandatory minimum sentence provisions in the Arms Act for offences relating to unlicensed firearms. The court addressed the tension between judicial discretion in sentencing and legislative policy of mandatory minimums. While upholding the mandatory sentences, the court emphasized that sentencing courts must consider all circumstances including the mitigating factors, though they cannot go below the mandatory minimum. This case is significant in the broader debate about mandatory minimum sentences and their impact on the principles of proportionality in criminal sentencing.

Correct Answer: B. Right to know criminal and financial background of electoral candidates

Union of India v Association for Democratic Reforms (2002) upheld the Election Commission's power to require disclosure of candidates' criminal antecedents, assets, and educational qualifications as part of the nomination process. The Supreme Court held that the right to information is implicit in the freedom of speech and expression under Article 19(1)(a) and voters have a fundamental right to know about the background of candidates seeking their vote. The court stated that an uninformed voter cannot be a truly free voter, making transparency in electoral information essential to democracy.

Correct Answer: B. The rule in Rylands v Fletcher allowed exceptions that were inadequate for modern enterprises

MC Mehta v Union of India (1986), the Oleum Gas Leak case, introduced the Absolute Liability doctrine precisely because Justice P.N. Bhagwati found the English rule in Rylands v Fletcher (Strict Liability) inadequate for Indian conditions. The Strict Liability rule had exceptions — act of God, consent of plaintiff, and act of a third party — which could allow enterprises to escape liability even for catastrophic harm from hazardous operations. The court held that in a country with hazardous industries operating close to densely populated areas, a stricter rule without any exceptions was necessary to ensure corporate accountability for environmental disasters.

Correct Answer: B. A minuscule fraction of the country's total population (LGBT persons)

Suresh Kumar Koushal v Naz Foundation (2013) was a 2-judge bench Supreme Court judgment that reversed the Delhi High Court's landmark Naz Foundation verdict decriminalizing consensual same-sex relations. The court held that homosexuals constitute 'a minuscule fraction of the country's total population' and dismissed the constitutional challenge to Section 377 IPC. This reasoning — that fundamental rights do not protect minorities if they are too small — was later rejected as constitutionally untenable by the Supreme Court itself in Navtej Singh Johar (2018), which expressly overruled Koushal.