DAMODARAM SANJIVAYYA NATIONAL LAW

UNIVERSITY
VISAKHAPATNAM, A.P., INDIA

AN ANALYSIS OF JUSTICE PN BHAGWATIs INTERPRETATIONS IN HIS

JUDICIAL APPROACH

INTERPRETATION OF STATUTES

SUBMITTED TO
MR.R. BHARAT KUMAR

SUBMITTED BY
NIKHITHA JYESTA
Sem VII A.
ROLL NO;2013053

CERTIFICATE
The project entitled An Analysis Of Justice PNBhagwatis Interpretations In His
Judicial Approach" submitted to the DamodaramSanjivayya National Law University,
Visakhapatnam for Interpretation of Statutes, as part of internal assessment is my original
work carried out under the guidance of Mr.Bharat Kumar. The research work has not been
submitted elsewhere for award of any publication or degree. The material borrowed from
other sources and incorporated in the work has been duly acknowledged.

Signature of the candidate

ACKNOWLEDGMENT
I owe a great many thanks to a great many people who helped and supported me during the
completion of the project. My deepest thanks to Mr. Bharat Kumar, the Guide of the project
for guiding and correcting various documents of mine with attention and care. He has taken
pain to go through the project and make necessary correction as and when needed. I would
also thank my Institution and my faculty members without whom this project would have
been a distant reality.

CONTENTS
INTRODUCTION....................................................................................................... 1
JUSTICE PN BHAGWATI PROFILE...............................................................................2
JUSTICE BHAGWATIs JUDICIAL BENCHMARKS & INTERPRETATIONS..........................2
CASE LAWS............................................................................................................. 4
M.C. Mehta Vs. Union of India (UOI) and Ors.................................................................4
Bandhua Mukti Morcha v. Union of India.......................................................................4
Sudip Mazumdar v. State of Madhya Pradesh..................................................................4
Maneka Gandhi's Case.............................................................................................. 4
SP Gupta's Case....................................................................................................... 4
ADM Jabalpur Case................................................................................................. 4
Bachan Singh's Case................................................................................................. 5
Indira Gandhi v. Raj Narain........................................................................................ 5
M.C. Mehta (Taj Trapezium Matter) v. Union of India and
Ors.......................................................... 5
Union of India v. Godfrey Philips India
Limited...................................................................................5
CONCLUSION.......................................................................................................... 5

AN ANALYSIS OF JUSTICE PN BHAGWATIs INTERPRETATIONS IN HIS

JUDICIAL APPROACH

INTRODUCTION:
Nothing rankles more in the human heart than a brooding sense of injustice. Illness we can
put up with. But injustice makes us want to pull things down. When only the rich can enjoy
the law, as a doubtful luxury, and the poor, who need it most, cannot have it because its
expense puts it beyond their reach, the threat to the continued existence of free democracy is
not imaginary but very real, because democracys very life depends upon making the
machinery of justice so effective that every citizen shall believe in an benefit by its
impartiality and fairness.
- Justice Bhagwati in HussainaraKhatoon case.
The Indian judiciary, especially at the level of the Supreme Court and the High Courts, has
for long been concerned with the concept and practice of justice. What constitutes justice and
for whom? How do we truly achieve the laudable constitutional precepts that no one is
above the law and that all persons are entitled to the equal protection of the law? How do
we cope with the problem that in principle, all persons are equal under the law but in reality,
some are more equal than others?
During the first couple of decades when, for all practical purposes, India was functioning as a
de facto one-party political system, the Supreme Court focused on promoting the values of
constitutionalism, separation of powers and checks and balances over and in each organ of
the State. The Supreme Court and the High Courts were ever-vigilant in their review of
executive actions, hence ensuring to the public requisite protection against excesses of
authority or abuses of power. They were equally vigilant in their review of legislative actions,
both in respect of lawmaking as well as in balancing legitimate parliamentary powers,
(necessary for the effective functioning of Parliament) with parliamentary privileges, notably
that of punishing for contempt.

In the decades thereafter, the Supreme Court turned its attention towards the frequency with
which the Parliament was amending the Constitution using the dominance of a single
political party at both the national and state levels to the maximum. The Court elaborated
upon the distinction between the constituent and legislative power These were the testing
times when Justice Bhagwati made a mark on the Indian diaspora of judicial activism.

JUSTICE P N BHAGWATI PROFILE

The Hon'ble Mr. Justice P.N. Bhagwati; was born on 21st December,1921; son of late N.H.
Bhagwati; he had married Prabhavati Shethji and had three daughters Parul, Pallavi and
Sonali. He has secured 2nd position in Matriculation in Bombay, graduated in Maths. (Hons.)
in Ist Class from Elphin stone College, Bombay in 1941; appointed a Fellow of the same
college; whilst doing M.A. in Maths. courted arrest during the National Freedom Movement
in 1942 and went underground for four months; took his Law Degree in Ist Class from
Government Law College, Bombay; practised at the High Court, Bombay; became a Judge of
the Gujarat High Court on 21st July, 1960; became Chief Justice of Gujarat on 16th
September, 1967; became Judge of the Supreme Court on 17th July, 1973; was Chairman of
the Legal Aid Committee appointed by the Government of Gujarat for suggesting ways and
means of providing free legal aid and advice to the poor and weaker section of the
community; acted as Chairman of the State Legal Aid Committee for running the Pilot
Project of free Legal Aid and Advice in Gujarat; Chairman of the Judicial Reforms
Committee set up by the Government of Gujarat; Chairman of the Gujarat Kendra of the
Bharatiya Vidya Bhavan; connected with several educational institutions in Ahmedabad;
Chairman of the Harilal Bhagwati Institute of Journalism conducted by the Bharatiya Vidya
Bhavan, Ahmadabad; at one time Member of the Senates of the Gujarat University and the
M.S. University at Baroda; Appointed as Chief Justice of India on 12.07.1985. Retired on
20.12.1986.

JUSTICE BHAGWATIs JUDICIAL BENCHMARKS& INTERPRETATIONS

The case of S.P. Gupta v. Union of India,1 remembered as the Judges Transfer Case, is a
unique product of the Indian Supreme Court, dealing with aspects of the Law of Evidence,
Constitutional Law and Executive-Judiciary relations, united in

a strong political

undercurrent of a most unique variety in the Supreme Courts post-Emergency catharsis.

It is best elucidated by the dictum of Justice Bhagwati :
Where a legal wrong or a legal injury is caused to a person or to a determinate class of
persons by reason of violation of any constitutional or legal right or any burden is imposed
in contravention of any constitutional or legal provision or without authority of law or any
such legal wrong or legal injury or illegal burden is threatened and such person or
determinate class of persons by reasons of poverty, helplessness or disability or socially or
economically disadvantaged position unable to approach the court for relief, any member of
public can maintain an applicationin the High Court under Article 226 and in case any
breach of fundamental rights of such persons or determinate class of persons, in this court
under Article 32.
The Supreme Court decision in ADM Jabalpur v. Shiv Kant Shukla,2 better known as the
Habeas Corpus case, along with its decision in SP Gupta v. Union of India ( The Judges
Transfer case) represent the high watermark of the abdication of judicial power or inactivism
that charactreised most systems of adjudication during Indira Gandhi Governments.
Concurring with the majority in both cases was Justice (as he then was) PN Bhagwati, who
later went on to became Chief Justice of India.
In the first case, he agreed with the then Attorney Generals arguments that all fundamental
rights stood suspended during an Emergency and that no individual had any right to approach
the Courts for any sort of remedy for violation of even the fundamental right to life. In the
second, he concurred with the majority in holding that the Union government enjoyed an
almost absolute power in the transfer of Judges, representative of judicial abdication in the
context of the Union Government looking for pliant judges and transferring judges according
to their policy requirements.

1AIR 1982 SC 149

2 AIR 1976 SC 1207
7

Needless to say, he went on to become Chief Justice of India. However, it must be noted by
all that Justice Bhagwati was a pioneer of judicial activism best seen today through the vast
PIL jurisprudence. His decisions on locus standi in SP Gupta and BandhuaMuktiMorcha are
activist in so far as they greatly further the cause of depressed classes in society; Maneka
Gandhi3 represented a new step in the constitutional rights paradigm. Upendra Baxi, a
prominent jurist terms such a volte face, of first succumbing to the Governments policy
pressures so as to achieve high office before going on to use such high office to
redemocratise the nation and help the citizens of India, as nothing but a process of judicial
catharsis.

CASE LAWS
1. M.C. Mehta Vs. Union of India (UOI) and Ors.4
Facts.
The case came up before the five-judge bench of the Supreme Court after a three-judge bench
had referred it to a higher bench because certain questions of seminal importance and high
constitutional significance were raised in the course of arguments when the writ petition was
originally heard.
1. The Bench of three Judges permitted Shriram Foods and Fertiliser Industries
(hereinafter referred to as Shriram) to restart its power plant as also plants for
manufacture of caustic chlorine including its by-products and recovery plants like
soap, glycerine and technical hard oil, subject to the conditions set out in the
Judgment.
2. The main issue in the original writ petition which was filed in order to obtain a
direction for closure of the various units of Shriram on the ground that they were
hazardous to the community.
3. But while the writ petition was pending there was escape of oleum gas from one of
the units of Shriram on 4 and 6 December 1985 and applications were filed by the
Delhi Legal Aid & Advice Board and the Delhi Bar Association for award of
3AIR 1978 SC 597
41987 SCR (1) 819
8

compensation to the persons who had suffered harm on account of escape of oleum
gas.
4. The Court thought that these applications for compensation raised certain important
issues and those issues should be addressed by a constitutional bench.
Issues
There was only one preliminary objection filed by the counsel for the defendant, and this was
that the Court should not proceed to decide these constitutional issues since there was no
claim for compensation originally made in the writ petition and these issues could not be said
to arise on the writ petition.

Judgement
This judgment was delivered by PN Bhagawati, G.oza, ranganath mishra, KN Singh, MM
dutt that Shriram was made liable as part of state action and thus liable to pay compensation.
Reasoning
It may now be taken as well settled that Article 32 does not merely confer power on this
Court to issue a direction, order or writ for enforcement of the fundamental rights but it also
lays a constitutional obligation on this Court to protect the fundamental rights of the people
and for that purpose this Court has all incidental and ancillary powers including the power to
forge new remedies and fashion new strategies designed to enforce the fundamental rights.
The next question which arises for consideration on these applications for compensation is
whether Article 21 is available against Shriram which is owned by Delhi Cloth Mills Limited,
a public company limited by shares and which is engaged in an industry vital to public
interest and with potential to affect the life and health of the people. The issue of availability
of Article 21 against a private corporation engaged in an activity which has potential to affect
the life and health of the people was vehemently argued by counsel for the applicants and
Shriram.
The Court traced the evolution of the Doctrine of State Action to ascertain whether the
defendants in this case fall under the definition of the term state, as provided under Article 12,
or not. The Court also looked into the Industrial Policy of the Government. Under the
9

Industrial Policy Resolution 1956 industries were classified into three categories having
regard to the part which the State would play in each of them. The first category was to be the
exclusive responsibility of the State. The second category comprised those industries which
would be progressively State owned and in which the State would therefore generally take the
initiative in establishing new undertakings but in which private enterprise would also be
expected to supplement the effort of the State by promoting and development undertakings
either on its own or with State participation. The third category would include all the
remaining industries and their future development would generally be left to the initiative and
enterprise of the private sector.
If an analysis of the declarations in the Policy Resolutions and the Act is undertaken, we find
that the activity of producing chemicals and fertilisers is deemed by the State to be an
industry of vital public interest, whose public import necessitates that the activity should be
ultimately carried out by the State itself, in the interim period with State support and under
State control, private corporations may also be permitted to supplement the State effort. The
argument of the applicants on the basis of this premise was that in view of this declared
industrial policy of the State, even private corporations manufacturing chemicals and
fertilisers can be said to be engaged in activities which are so fundamental to the Society as to
be necessarily considered government functions.

2. BandhuaMuktiMorcha v. Union of India.5

Facts:
The Supreme Court entertained a matter concerning release of bonded labor raised by an
organization dedicated to the cause of release of bonded labor.
Issues
The applicant had raised the issue of bonded labour plaguing the society and the need for its
immediate redressal.
Judgement
The Locus Standi was removed and the concept underlying PIL was exploited.
5(1984) 3 SCC 161
10

Reasoning
Justice Bhagwati explained the concept underlying PIL as Where a person or class of
persons to whom legal injury is caused by reason of violation of a fundamental right is
unable to approach the court of judicial redress on account of poverty or disability or
socially or economically disadvantaged position, any member of the public acting bona
fide can move the court for relief under Article 32 and a fortiorari also under Article 226, so
that the fundamental rights may be meaningful not only for the rich and the well to do who
have the means to approach the court but also for the large masses of people? who are living
a life of want and destitution and who are by reason of lack of awareness, assertiveness and
resources unable to seek judicial redress.

3. SudipMazumdar v. State of Madhya Pradesh.6

FACTS
THESE proceedings were registered as a public interest litigation on the basis of a letter
dated 15-11-1982 addressed to the then Chief Justice of India by Shri SudipMazumdar, a
journalist.
Issues
The petition concerns the alleged inadequacy of safety precautions in the Indian Army's
ammunition test-firing range near Itarsi in Madhya Pradesh. It is alleged that the villagers,
mostly tribals, who stray into what is stated to be the country's largest ammunition test-firing
range, were getting killed and maimed
Judgement
In this case, or, account of test firing practices being organised at a test firing range near
Itarasi in Madhya Pradesh, several of the tribals are becoming victims of the firing and some
of them succumb to the injuries and several sustain grievous injuries. That resulted in filing
this writ petition. This Court, by order dated March 13, 1994 by a Constitution Bench, had
accepted the recommendations made by High-level Committee of the Government
constituted pursuant to an order passed by this Court.
6(1994) Suppl. 2 SCC 327
11

Reasoning
The recommendations, as accepted by this Court, are as under:
(i) The substitute plans of erecting barbed wire fencing around the four target areas have been
worked out.
(ii) DSC personnel will be deplayed to patrol the target areas to prevent unauthorised entry by
metal pickets into the target area and to protect the barbed wire.
(iii) Watch towers will be constructed around the fencing to provide effective field of
observations to the DSC guards to carry out duties at (b) above.
(iv) Approach roads to the target areas will be constructed for easy access.
(v) Additional transport will be provided to CPE Itarsi to ferry DSC troops to and fro target
areas and to convey food and other essential requirements to them while on duty."

4.Maneka Gandhi v Union of India7

Facts
Maneka Gandhi was issued a passport on 1/06/1976 under the Passport Act 1967. The
regional passport officer , New Delhi issued a letter dated 2/7/1977 addressed to Maneka
Gandhi , in which she was asked to surrender her passport under section 10(3)(c ) of the Act
in public interest, within 7 days from the date of receipt of the letter. Maneka Gandhi
immediately wrote a letter to the Regional passport officer New Delhi seeking in return a
copy of the statement of reasons for such order. However the government of India, Ministry
of External Affairs refused to produce any such reason in the interest of general public.
Issues
Whether Section 10(3) (c) of Passport Act violated Right to Personal Liberty of the
Applicant.
Judgement

71978 AIR 597

12

Justice Bhagwati, using the meaning given to the phrase personal liberty by Dicey, held that
the phrase personal liberty in Art. 21 meant nothing more than the liberty of the physical
body, that is, freedom from arrest and detention without the authority of law. According to
majority, the term liberty was wider in meaning and scope than personal liberty. Hence,
while liberty could be said to include Art. 19 within its ambit, personal liberty had the
same meaning as given to the expression liberty of the person under English law. Hence,
the majority took the view that Art. 19 and Art. 21 deal with different aspects of liberty. The
Court further interpreted the term law as State made law and rejected the plea that the term
law in Art. 21 meant jus naturale or principles of natural justice.

Reasoning
It is pertinent to mention here that in A.K. Gopalans case, the attention of the Supreme Court
was drawn to the legislative history of Art. 21 which showed why the expression due
process of law was replaced by procedure established by law. However, it is unfortunate
that the legislative history of Art. 22, and particularly of clauses (1) and (2), whereby the
substance of due process was reintroduced, was not brought to the attention of the Supreme
Court.
But this restrictive interpretation of the expression personal liberty has not been followed by
the Supreme Court in its later decisions. Like for example, in Kharak Singhs case, it was
held that personal liberty was not only limited to bodily restraint but was used as
compendious term including within itself all the varieties of rights which go to make up the
personal liberty of man other than those dealt within Art. 19(1).
Bhagwati, J. observed:
Theexpression personal liberty in Article 21 is of widest amplitude and it covers a variety
of rights which go to constitute the personal liberty of man and some of them have raised to
the status of distinct fundamental rights and given additional protection under Article 19.
5.SP Gupta's Case.8
8AIR 1982 SC 149
13

Facts
The case remembered as the Judges Transfer Case, is a unique product of the Indian Supreme
Court, dealing with aspects of the Law of Evidence, Constitutional Law and ExecutiveJudiciary relations, united in a strong political undercurrent of a most unique variety in the
Supreme Courts post-Emergency catharsis.
Issues
Decided by a bench of seven judges, the matter to be decided rested on several contentious
issues:
1. The claim of privilege of certain correspondence between certain Chief Justices, the CJI
and the Law Minister.
2. The locus standi of the petitioners.
3. The circumstances of appointment and conditions of service and confirmation of
Additional Judges, arising in the context of Justices Vohra & Kumar of the Allahbad High
Court.
4. The circumstances of transfer of Judges, arising in the context of Chief Justice KBN Singh
of the Patna High Court.
Judgement
The Supreme Court held that the Chief Justice shall have to consult two other senior most
Judges of the Supreme Court before sending his opinion. In this Judgement, the Supreme
Court laid down certain guidelines.
a) Individual initiation of high constitutional functionaries in the matter of appointment of
Judges reduced to minimum. It gives privacy to the Chief Justice of India but puts a check on
him to consult at least two of his senior most colleagues.
b) Constitutional functionaries must act collectively in Judicial Appointments.
c) Appointment of Chief Justice of India by seniority only.
d) No Judge can be appointment by the Union Government without Consulting the Chief
Justice of India.
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Reasoning
Justice Bhagwati on the existence of locus standi of the petitioners opined , Where a legal
wrong or a legal injury is caused to a person or to a determinate class of persons by reason
of violation of any constitutional or legal right or any burden is imposed in contravention of
any constitutional or legal provision or without authority of law or any such legal wrong or
legal injury or illegal burden is threatened and such person or determinate class of persons
by reasons of poverty, helplessness or disability or socially or economically disadvantaged
position unable to approach the court for relief, any member of public can maintain an
applicationin the High Court under Article 226 and in case any breach of fundamental
rights of such persons or determinate class of persons, in this court under Article 32.
Furthermore on the circular calling for the transfer of Judges, It may be that because an
additional Judge does not give his consent tobe appointed as a permanent Judge in another
High Court, he may not be appointed as a permanent Judge in his own High Court and may
be discontinued as an additional Judge on the expiration of his term, though this is not within
the intendment of the circular letter and is clearly impermissible but in that event it would be
his non-appointment as a permanent Judge or discontinuance as an additional Judge which
would, if at all, give him a cause of action and not the circular letter asking for such consent .
6.ADM Jabalpur Case.9
Facts
The main question of the case was whether, under Presidential Orders the High Court could
entertain a writ of Habeas Corpus filed by a person challenging the ground for his detention.
The arguments in Supreme Court began on December 14 1975, before a bench consisting of
Chief Justice of India A.N. Ray, Justice H.R. Khanna, Justice M.H. Beg, Justice Y.V.
Chandrachud and Justice P.N. Bhagwati.
Issues
Whether the access to Courts remained suspended during emergency?
Judgement

9A.I.R. 1976 S.C. 1207

15

Justice Bhagwati, held up the torch of personal liberty only to dampen it with the diplomacy
of the correct reading of the Constitution. Courtroom records read as him saying: I have
always leaned in favour of upholding personal liberty, for, I believe, it is one of the most
cherished values of mankind, without it life would not be worth living. It is one of the pillars
of free democratic society. Men have readily laid down their lives at its altar, in order to
secure it, protect it and preserve it. But I do not think it would be right for me to allow my
love of personal liberty to cloud my vision or to persuade me to place on the relevant
provision of the Constitution a construction which its language cannot reasonably bear.10
In view of the Presidential Order dated 27th June 1975 no person has any locus to move any
writ petition under Art. 226 before a High Court for habeas corpus or any other writ or order
or direction to challenge the legality of an order of detention on the ground that the order is
not under or in compliance with the Act or is illegal or is vitiated by mala fides factual or
legal or is based on extraneous considerations.11

7.Bachan Singh's Case.12

Facts
After Cr. P.C. 1973 , death sentence ceased to be the normal penalty for murder [ 354 (3)].
Another reason was that Maneka Gandhi's case gave a new interpretation to Art. 14,19 and 21
and their interrelationship . Main issues before the SC were constitutional validity of Sec. 302
of the I.P.C .as well as constitutional validity of Sec. 354 (3) of Cr.P.C. .
Issues
While answering the question of reasonableness of death penalty, the constitution bench also
discussed various other issues. These issues were :1. Whether death sentence saves any enological purpose ?
10PUCL National Reports on habeas corpus, Accessed from
http://www.pucl.org/reports/National/2001/habeascorpus.htm
11http://indiaopines.com/a-d-m-jabalpur-shukla-emergency-1975-77/
12(1980) 2 SCC 684
16

2. Views of famous Jurists & sociologists from all over the world.
3. Various foreign cases and position in other countries.
4. Circumstances which can aggravate or mitigate death punishment .
5. Cases in which the death sentence should be inflicted , and
6. The extent of judicial discretion and need of guidelines.
Judgement& Reasoning.
This judgement was delivered by Chandrachur, Sarkaria,J Bhagwati.J.bhagawati was the only
one to dissent . He said :I am of the opinion that Sec. 302 of the I.P.C. in so for as it provides for imposition of death
penalty as an alternative to life sentence is ultra vires and void as being violative of Art. 14
and 21 of the constitution since it does not provide any legislative guidelines as to when life
should be permitted to be extinguished by imposition of death sentence.

8.Indira Gandhi v Raj Narain

Facts & Issues
Raj Narain had contested the Indian general election, 1971 against Indira Gandhi, who
represented the constituency of Rae Bareilly in the Lok Sabha, the lower house of the Indian
Parliament. Gandhi was re-elected from Rae Bareilly by a two-to-one margin of the popular
vote, and her Indian National Congress (R) party won a sweeping majority in the Indian
Parliament. Narain filed a petition to appeal the verdict, alleging that Indira Gandhi used
bribery, government machinery and resources to gain an unfair advantage in contesting the
election. Narain specifically charged Gandhi of using government employees as election
agents and of organising campaign activities in the constituency while still on the payroll of
the government.
Judgement
This judgement was delivered by Krishna Iyer and PN bhagawati that The court order gave
the Congress (R) twenty days to make arrangements to replace Indira in her official posts.
This was unprecedented.
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9.M.C. Mehta (Taj Trapezium Matter) v. Union of India and Ors.13

Facts & Issues
The case sought to address the issues of blackening of Taj Mahal due to pollution.
Judgement & Reasoning
Justice PN Bhagwati described the idea of PIL as "Where a legal wrong or a legal injury
is caused to a person or to a determinate class of persons by reason of violation of any
constitutional or legal right or any burden is imposed in contravention of any constitutional
or legal provision or without authority of law or any such legal wrong or legal injury or
illegal burden is threatened and such person or determinate class of persons by reasons of
poverty, helplessness or disability or socially or economically disadvantaged position unable
to approach the court for relief, any member of public can maintain an application for an
appropriate direction, order or writ in the High Court under Article 226 and in case any
breach of fundamental rights of such persons or determinate class of persons, in this court
under Article 32 seeking judicial redress for the legal wrong or legal injury caused to such
person or determinate class of persons."

10.Union of India v. Godfrey Philips India Limited

The case answered the issue whether there could be estoppel against the legislature?
Judgement & Reasoning.
Of course we must make it clear, and that is also laid down in Motilal Sugar Mills case
(supra), that there can be no promissory estoppel against the Legislature in the exercise of its
legislative functions nor can the Government or public authority be debarred by promissory
estoppel from enforcing a statutory prohibition. It is equally true that promissory estoppel
cannot be used to compel the Government or a public authority to carry out a representation
or promise which is contrary to law or which was outside the authority or power of the officer
of the Government or of the public authority to make. We may also point out that the doctrine
of promissory estoppel being an equitable doctrine, it must yield when the equity so requires,
13[1988] 2 S.C.R. 530
18

if it can be shown by the Government or public authority that having regard to the facts as
they have transpired, it would be inequitable to hold the Government or public authority to
the promise or representation made by it, the Court would not raise an equity in favour of the
person to whom the promise or representation is made and enforce the promise or
representation against the Government or public authority.

CONCLUSION
The interpretations by Justice PN Bhagwati has been a benchmark in Indian Judiciary,
something which not only the local courts but the courts across the world look upto. He has
raised the bar for others to follow. Though he may have been on the wrong side of
interpretation in Habeas Corpus case, he has made up for it with his other endeavours
succeeding that.
Bibliography
www.westlaw.org
indiankanoon.org
legalservicesindia.com
lawyerscludindia.blogspot.in
Constitutional of india, VN shukla, EASTERN BOOK DEPOT, ALLAHBAD.
Constitution of india, JN pandey , central law, agency , Allahabad.
Indian penal code,KD gaur , central law agency Allahabad

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