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S.R. Bommai vs. Union of India (1994): A Landmark in Federalism and Secularism

The S.R. Bommai vs. Union of India case is one of the most significant verdicts in Indian judicial history, focusing on the contours of federalism, the powers of the President under Article 356, and the core value of secularism enshrined in the Indian Constitution. In this blog post, we critically analyze the judgment, its wider implications, and its continuing significance in the current political and constitutional landscape.

1. Background of the Case

The crux of the S.R. Bommai case revolved around the misuse of Article 356 of the Indian Constitution. Article 356 empowers the President to impose President’s Rule in a state if, in his opinion, the state machinery has failed. Over the years, this provision was often misused for political purposes, leading to S.R. Bommai challenging the President’s decision to dissolve the Karnataka State Assembly in 1989.

2. The Core Issues

  • The legality and the extent to which the President’s power under Article 356 can be subjected to judicial review.
  • The circumstances under which the President can be justified in invoking Article 356.
  • The position of secularism as a part of the basic structure of the Indian Constitution.

3. The Court’s Decision

  • Judicial Review of Article 356: The Supreme Court held that the imposition of President’s Rule under Article 356 is justiciable. The Court can strike down the imposition of President’s Rule if it is found mala fide or based on extraneous grounds.
  • Secularism as Inviolable: The Court firmly stated that secularism is a part of the basic structure of the Constitution. Any violation of secularism by any government would be a valid ground for the imposition of President’s Rule.

4. Critical Analysis

  • Safeguarding Federalism: This judgment stands as a bulwark in defense of federalism in India. By making the imposition of Article 356 subject to judicial review, the Supreme Court ensured that the central government could not misuse its powers for political gains.
  • Reaffirming Secularism: The unequivocal stance of the Court in declaring secularism as an intrinsic part of the basic structure is commendable. This ensures that secularism, as a principle, remains untouchable, regardless of the party in power.
  • Yet, Challenges Remain: While the judgment laid down clear guidelines, the implementation and interpretation of Article 356 have continued to be contentious in various instances. The potential for misuse, although reduced, still remains a challenge.

5. Broader Implications

  • A Check on Centralization: The verdict acts as a check against the overarching centralization of power. It stands as a testament to the balance of power between the center and the states.
  • Boosting Public Confidence: By ensuring that the misuse of Article 356 would be subject to judicial scrutiny, the judgment enhanced public confidence in the judiciary and the democratic process.
  • Defining the Contours of Secularism: The judgment played a pivotal role in cementing the idea of secularism in the public discourse, ensuring that it is treated as a non-negotiable tenet of the Constitution.


The S.R. Bommai vs. Union of India case is more than just a judgment; it is a cornerstone in India’s constitutional democracy. It reiterates the principles of federalism and secularism, ensuring that they remain shielded from potential political misuse. The judgment serves as a reminder of the judiciary’s role in upholding the Constitution’s tenets and preserving the intricate balance of power that sustains the world’s largest democracy.

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