S. R. Bommai v. Union of India

S. R. Bommai v. Union of India ([1994] 2 SCR 644 : AIR 1994 SC 1918 : (1994)3 SCC1) is a landmark decision of the Supreme Court of India, where the Court discussed at length provisions of Article 356 of the Constitution of India and related issues. This case had a huge impact on Centre-State Relations. The judgement attempted to curb blatant misuse of Article 356 of the Constitution of India, which allowed President's rule to be imposed over state governments. S. R. Bommai, former Chief Minister of Karnataka, is widely remembered as the champion for this landmark judgment of the Supreme Court of India, considered one of the most quoted verdicts in the country's political history.

Background (Article 356 and President’s Rule): Article 356 allows the Central Government to impose President’s Rule in a State. When this happens, the elected State government and its Council of Ministers are dismissed, and the Governor (appointed by the President) takes direct control. This goes against the federal nature of India’s Constitution, where power is meant to be shared between Centre and States, and also weakens democracy by suspending an elected government.

Dr. B.R. Ambedkar, during the Constituent Assembly debates, had called Article 356 a “dead letter” and hoped it would rarely be used. He suggested that the President should first warn the State, and if needed, call for fresh elections, using Article 356 only as a last resort.

However, before the S.R. Bommai judgment, Article 356 was frequently misused by the Centre to remove State governments led by rival parties. It was invoked more than 90 times, often on doubtful grounds, making it one of the most controversial provisions of the Constitution.