State of Rajasthan v Union of India
Rule established
The satisfaction of the President under Article 356 is subjective and largely political, and was held reviewable only in the narrowest circumstances, such as where the action rested on wholly extraneous considerations or was mala fide. The decision has since been substantially superseded by S R Bommai.
Facts
- The general election to the House of the People held in 1977 resulted in the heavy defeat of the party which had until then been in power at the Centre.
- In nine States that party continued to hold office in the State Governments, its Assemblies having been elected earlier.
- The Union Home Minister addressed communications to the Chief Ministers of those States suggesting that they advise dissolution of their Legislative Assemblies and seek a fresh mandate, on the footing that the general election showed they had lost the confidence of the electorate.
- The communications carried the implication that if they did not do so, action under Art.356 might follow.
- Several of the States instituted suits against the Union in the Supreme Court under Art.131, seeking to restrain such action.
- No Proclamation had yet been issued at the time the suits were filed.
Issue
- Whether the President's satisfaction under Art.356 is justiciable; and whether a defeat at a general election to the House of the People is a relevant consideration in assessing whether a State Government retains the confidence of the people.
Held
- The suits failed. The Court took a narrow view of justiciability, holding that the satisfaction required by Art.356 is subjective, resting on an assessment of a political situation which the Court is neither equipped nor entitled to make. It could be examined only in the most limited circumstances, essentially where the action was shown to be founded on wholly extraneous or irrelevant considerations, or to be mala fide. On the substantive point, the majority accepted that the verdict of a general election to the House of the People could legitimately be taken into account in forming a view whether a State Government still enjoyed the confidence of the people of the State, so a communication inviting dissolution on that basis was not improper.
Ratio Decidendi
Article 356 confers a power to be exercised on the President's satisfaction, and where a Constitution commits an assessment to a named functionary in subjective terms, a court substituting its own assessment would be exercising the power itself. Political judgments of this character depend on materials and considerations that are not susceptible of judicial evaluation by the ordinary standards of proof, which is why the reviewing jurisdiction was confined to the extremes of bad faith and irrelevance.
How to use it in an exam
- Cite it as the starting point and the earlier deferential position, and then state plainly that it has been substantially superseded by S R Bommai v Union of India 1994.
- The specific holding that has not survived is the acceptance of a defeat at a parliamentary general election as a ground affecting a State Government's mandate. Bommai rejected that reasoning, since a State Ministry answers to its own Assembly and not to the national electorate.
- Contrast the standard of review. Here it was confined to mala fides and wholly extraneous considerations, with the burden effectively on the challenger. Under Bommai the Court examines whether there was any material and whether it was relevant, and the burden lies on the Union to produce it.
- The case remains useful on Art.131, since the suits were entertained as disputes between the Union and States involving legal rights, alongside State of West Bengal v Union of India 1963 and State of Karnataka v Union of India 1977.
- Use it in an evaluative answer on the misuse of Art.356, together with the Sarkaria Commission's recommendation that the power be used sparingly and as a last resort, and Rameshwar Prasad v Union of India 2006 on the requirement of material.
Source
Source: (1977) 3 SCC 592; AIR 1977 SC 1361; Bench of seven Judges; the earlier deferential position on Art.356, substantially superseded by S R Bommai (1994); citation and bench checked against Indian Kanoon and reported sources, audit of 12 August 2026
This is an educational summary, not the judgment itself. Cite the reported version in professional or academic work.