The Golden Triangle of India’s Constitution: Interplay of Articles 14, 19, & 21

Shivendra Pratap Singh


High Court Lucknow


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Introduction: At the heart of the Constitution of India lies the principle of ensuring fundamental rights to its citizens. Articles 14, 19, and 21, often termed the ‘Golden Triangle,’ form the crux of these rights. The interplay between these articles is pivotal in ensuring the holistic protection of individual rights while balancing the state’s interests.

Understanding the Articles:

  1. Article 14: Guarantees “equality before the law” and “equal protection of the laws.” It embodies the general principles of equality and non-discrimination.
  2. Article 19: Ensures six fundamental freedoms, including the freedoms of speech and expression, assembly, association, movement, residence, and profession. These rights aren’t absolute; they come with specific reasonable restrictions.
  3. Article 21: Asserts that “No person shall be deprived of his life or personal liberty except according to the procedure established by law.” Over the years, ‘life’ and ‘personal liberty’ have received expansive interpretations, encapsulating various rights.

Interplay and Interdependence:

  1. Expansive Interpretation of Article 21:
    • In the Maneka Gandhi vs. Union of India (1978) case, the Supreme Court held that the procedure under Article 21 must be fair, just, and reasonable. The case linked the values of Articles 14 and 19 into Article 21, suggesting that laws restricting personal liberty should not only be procedurally valid but also just, fair, and reasonable.
  2. Conjoined Reading for Justice:
    • The case of Olga Tellis vs. Bombay Municipal Corporation (1985) concerning the eviction of pavement dwellers is a prime example. The Court held that the right to livelihood is derived from Article 21. Any eviction that deprives this right must be just, fair, and reasonable, and the affected parties should be given an opportunity to be heard.
  3. Freedom of Press and Personal Liberty:
    • The Press has its freedom under Article 19(1)(a) – Freedom of Speech and Expression. However, this freedom intertwines with Article 21 when it comes to the right to know. The citizens’ right to be informed and the press’s right to express information is where Articles 19 and 21 meet.
  4. Article 19’s Restriction & Fairness:
    • Any restriction imposed under Article 19 has to be tested against the fairness principle embedded in Articles 14 and 21. For instance, any law that curtails freedom of speech should not be arbitrary (Article 14) and must adhere to a procedure that’s just, fair, and reasonable (Article 21).

Balancing Act:

While these Articles aim to safeguard individual rights, they also consider the collective interest. The ‘reasonable restrictions’ in Article 19 or the ‘procedure established by law’ in Article 21 provide room for the state to act in larger public interest, but always within the bounds set by Articles 14, 19, and 21.


The intertwined nature of Articles 14, 19, and 21 demonstrates the vision of India’s constitutional framers – a vision of a nation that doesn’t view rights in isolation but as part of an interconnected web ensuring a dignified life for all. This interplay has been pivotal in landmark judgments, emphasizing the importance of a holistic approach when it comes to human rights and the role of the state.