Golden Triangle of Indian Constitution

Indian Constitution

In terms of sovereignty, the Constitution of India is the longest written Constitution, having 470 Articles, grouped into 25 Parts, along with 12 Schedules. That sounds like a lot of words, and a lot of laws, and since it is the supreme law of the land, it enshrines the basic principles of governing the country. Apart from the 25 parts, the Constitution of India also has a Preamble to it, which is often called the “basic structure” of the Constitution, because it represents a sort of introduction to the whole text, along with providing an insight to the document. The powers and duties of the government, the rights and duties of people, division and separation of the powers, various organs of the government, directive principles etc. are all mentioned in the Constitution. It is called a “living constitution”, because it can be amended as per the needs and aspirations of the people. It is rigid and flexible at the same time, allowing it to be static and dynamic at relevant issues.

The Indian Constitution can be said to be a “lawyer’s paradise”, because it consists of legal jargon, much suited to those in the legal profession, and hardly comprehended by the common man. But certain basic features of the Constitution are known to all, be it our politicians, the media, or even elements of public unrest. One of the most widely used and talked about are the Fundamental Rights, mentioned in Part III of the Constitution, from Article 12 to 35.

Fundamental Rights

The Fundamental Rights of our Constitution find their origin in many documents, such as the Bill of Rights in England, the Bill of Rights of the United States, and the Declaration of France on the Rights of Man. The framers of our Constitution felt that these rights were necessary for the preservation of democracy and for the development of every individual. Each right has been accorded the status of being fundamental, in the sense that it cannot be taken away by the State or any other individual, and even if this happens, one can always approach the courts for their enforcement, which is again, a fundamental right.

It is generally said that there are 6 fundamental rights, although there are more than that because every right is branched out into particular rights, but overall they are deemed to be 6.

Article 14 mentions the Right to Equality, which holds that all people are equal before the law.

Article 19 mentions the Right to Freedom, which includes certain freedoms of speech, movement, profession, and also includes the right to information.

Articles 23 and 24 state the Right against Exploitation, and protect certain groups of people from being exploited by others.

Articles 25 to 28 provide the Right to Freedom of Religion, considering the fact that India is home to a diversity of faiths, and the State is obliged to protect the faith of every individual.

Articles 29 and 30 mention Cultural and Educational Rights, mainly for the backward sections and minorities of the country.

Article 32 states the Right to Constitutional Remedies, wherein a citizen can approach the court if his/her fundamental rights have been violated.

As stated earlier, there are other significant rights as well, such as the Right to Life and Personal Liberty under Article 21, which comes under the umbrella of Article 19, and the Right to Education, under Article 21A, also under Article 19. Each right holds importance, however, there are three major fundamental rights which are given a lot of weightage, and when combined together form the Golden Triangle of Indian Constitution.

Golden Triangle of Indian Constitution

Article 14, Article 19 and Article 21 of the Indian Constitution form what is called the Golden Triangle in the Fundamental Rights. This development came about when Justice P. N. Bhagwati gave an eye-opening verdict in a case, which went on to become a patron of the Rule of Law. In Maneka Gandhi v. Union of India[1], it was held that when a law is such that it deprives a person of his/her ‘personal liberty’, then that law has to stand the test of not only Article 21 (right to life and personal liberty), but also of Article 14 (right to equality) and Article 19 (right to freedom).

Article 14 of the Constitution states the most important right among all, the right to be equal in the eyes of law. It sets equality among people, whatever be their age, gender, caste, religion or place of birth. The law will treat every citizen equally and will not discriminate against anyone on whimsical grounds. Not only this, but the law will also protect anyone from being treated unequally. The concept of equality goes a step further and allows the law to classify persons for legitimate purposes in a non-arbitrary manner, so that similar people can be treated equally in similar circumstances.

Article 19 is another major article in the sense that it guarantees several basic freedoms, which are listed below:

  • The freedom of speech and expression
  • The freedom of peaceful assembly without arms
  • The freedom to form unions or associations
  • The freedom of movement throughout the territory of India
  • The freedom of residing and settling throughout the territory of India
  • The freedom of profession, to carry on any occupation, trade or business

Without these freedoms, it would be almost impossible to live in a country, because otherwise, everything would be regulated by the government, which would result in the destruction of the concept of free will. The right to freedom of speech and expression is vital when it comes to a democratic country because it questions the authority of those in power when required. The freedom of movement and to settle down in India assure us that this country is our own and is open to us.

The right to form associations for a positive purpose is essential as it allows individuals to come together and think together, and subsequently act together. The freedom of assembly without arms simply promotes organic public gatherings, and the freedom to practice any profession, or to carry out trade or business of one’s choice is needed because this is an individual stance, as long as the profession or trade is not illegal or unlawful.

Article 19 is further protected by Articles 20, 21 and 22, which have been, supposedly, the most debated articles in the Constituent Assembly. Since Article 21 guarantees the right to life and personal liberty, it is the prime human right, without which, human existence is impossible. The Article involved much controversy up till 1978, when it was worded to mean that this right could be taken away by “due process of law”.This restricted the right to executive action only.

However, it was in 1978, and in Maneka Gandhi’s case itself, that the Supreme Court extended the right’s application and replaced the words “due process of law” by stating that a law that laid down a procedure should be fair, just and reasonable, thus allowing legislative action also under the ambit of restriction. The right to life and personal liberty cannot be suspended even during emergency.

Maneka Gandhi vs Union of India

The simple facts of this case were that the passport of Maneka Gandhi, who is an Indian politician, an environmentalist, and an animal rights activist, was impounded (confiscated) by reason of ‘public interest’ on July 2nd, 1977, under the Passport Act of 1967. When the reasons for the same were demanded, the Government of India refused to put out any such reasons, and also denied to hear Gandhi. Maneka Gandhi filed a writ under Article 32 of the Indian Constitution, stating that her Fundamental Rights under Articles 14, 19 and 21 had been violated.

This case is a landmark judgement of Fundamental Rights, and it overruled the judgement of A. K. Gopalan v. State of Madras[2], wherein it was held that the Fundamental Rights were exclusive of each other. The Court established a connection between Articles 14, 19 and 21, which was referred to as the Golden Triangle or Trinity of Indian Constitution, and stated that a law which takes away the personal liberty of a person also deprives a person of the right to equality and the right to freedom under Articles 14 and 19, respectively.

The seven-judge bench held that there exists a ‘triumvirate’ between Articles 14, 19 and 21, and that they have to be read together. Any law that encroaches upon the personal liberty of an individual must go through three separate tests:

  • It should prescribe a procedure.
  • The said procedure must comply with any of the provisions of Article 19, whichever are pertaining to it.
  • The procedure must also comply with the requirements of Article 14. If a procedure fails to withstand Article 14 it would not be a procedure under Article 21.

Justice P. N. Bhagwati wrote a plural judgement on behalf of Justice Untwalia and Justice Fazal Ali. Justice Chandrachud, Justice Krishna Iyer, and Chief Justice Beg wrote their own judgements in conformity; Justice Kailasam wrote a dissenting opinion.


The Indian Constitution is full of detailed spectra, and when one spectrum opens, it leaves various questions in the minds of thinkers. The Constitution is not simply a book of law, it is a legacy, of our constitution-makers, who thought out every word and then put it into writing. Constitutional law tends to examine this very thought-process, and tries to bring into light what would have been the intention of the Constituent Assembly while framing a certain right, duty, provision etc. It is important that we do not let the essence of our Constitution die by skimming through its provisions without stopping to ponder over.

The judiciary plays a vital role in maintaining the system of checks and balances in the government, a major reason of it being its independence. The judiciary is not subordinate to the legislature or the executive, rather it stands beside them just to make sure they do not act against the public. Judgements like the one in Maneka Gandhi’s case have had a major influence on the constitutional law of India.

Maneka Gandhi’s case, in particular, highlights that moment in the history of judicial decisions when the Supreme Court rejected the decades of formal interpretation of the Constitution, and showed us a new path whereby the courts would focus on stretching the rights of the citizens against the State, instead of limiting them. Several decisions following in the footsteps of this case arrived, and were accepted without dissent.

The three Articles, 14, 19 and 21, stand as a guard against the arbitrary and capricious acts of the government. They play a very important role in the operation of the judiciary with respect to Fundamental Rights, and knowingly or unknowingly, they affect our daily lives as a citizen of this country. There is no restriction on exercising these rights since they were formulated with a view to be absolute to the extent that their exercise would not cause harm to another individual or the State. These three articles are a reminder to the ruling power that the fundamental protections of citizens is of utmost importance and any law that tries to affect it negatively would be struck down by the judiciary.

In present times, such decisions of the Supreme Court or any other court, are required at the earliest, when multiple human rights are being violated at once. The judiciary is said to be the shoulder for the people, which has the ability to hear a citizen when the government wouldn’t. Article 14, Article 19 and Article 21 are called the Golden Triangle of Indian Constitution because it is a glorifying feature of the Constitution of India.

FAQs on Golden Triangle of Indian Constitution

In which case was the golden triangle established?

The Golden Triangle of Indian Constitution was established in case of Maneka Gandhi v. Union of India.

Which articles are called the Golden Triangle of Indian Constitution?

Article 14, Article 19 and Article 21 are called the Golden Triangle of Indian Constitution.

[1] AIR 1978 SC 597.

[2] AIR 1950 SC 27.

Zara Suhail Ahmed

Zahra is a student at Aligarh Muslim University, pursuing a 5-year B.A. LLB course. Currently in her 4th year, Zahra opted for Law after completing most part of her schooling from Cambridge School, New Delhi. Zahra has interned under a few lawyers and firms, participated in various moot courts and similar events, and is proficient in research and written content. A strong believer that education is the greatest virtue, Zahra seeks to learn from every platform and individual, whether working alone or as a team. Although Zahra is keenly interested to pursue ADR (Alternate Dispute Resolution) as a career, she has kept her options open and is interested in examining the different career prospects that her profession has to offer. Zahra has diversified interests apart from her professional life as well. Not only a successful lawyer, but she also aspires to become a productive human being.