Golden triangle

Polity & Governance glossary

Also called: Articles 14, 19 and 21 · Topic: Fundamental Rights and Constitutional Remedies · NCERT: Beyond NCERT

Meaning

The golden triangle is a popular name for three articles read together:

  • Article 14: equality before law;
  • Article 19: the freedoms;
  • Article 21: life and personal liberty.

The idea comes from Maneka Gandhi (1978), which said these rights are connected, not separate boxes. Minerva Mills (1980) is linked to the name. Under it, a law that limits a person's liberty must pass the tests of all three articles. Its procedure must also be "right, just and fair".

Example

In Maneka Gandhi (1978), the government impounded a passport without giving reasons. The Court tested this action against Articles 14, 19 and 21 together, not Article 21 alone. That brought due process into Article 21 in substance. Due process means asking whether the law itself is fair, not only whether a law exists.

Don't confuse with

  • A.K. Gopalan approach (1950): this treated each right as a separate box and accepted any procedure laid down in an enacted law. The golden triangle reads the rights together.

Related concepts

Read more