P.V. Narasimha Rao case
Also called: JMM bribery case (1998), P.V. Narasimha Rao v. State · Topic: Parliamentary Procedure, Committees and Privileges · NCERT: Class 11, Ch 6 "Judiciary"
Meaning
In P.V. Narasimha Rao v. State (1998), the Supreme Court dealt with MPs accused of taking bribes to vote against a no-confidence motion in 1993. The court held that these MPs were immune under Article 105(2), which protects members from court action over any vote given in Parliament. Critics said this protected corruption. In 2024 a seven-judge bench overruled it in the Sita Soren case. That bench held that bribery is not protected by Article 105 or Article 194.
Example
In the 1993 no-confidence vote, some MPs were said to have taken money to vote for the government. Under the 1998 ruling, the MPs who took bribes and voted could not be prosecuted for it. This was later held wrong in Sita Soren (2024).
Don't confuse with
- Sita Soren case (2024): this is the later ruling that overruled Narasimha Rao. Today the law is that taking a bribe to vote or speak gets no immunity.
Related concepts
- Parliamentary privileges
- Individual privileges
- Collective privileges
- Bar on courts inquiring into parliamentary proceedings
- Breach of privilege
- Contempt of the House
- Privilege motion
- Committee of Privileges
- Ethics Committee
- Keshav Singh case