The S.R. Bommai judgment transformed Indian federalism by curtailing gubernatorial arbitrariness. Assess its impact on centre–state relations and political governance.

Q. The S.R. Bommai judgment transformed Indian federalism by curtailing gubernatorial arbitrariness. Assess its impact on centre–state relations and political governance. (15 marks, 250-350 words)

Delivered by a nine-judge bench in 1994 after the dismissal of the Karnataka government, S.R. Bommai v. Union of India made Article 356 justiciable and shifted the test of majority from the Governor's satisfaction to the floor of the House [1]. Its impact has been transformative, though incomplete.

Impact on centre–state relations - Justiciability of Article 356 — the Presidential Proclamation became subject to judicial review for mala fides or irrelevant grounds, and the Assembly may only be suspended, not dissolved, until Parliament approves it [1]. - Curbing central misuse — the wave of dismissals of non-Congress governments in 1988–92 that provoked the case became hard to repeat; President's Rule turned into a last-resort rather than a routine instrument [1]. - Federalism as basic structure — states were affirmed as constitutional units, not administrative appendages. The Punchhi Commission built on this, urging localised emergency and exhaustion of dialogue before invoking Article 356 [2].

Impact on political governance - Floor-test supremacy — majority is tested only in the House, ending Governors certifying majority through letters and MLA parades [1]. - Judicial operationalisation — courts now order time-bound composite floor tests, as in Maharashtra (2019) and Madhya Pradesh (2020), shrinking the window for horse-trading. - Narrowing "pleasure" — Article 164(1) yields to collective responsibility under Article 164(2); a Chief Minister cannot be removed on the Governor's private assessment or on election results alone.

Unfinished agenda - Hung Assemblies — whom the Governor invites first remains unregulated (Goa 2017, Karnataka 2018), as Sarkaria Commission criteria are non-binding [3]. - Post-facto remedy — review comes after dissolution and defections have altered political facts. - Residual gaps — Article 361 immunity, delayed summoning of the House, and, until the pending Constitution (130th Amendment) Bill, 2025, no rule on ministers in prolonged detention [4].

On balance, Bommai moved the locus of legitimacy from Raj Bhavan to the Assembly floor and made federalism judicially enforceable, even if discretion survives at the margins. Codifying Sarkaria–Punchhi guidelines on government formation and fixing statutory time limits for floor tests would complete its promise — that in a federal democracy the people's House, not the Governor, decides who governs.

(~335 words)

Sources: 1. S.R. Bommai v. Union of India (1994) — Supreme Court of India, Digital Supreme Court Reports — judicial review of Article 356, floor test as sole test of majority, suspension not dissolution of the Assembly 2. Report of the Commission on Centre-State Relations (Punchhi Commission), 2010 — Inter-State Council Secretariat — localised emergency and dialogue before invoking Article 356 3. Report of the Sarkaria Commission — Inter-State Council Secretariat — non-binding criteria for the Governor in inviting a government in a hung Assembly 4. The Constitution (One Hundred and Thirtieth Amendment) Bill, 2025 — PRS Legislative Research — pending provision on cessation of office of Ministers on 31 days' detention