DOCTRINE OF RULE OF LAW: AN INDIAN PERSPECTIVE
By

-- Shivangi Mahajan, Law Student --

SHIVANGI MAHAJAN[1]

ABSTRACT: This research paper delves into the everchanging nature of the rule of law and how it has been implemented in India throughout its history. Why do we expect law to bring about better and more just societies? Around the world, systems of accountability are weak and dictators find ways to avoid the constraints of both national and international law. The paradox is that we believe in the rule of law and that we insist it should constrain power in practical and effective ways to be worth creating at all. Rule of law is one of the basic principles of the English constitution. This doctrine has been enshrined in the Constitution of U.S.A and in the Constitution of India as well.

KEYWORDS: - Rule of Law, Power, International and National Law, History.

INTRODUCTION[2]:- Administrative law is a separate branch of law and a subject for academic study but since last few decades, it has gained full stature as a “responsible” field of study for the law students and practitioners. So, to recognize its independent existence, the people of England used the weapon of Dicey’s concept of Rule of Law to strike the growth of administrative law. ‘Rule of Law’ is a new ‘lingua franca’ of global moral thought and the supreme manifestation of human civilization and culture. Thus, rule of law adds eternal value to the Constitution and an inherent attribute for democracy and good governance. This concept is an animation of natural law and remains a historical idea which makes a powerful appeal not by a powerful man but by the Rule of Law. So, it can be well quoted by Lal Bahadur Shastri that –

  The Rule of law ought to be respected with the goal that the basic structure of our democracy is maintained and further reinforced”.

CONCEPT OF RULE OF LAW[3] :-

        As the term itself connotes, “Rule of Law” means rule of law and not of men. The expression “Rule of Law” is derived from the French phrase ‘le principe de legalite’ meaning the principle of legality. The doctrine has been described as supremacy of the law. This means that where there is rule of law no person can be said to be above the law, even the functions and actions of the executive organ of the state shall be within the ambit of the law.

        Rule of law imposes a duty on all citizens in a parliamentary democracy to obey the law itself must be just law and not arbitrary or oppressive law. The aim of Rule of law like other constitutional principles is the uplifting of freedom and fundamental rights of the people. The rule of law has propounded to make sure that the executive doesn’t use law of the land or country to oppress or curtail freedom of individuals as they are found in the bill of rights. In the Indian context, the meaning of rule of law has somewhat been much expanded. The Supreme court has in various occasions further enunciated and illustrated the rule of law through its judgement in furtherance of the basic principles as laid down by A.V. Dicey[4] . It is considered as a part of the basic structure of the Constitution and, hence, it cannot be abrogated or destroyed even by the Parliament. The ideals of constitution; liberty, equality and fraternity have been enshrined in the preamble. Rule of law mandates that no person shall be subjected to harsh, uncivilised or discriminatory treatment even if the object is to protect and secure law and order.

THE ORIGIN OF THE RULE OF LAW[5] :-

        The rule of law is an established principle with a long history. Around 350 BC, prominent ancient Greek philosophers like Plato and Aristotle brought it up in conversation. To paraphrase Aristotle, “Law should govern and those in power should be servants of the laws.” This statement demonstrates Aristotle’s support for the rule of law. Later on, other European medieval philosophers – including Hobbs, Locke, and Rousseau- took up the cause via the social contract thesis. In the own unique ways, Indian thinkers like Chanakya have advocated for the rule of law, arguing that the king ought to be governed by the letter of the law. The establishment of legislatures, according to Locke, ought to be done by majority vote.

        The idea behind this came from Sir Edward Coke, who was the chief justice during reign of King James. He insisted that the monarch ought to submit to God and the law. He proved that the rule of law is paramount and that it may be used as a weapon against the executive branch.

RULE OF LAW POST – INDEPENDENCE[6]:-

        The Indian constitution’s founders welcomed the rule of law. The preamble guarantees the provision of equal status and opportunities, as well as the promotion of these principles among all individuals. It grants citizens the most crucial basic rights.

        The Supreme Court and High Courts are responsible for safeguarding the Articles from12 to 35 of part 3 of the constitution of India

        According to Article 14 of the constitution, the State is prohibited from denying any person equality before the law within the territory of India. Nevertheless, it should be acknowledged that there are a limited number of cases where the principle of equality does not apply.

        As per Article 361, the President or Governor of a State cannot be held accountable in court for their actions and responsibilities in their respective offices. However, the President’s behaviour can be reviewed if charges are brought against them under Article 61. This article allows any individual to initiate legal proceedings against a state Governor.

        As to Article 20[1] of the constitution, individuals can only be convicted of an offense if they have violated a law that was in effect at the time they committed the act in question.

        Article 21 states that individuals cannot be deprived of their life or personal freedom unless it is done in accordance with the legal process.

        According to Article 14, discussions about the behaviour of judges in the Supreme court or High court during their duties are not allowed in Parliament, unless there is a motion to address the President and request the removal of the judge, as specified later on. The principle of the rule of law is considered an integral component of the fundamental framework of the constitution, and as such, it is immune to being abolished or eradicated by the parliament. The Rule of Law governs and oversees every aspect of the state’s institutions. The mandate is our constitution. It is a principle that governs the legal system.

DICEY’S CONCEPT[7]:-

 The expression rule of law was given prominence by Dicey. According to him, the rule of law is one of the cardinal principles of the English legal system. He attributed the following three meanings to the doctrine:

    Supremacy of law

    Equality before law; and

    Predominance of legal spirit.

1.    SUPREMACY OF LAW: - Expounding the first postulate, Dicey states that rule of law means the absolute supremacy or predominance of regular law as opposed to the influence of arbitrary power or wide discretionary power. It excludes the existence of arbitrariness of prerogative power or even wide discretionary authority on the part of government. He asserted that the Englishmen were ruled by the law, and by the law alone; he denied that in England the government was based on exercise by persons in authority of wide arbitrary, or discretionary powers.

 Dicey’s claimed “wherever there is discretion there is room for arbitrariness and that in a republic no less than under a monarchy discretionary authority on the part of its subject”[8]. Accordingly Wade[9] also says, “The Rule of Law requires that the government should be subject to the law, rather than the law subject to the government”.

2.    EQUALITY BEFORE LAW: - Explaining the second postulate of the doctrine of rule of law, Dicey says that there must be equality before the law or the equal subjection of all classes to the ordinary law of the land administered by the ordinary law courts. In England, he maintained, all persons were subject to one and the same law, and there were no extraordinary tribunals or special courts for officers of the government and other authorities. According to him courts are supreme throughout the state. In this connection he criticized the French legal system of droit administrative in which there were separate administrative citizens. In his view, exemption of civil servants from the jurisdiction of the ordinary courts of law and providing them with the special tribunals was the negation of equality.

3.    PREDOMINANCE OF LEGAL SPIRIT: - Explaining the third postulate, Dicey says that the general principles of the constitution are the result of judicial decisions of the courts in England. In many countries rights are guaranteed by a written constitution; in England it is not so. Those rights are the result of judicial decisions in concrete cases which have actually arisen between the parties. The constitution is not the source but consequence of the rights of the individuals. Dicey apprehended that if the source of fundamental right of the people is any written constitution, the right can be abrogated at any time by amending the constitution. In this way rule of law postulates judicial supremacy.

RULE OF LAW IN INDIAN CONSTITUTION [10]:-

        The notion of the rule of law can be ascribed back to the Hindu scriptures in India. Its roots can also be detected in sagas and epics such as the Ramayana and Mahabharata, and also the ten commandments, the dharma chakra, as well as other fundamental sacred writings. There have been no writings in contemporary days that expressly examine or acknowledge the theory of rule of law. The rule of law is considered to be to be incorporated in numerous clauses of the Indian constitution. The founders of the constitution were not just acquainted with Dicey’s postulates of rule of law, but also with their application in British India.

        The constitution of India is the guiding principle of the nation, from which all other laws acquire their legitimacy, making all other laws acquire their legitimacy, making all other laws subordinate to it and following the postulates of the rule of law outlined by the constitution.

        Furthermore, Article 13[1][11] specifies that every law passed by the legislature must be in accordance with the provisions of the constitution, or it will be considered unconstitutional. As a result, any new law must be consistent with the requirements of the constitution. Even the preamble of the constitution of India includes the word justice, sovereignty, and equality, which are unambiguous indicators of a just and fair government with no discrepancy amongst the masses regardless of their social status.

        Dicey’s enumeration of equality before the law is included under Article 14 of the Indian constitution, which establishes the idea of equality before law and equal protection under the law. The right to life and personal liberty, which is a fundamental human right, is also enshrined in the constitution for all citizens.

        The word ‘rule of law’ has no set formulation in the Indian constitution. However, courts in India use it in a plethora of judgements. In India, the proverb ‘The King can do no wrong’ does not apply, as all public institutions are subject to the jurisdiction of common law courts and the same sets of laws. The constitution is the supreme law of the land, superseding the 3 organs of the government i.e.,

The Judiciary

The Executive

The Legislature

These three governmental organs must act in accordance with the principles enshrined in the Constitution of India.

RULE OF LAW AND JUDICIAL SYSTEM OF INDIA[12]:-

The judiciary has consistently worked to uphold the Rule of Law and has had equal backing from citizens and the state by adhering to the legislation as laid down by the legislature and enforced by the courts. Though there have been numerous occasions where the citizens have engaged in violence against the parliamentary act or any judicial proceedings or doing actions contrary to law.

Along with the provisions of the constitution, the judgements [13]given by several courts and tribunals have played a prominent role in the interpretation and advancement of the doctrine of rule of law in India. It has been opined by several distinguished jurists of India that the constitution of India is founded on the principle of the rule of law.

 In a subsequent decision, the supreme court observed that the rule of law, as enshrined in Article 14 of the constitution, is a basic feature of the Indian constitution and thus cannot be amended, revoked, or modified even by a constitutional amendment under Article 368 of the constitution. In accordance with the third postulate of the rule of law principle, India has a strong judicial system that checks other organs of government while carrying out work independently.

LANDMARK CASE LAWS: -

In Keshavananda Bharati V. State of Kerala[14] ,the court propounded the principle of basic structure and held that any part of the constitution can be amended without modifying the basic structure of it.

In the case of Indira Gandhi V. Raj Narain[15], the court decided that the ‘rule of law’ is also a part of the basic structure of the constitution and hence, it cannot be amended.

In the case of State of Bihar V. Sonawati Kumari [16], the court held that as per the concept of ‘rule of law’, all the authorities operating within the state including executive government is bound to obey the rules.

In the case of Bachan Singh V. State of Punjab[17] , the five bench judges comprising of justice Y Chandrachud, justice A Gupta, Justice P Bhagwati and Justice R Sarkaria, held that the concept of rule of law is free from arbitrary action and if any action is done with arbitrary power, then it will be considered as the denial of rule of law. This case is also known as “death penalty case”.

In the case of Som Raj V. State of Haryana[18], the three bench judge of supreme court comprising of Justice K Puttaswamy, justice Raghunath Mishra and Justice M.M Punchhi, held that the absence of arbitrary power is the absolute aim of the principle of rule of law upon which directly the whole constitution is dependent.

In the case of ADM Jabalpur V. Shivkant Shukla[19] , popularly known as the habeas corpus case, is one of the most important cases of rule of law. In this case a question arose before the court whether rule of law in India is apart from Article 21 of the Indian constitution. Thus, the five judge bench comprising of Justice A.N Ray, Justice Hans Raj Khanna, Justice M Hameedullah, Justice Y.V Chandrachud and Justice P.N Bhagwati held that there is no rule apart from Article 21 and there can never be a separate rule of law.

The Supreme court extended the scope of Rule of law in the case of Veena Seth vs. State of Bihar[20], where the court stated that rule of law extends to the poor and the downtrodden, ignorant and the illiterate, who constitute the majority of humanity in India. The court ruled that the Rule of law does not exist merely for those who have the means to fight for their rights and often do so for the perpetuation of the status quo which protects and preserves their dominance and permits them to exploit a large section of the community.

In the case of Union of India V. Raghubir Singh[21], the court held that the principle of ‘rule of law’ is a considerable degree which governs the lives of the people and regulates the functions of the state from the decision of the superior courts.

In the case of Chief settlement Punjab V. Om Prakash and Ors.[22], the Supreme court observed that in the present scenario, the authority of the law courts is to test the administrative actions by the standard of legality.

The Supreme court in the case of S.G Jaisinghani V. Union of India[23], characterized the prerequisites of rule of law in a very lucid manner. Here the court observed that the rule of law means that decisions should be made by the application of known principles and such decision should be predictable and the citizen should know where he is. But if a decision is made without referring to any principle, then it is unpredictable and such decision is the antithesis of a decision taken in accordance with the rule of law.

In the case Supreme Court Advocates on Record Association V. Union of India[24] , also known as the “second judges’ case”, the supreme court held that the absence of arbitrariness is one of the important concepts of rule of law.

The constitution bench of the court in the case of Secretary, State of Karnataka and Ors V. Umadevi and Ors.[25] , stated that “Thus, it is clear that adherence to the rule adherence to the rule of equality in public employment is a basic feature of our constitution and since the rule of law is the core of our constitution, a court would certainly be disables from passing an order maintaining and infringement of article 14 in requesting the ignoring of the need to agree to the necessity of article 14 read with article 16 of the constitution".

MODERN CONCEPT OF THE RULE OF LAW [26]

The modern concept of the rule of law is fairly wide. Davis [27]gives seven principal meaning of the term Rule of law: -

1.    Law and Order;

2.    Fixed rules;

3.    Elimination of discretion;

4.    Due process of law or fairness;

5.    Natural law or observance of the principles of natural justice;

6.    Preference for judges and ordinary courts of law to executive authorities and administrative tribunals; and

7.    Judicial review of administrative action.

CONCLUSION[28]:-

 The concept of rule of law was not without flaws, but it managed to subdue the powers of the executive branch via its actions, and for this reason, many nations have accepted it as the guardian of their constitutions. This technique is the most effective means to attain the highest authority of law. The court has made deliberate attempts to establish a connection between the concept of rule of law and human rights. Therefore, the government, guided by the principle of rule of law, establishes regulations and circumstances that do not infringe upon the dignity of any individual.

REFERENCES: -

BOOKS

A.V Dicey, introduction to the study of the law of the constitution.

M.P Jain, Indian constitutional law

Dr. J.J.R UPADHYAYA Administrative law.

 CASE LAWS

Kesavananda Bharati v. State of Kerala (1973) 4 SCC 225.

Indira Nehru Gandhi v. Raj Narain AIR 1975 SC 2299.

ADM Jabalpur v. Shivkant Shukla AIR 1976 SC 1207.

Bachan Singh v. State of Punjab AIR 1980 SC 898.

Som Raj v. State of Haryana AIR 1990 SC 1176.

Veena Seth v. State of Bihar AIR 1983 SC 339.

Union of India v. Raghubir Singh AIR 1989 SC 1933.

S.G. Jaisinghani v. Union of India AIR 1967 SC 1427.

Secretary, State of Karnataka v. Umadevi AIR 2006 SC 1806.

Supreme Court Advocates-on-Record Association v. Union of India AIR 1994 SC 268.

Chief Settlement Commissioner, Punjab v. Om Prakash AIR 1969 SC 33.

State of Bihar v. Sonawati Kumari AIR 1961 SC 221

ARTICLES AND JOURNALS: -

    IJCRT, Tanya Sharma, RULE OF LAW: A DETAILED ANALYSIS

    LAWOCTOPUS, K.R Adithyaa Shankar, evolution of rule of law and action in India.

    IPLEADERS, SHRAILEEN KAUR, Rule of law.

    Upendra Baxi, “The rule of law in India” sur international journal on human rights.



[1] STUDENT OF BBALLB 3RD YEAR, CHANDIGARH LAW COLLEGE

[2] IJCRT, RULE OF LAW, VOLUME 8, 2020

[3] A.V DICEY, Introduction to the study of the law of the constitution, 10th ed., pp. 183-188

[4] J.J.R. Upadhyaya, Administrative law, 8th ed., 2018, pp.36-40

[5] Academike, Evolution of rule of law, September 2, 2024

[6] M.P Jain, Indian constitutional law ,7th ed., 2014, pp. 146-153

[7] Dr. J.J.R Upadhyaya, central law agency pp.36-37

[8]Dicey, law of the constitution, 8th ed., pp. 198

[9] Administrative law, 1988 p. 24

[10] Ipleaders, Shraileen Kaur, July 5 2022

[11] The constitution of India, 1950, preamble and Article 13 [1]

[12] M.P Jain, constitutional law, 7th ed., 2014, pp. 170-175

[13] Keshavananda Bharati V. State of Kerala, [1973] 4 SCC 225

[14] [1973] 4 SCC 225

[15] [1961] AIR 865

[16] [1961] AIR 221

[17] [1980] AIR, SC 898

[18] [1990] AIR 1176

[19] [1976] AIR 1207

[20] AIR [1983] SC 339

[21] AIR [1989] 1933

[22] AIR [1969] 33

[23] AIR [1967] 1427

[24] AIR [1994] SC 268

[25] AIR [2006] SC 1806

[26] J.J.R. Upadhyaya, Administrative law, 8th ed., 2018, pp.38-39

[27] Administrative law,1959, pp.,24-27                                  

[28] K.R Adithya, “rule of law”, lawoctopus, 2019


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