Maneka Gandhi's passport was impounded on July 4, 1977 under Section 10(3)(c) of the Passport Act of 1967. She filed a petition challenging the impounding as a violation of her rights to travel abroad and freedom of speech and expression under Articles 14, 19(1)(a), and 21 of the Indian Constitution. The Supreme Court ruled that Section 10(3)(c) granted vague powers to passport authorities and violated Article 14. The court established that any law depriving a person's liberty must also fulfill the requirements of Articles 14 and 19, and that "procedure established by law" is synonymous with "due process of law".

1. MANEKA GANDHI CASE Dev Prakash Singh

2. BRIEF ABOUT CASE
4th of July, 1977 : impound the passport of Smt. Maneka Gandhi
under sec10(3)(c) of the Passport Act, 1967
Reason for impounding the case.
Filled the petition with regard to the matter.
ISSUES: right go abroad, passport act, violates Art. 14,19(1)(a) and 21,
freedom of speech and expression.

3. JUDGEMENT
It was held that Section 10(3)(c) of the Passport Act confers vague and
undefined power on the passport authorities, it is violative of Article
14 of the Constitution.
Right to travel.
If a law is depriving a person a person from liberty, it has to fulfil
requirement of Act. 14 & 19 also.
Effect:
A new doctrine of “post decisional theory”
The court overruled existence law.
‘Procedure established by laws’ synonymous with ‘due process of
law’.

4. REFERENCE
Article 14 of the Constitution of India reads as under: “The State shall
not deny to any person equality before the law or the equal protection
of the laws within the territory of India.”