"Rule of Law is the antithesis of arbitrariness". Justice Khanna observed this in the case of ______________.

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  1. Chairman, Railway Board v. Chandrima Das
  2. Vishaka v. State of Rajasthan
  3. State of Rajasthan v. Vidyawati
  4. ADM Jabalpur v. S Shukla

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Option 4 : ADM Jabalpur v. S Shukla
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The correct answer is 'ADM Jabalpur v. S.S. Shukla'

Key Points

  • ADM Jabalpur v. S.S. Shukla:
    • In this landmark case, popularly known as the "Habeas Corpus case," the Supreme Court dealt with the suspension of fundamental rights, specifically the right to approach courts during the Emergency declared in India in 1975.
    • Justice H.R. Khanna famously dissented in this case, asserting that the "Rule of Law is the antithesis of arbitrariness," emphasizing that even during emergencies, the judiciary must uphold citizens' rights and prevent arbitrary actions by the State.
    • The majority judgment upheld the government's stance that during the Emergency, individuals could not approach courts for the enforcement of fundamental rights. However, Justice Khanna's dissent is celebrated for its defense of constitutionalism and the Rule of Law.
    • This case highlighted the tension between executive authority and judicial independence, and Justice Khanna's observations about the Rule of Law remain a cornerstone of constitutional jurisprudence in India.

Additional Information

  • Chairman, Railway Board v. Chandrima Das:
    • This case dealt with the issue of compensation for a victim of gang rape in a railway premises. The court held that the State has a responsibility to uphold the dignity of individuals under Article 21 of the Constitution.
    • While the case is significant for its interpretation of Article 21, it does not relate to the principle of Rule of Law or arbitrariness specifically.
  • Vishaka v. State of Rajasthan:
    • This case laid down guidelines for preventing sexual harassment at workplaces and emphasized the role of the judiciary in ensuring gender justice under Article 21.
    • Though important for protecting fundamental rights, it does not address the Rule of Law or arbitrariness in the context mentioned in the question.
  • State of Rajasthan v. Vidyawati:
    • This case focused on the liability of the State for the negligence of its employees, specifically in a motor accident case. The court held the State accountable for torts committed by its employees during their official duties.
    • The principle of State liability is different from the concept of Rule of Law and arbitrariness addressed by Justice Khanna.
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