UPSC MainsLAW-PAPER-I201715 Marks
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Q10.

Discuss the law relating to the powers of Parliament and State Legislatures to punish a person for breach of their privileges.

How to Approach

This question requires a detailed understanding of parliamentary privilege and legislative immunity. The approach should be to first define parliamentary privilege and its rationale. Then, discuss the powers of both Parliament and State Legislatures to punish breaches, including the constitutional limitations. Finally, analyze the judicial perspective and recent developments. A comparative table highlighting differences between Parliament and State Legislature powers will enhance the answer. Structure the answer into clear sections: definition, powers of Parliament, powers of State Legislatures, limitations, and judicial perspective.

Model Answer

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Introduction

Parliamentary privilege is a unique and essential aspect of the Indian democratic framework, rooted in the principle of free and unfettered debate within legislative bodies. It is not explicitly enshrined in the Constitution but is inferred from Articles 105 and 194 of Part V. The rationale behind this privilege is to ensure that legislators can perform their duties without fear of undue influence or reprisal. Recent debates surrounding the privilege of the Rajya Sabha Ethics Committee in the context of the Derek O’Brien case highlight the ongoing relevance and potential controversies surrounding this power. This answer will delve into the law relating to the powers of Parliament and State Legislatures to punish breaches of privilege, examining the scope, limitations, and judicial oversight.

Understanding Parliamentary Privilege

Parliamentary privilege is a set of immunities and rights granted to members of Parliament (Lok Sabha and Rajya Sabha) and State Legislatures, essential for the effective functioning of the legislature. It is inherent in the legislative process, not a statutory grant. It is analogous to the privileges historically enjoyed by the British Parliament.

Powers of Parliament to Punish Breach of Privilege

Article 105 of the Constitution provides the basis for Parliament’s power to punish breaches of privilege. The Speaker of the Lok Sabha and the Chairman of the Rajya Sabha are the final authorities on questions of privilege.

  • Investigation and Inquiry: Parliament can investigate and inquire into matters of privilege through a Privileges Committee.
  • Punishment: Punishments for breach of privilege can include:
    • Imprisonment: Members can be imprisoned for contempt of the House, though this is rare.
    • Suspension: Suspension from the service of the House.
    • Censure: Formal reprimand by the House.
    • Disqualification: Although not directly a punishment for breach of privilege, actions leading to a breach could potentially trigger disqualification under Article 104.
  • Example: The 2023 case involving Derek O'Brien of the TMC in the Rajya Sabha, where he was accused of tearing rule books during a debate, exemplifies the exercise of parliamentary privilege. While a committee was formed, the issue remains contentious, demonstrating the complexities of applying privilege.

Powers of State Legislatures

Article 194 grants similar powers to State Legislatures, mirroring the provisions for Parliament. The Speaker of the State Legislative Assembly and the Chairman of the State Legislative Council are the final authorities.

  • Investigation and Inquiry: Similar to Parliament, State Legislatures can investigate breaches of privilege.
  • Punishment: The range of punishments is similar to that available to Parliament - imprisonment, suspension, censure.
  • Differences from Parliament: State legislatures have less scope to punish offences. They are subject to greater judicial scrutiny.

Limitations on Powers

While significant, the power to punish for breach of privilege is not absolute and faces limitations:

  • Constitutional Rights: Any punishment must respect fundamental rights guaranteed under the Constitution, particularly freedom of speech and expression (Article 19).
  • Judicial Review: The power to punish for breach of privilege is subject to judicial review. Courts can intervene if the proceedings are found to be arbitrary, unfair, or violate constitutional principles.
  • Rule of Law: The principle of natural justice must be followed during proceedings.
  • Article 212: This article bars judicial review of proceedings in the Legislature, but this has been diluted by Supreme Court interpretations.

Judicial Perspective

The Supreme Court has taken a cautious view of the power to punish for breach of privilege, emphasizing the need for restraint and adherence to constitutional principles.

  • Kesavananda Bharati Case (1973): While upholding the power, the court stressed that it must be exercised reasonably and not arbitrarily.
  • Maneka Gandhi Case (1978): Expanded the scope of Article 21 (right to life and personal liberty) which has implications for procedural fairness in privilege proceedings.
  • Rajesh Rastogi vs. State of UP (2006): The Supreme Court held that the power to punish for breach of privilege cannot be used to stifle legitimate criticism.
Feature Parliament (Lok Sabha/Rajya Sabha) State Legislature (Assembly/Council)
Basis of Power Article 105 of the Constitution Article 194 of the Constitution
Final Authority Speaker (Lok Sabha), Chairman (Rajya Sabha) Speaker (Assembly), Chairman (Council)
Judicial Review Subject to judicial review, but with greater deference Subject to greater judicial scrutiny
Scope of Punishment Potentially wider range of punishments More restricted range of punishments

Recent Developments and Concerns

The increasing use of privilege proceedings, sometimes perceived as tools to stifle dissent or target political opponents, has raised concerns about the potential for abuse. The Derek O'Brien case serves as a stark reminder of these tensions.


Conclusion

In conclusion, the power of Parliament and State Legislatures to punish breaches of privilege is a vital mechanism for maintaining the dignity and effectiveness of legislative bodies. However, this power is not unfettered and is subject to constitutional limitations and judicial review. Balancing the need to protect legislative processes with the fundamental rights of individuals remains a crucial challenge, requiring careful consideration and restraint in the exercise of this privilege. Future legislative reforms and judicial interpretations will likely shape the contours of parliamentary privilege in the years to come.

Answer Length

This is a comprehensive model answer for learning purposes and may exceed the word limit. In the exam, always adhere to the prescribed word count.

Additional Resources

Key Definitions

Contempt of the House
Any act or speech that undermines the authority, dignity, or proceedings of the legislature is considered contempt of the House, and can be penalized.
Legislative Immunity
Legislative immunity is the immunity from arrest and prosecution enjoyed by legislators during their attendance in Parliament or State Legislatures, protecting them from legal action that could impede their ability to perform their duties.

Key Statistics

According to a PRS Legislative Research report (2021), there has been a significant increase in the invocation of privilege motions in both Parliament and State Legislatures in recent years, raising concerns about potential misuse.

Source: PRS Legislative Research

According to data from the Lok Sabha website (as of knowledge cutoff), approximately 20-30 privilege motions are moved in each session of Parliament.

Examples

The Indira Sawhney Case (1992)

While not directly about breach of privilege, this case highlighted the tension between parliamentary privilege and fundamental rights, reinforcing the importance of judicial oversight.

Frequently Asked Questions

Can a member of Parliament be arrested for a breach of privilege?

Yes, theoretically, a member can be imprisoned for contempt of the House, which can arise from a breach of privilege. However, this is extremely rare and subject to judicial review.

Topics Covered

PolityLawConstitutionLegislatureConstitutional LawPrivileges