UPSC MainsLAW-PAPER-I201910 Marks150 Words
Q4.

“The issue of Parliamentary-privileges has been a bone of contention and conflict between the Parliament and the Judiciary.” Analyse this statement in the backdrop of decided cases.

How to Approach

This question requires a nuanced understanding of the interplay between parliamentary privilege and judicial review. The approach should begin by defining both terms and outlining the historical context of their relationship. The body should then analyze key cases like Kesavananda Bharati, Kihoto Hollohan, and In Re Special Reference, highlighting the evolving judicial stance. Finally, the answer must address the reasons for the ongoing tension and suggest possible avenues for reconciliation, demonstrating a balanced perspective. A table comparing the viewpoints would enhance clarity.

Model Answer

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Introduction

Parliamentary privileges, rooted in historical practices and enshrined in Article 105 of the Indian Constitution, are rights and immunities afforded to Members of Parliament (MPs) to enable them to discharge their duties effectively without fear of undue interference. These privileges, however, have frequently clashed with the judiciary's power of judicial review, leading to a persistent tension. The Kesavananda Bharati case (1973) marked a pivotal moment, initiating a debate on the limits of parliamentary power and judicial scrutiny. This statement's validity lies in the recurrent conflicts, exemplified by subsequent cases, showcasing the ongoing struggle to define the boundaries of these crucial constitutional principles.

Understanding Parliamentary Privileges and Judicial Review

Parliamentary privileges are not explicitly defined in the Constitution but are derived from constitutional provisions, conventions, and historical practices. They include freedom of speech in Parliament, protection from arrest during sessions, and the right to publish parliamentary proceedings. Judicial review, on the other hand, is the power of the judiciary to examine the constitutionality of laws and executive actions.

Historical Context: The Kesavananda Bharati Case (1973)

The Kesavananda Bharati case, while primarily concerned with the basic structure doctrine, indirectly touched upon parliamentary privileges. The Allahabad High Court’s decision restricting the power of the Parliament to amend the Constitution led to the 24th Amendment Act, which attempted to curtail judicial review. This demonstrated the initial reluctance of the judiciary to interfere with parliamentary power.

The Kihoto Hollohan Case (1992): A Defining Moment

The Kihoto Hollohan case proved to be a watershed moment. The Supreme Court, while acknowledging the importance of parliamentary privilege, held that it is not absolute and is subject to judicial review. The court struck down Section 53 of the Arunachal Pradesh Legislative Assembly Act, 1982, which conferred immunity from judicial scrutiny on decisions of the Speaker regarding disqualification of MLAs. This affirmed the judiciary's power to review actions taken under the guise of parliamentary privilege if they violate fundamental rights or constitutional principles.

In Re Special Reference (2014) and Subsequent Developments

In 2014, the Supreme Court, in a special reference, reiterated the principle that parliamentary privileges are not immune from judicial scrutiny, although the courts should be reluctant to interfere. The court emphasized the need for a delicate balance between the two branches of government. Recent instances, such as debates surrounding the privileges extended to parliamentary committees and their interactions with executive bodies, continue to highlight the ongoing tension.

Reasons for the Conflict

  • Differing Interpretations of Constitutional Provisions: Disagreement over the scope of Article 105 and the extent to which it protects parliamentary actions.
  • Protection of Fundamental Rights: Concerns that parliamentary privilege could be used to shield actions that violate fundamental rights guaranteed by the Constitution.
  • Separation of Powers: The inherent tension between the legislative and judicial branches, each safeguarding its domain.

Table: A Comparison of Perspectives

Perspective Argument
Parliament Privileges are essential for effective legislative functioning and should be broadly protected. Judicial intervention undermines parliamentary autonomy.
Judiciary While respecting parliamentary privilege, judicial review is necessary to uphold the Constitution and protect fundamental rights. Parliamentary actions are not beyond the reach of the law.

The Way Forward

Reconciling these conflicting interests requires a nuanced approach. Strengthening constitutional literacy among lawmakers and promoting greater dialogue between the branches are crucial. The judiciary should exercise restraint while safeguarding fundamental rights, and Parliament should respect the judiciary's role in upholding the Constitution.

Conclusion

The contention between parliamentary privilege and judicial review reflects the inherent tension within a democratic system governed by the principle of separation of powers. While the Kihoto Hollohan case solidified the judiciary’s power to review parliamentary actions, a delicate balance remains essential. Moving forward, fostering mutual respect, constitutional literacy, and open dialogue between Parliament and the judiciary will be vital to ensure the health and vitality of India’s democratic institutions.

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

Parliamentary Privilege
Rights and immunities enjoyed by Members of Parliament to enable them to discharge their duties effectively without fear of undue interference.
Judicial Review
The power of the judiciary to examine the constitutionality of laws and executive actions.

Key Statistics

According to the PRS Legislative Research, there has been a steady increase in the invocation of parliamentary privileges in recent years, indicating a continuing area of contention.

Source: PRS Legislative Research (knowledge cutoff)

The 24th Amendment Act, 1975, was passed in response to the Allahabad High Court's judgment in the Kesavananda Bharati case, demonstrating the extent of the conflict.

Source: Constitutional Law textbooks (knowledge cutoff)

Examples

Arunachal Pradesh Legislative Assembly Act, 1982

Section 53 of this Act, which granted immunity to the Speaker's decisions on MLA disqualification, was struck down by the Supreme Court in the Kihoto Hollohan case.

Recent Committee Privileges

Debates surrounding the powers of parliamentary committees to summon officials and the extent to which they can be compelled to appear, exemplify the ongoing tension between privilege and accountability.

Frequently Asked Questions

Can Parliament override a Supreme Court judgment?

While Parliament can legislate to amend the Constitution, it cannot directly override a Supreme Court judgment. However, it can enact laws that indirectly address the issues raised by the judgment, subject to the basic structure doctrine.

What is the 'basic structure' doctrine?

The ‘basic structure’ doctrine, established in the Kesavananda Bharati case, holds that the core principles of the Constitution are immutable and cannot be altered even by constitutional amendments.

Topics Covered

PolityConstitutional LawParliamentJudiciaryConstitutional Conflict