UPSC MainsLAW-PAPER-I202215 Marks
हिंदी में पढ़ें
Q7.

Discuss the application of fundamental rights to parliamentary privilege cases.

How to Approach

This question requires a nuanced understanding of parliamentary privilege and fundamental rights. The approach should begin by defining both concepts and then systematically analyzing how different fundamental rights (freedom of speech, freedom of expression, right to equality, etc.) interact with the protections afforded by parliamentary privilege. A discussion of judicial interpretations and landmark cases is crucial. Finally, the answer should address the evolving nature of this relationship in a democratic context. A tabular comparison of rights vs. privilege would be beneficial.

Model Answer

0 min read

Introduction

Parliamentary privilege, a cornerstone of a functioning democracy, grants special rights and immunities to Members of Parliament (MPs) to enable them to perform their duties effectively without fear of external interference. This privilege, however, is not absolute and faces increasing scrutiny in the context of fundamental rights guaranteed by the Constitution of India. The interplay between these two principles has been a subject of evolving judicial interpretation, particularly concerning instances where parliamentary actions potentially infringe upon individual liberties. The question explores this complex relationship, examining the extent to which fundamental rights can be invoked against actions taken under the cloak of parliamentary privilege.

Understanding Parliamentary Privilege

Parliamentary privilege is not explicitly enshrined in the Constitution but is recognized as an incident of legislative bodies. It derives from common law and historical practices, essential for free and impartial deliberation. Key aspects include:

  • Freedom of Speech in Parliament: MPs have the right to speak freely without fear of legal repercussions outside the House.
  • Exclusion from Subjudication: Proceedings in Parliament are immune from judicial scrutiny.
  • Power to Summon Witnesses & Demand Evidence: Parliament can compel individuals to appear and provide information.

Article 105 of the Constitution reinforces the importance of freedom of speech in Parliament, protecting MPs from legal action for statements made during debates.

Fundamental Rights and Their Potential Conflict

While parliamentary privilege is vital, it cannot operate in a vacuum, especially when it clashes with fundamental rights. Here’s a breakdown of how several fundamental rights are impacted:

1. Freedom of Speech and Expression (Article 19(1)(a))

This is the most directly relevant right. While MPs enjoy freedom of speech in Parliament, this privilege isn’t absolute. The Supreme Court in Kesavananda Bharati v. State of Kerala (1973) established the “basic structure” doctrine, limiting the power of Parliament to amend the Constitution, including curtailing fundamental rights. Criticisms of parliamentary actions, even if harsh, are generally protected, but hate speech or defamation could be subject to legal scrutiny.

2. Right to Equality (Article 14)

If parliamentary privilege is used to unfairly target specific individuals or groups, it can potentially violate Article 14. For example, if a parliamentary committee selectively investigates individuals based on their caste or religion, it could be challenged as discriminatory.

3. Right to Life and Personal Liberty (Article 21)

Actions taken by Parliament under the guise of privilege that severely impact an individual’s life or liberty (e.g., arbitrary arrest or detention) are susceptible to challenge under Article 21. However, the exclusion from subjudication often makes it difficult to challenge such actions in court.

4. Right against Exploitation (Article 23 & 24)

If parliamentary privilege is used to coerce or exploit individuals for political gain, it could potentially violate these rights.

Judicial Interpretation and Landmark Cases

The courts have attempted to balance parliamentary privilege and fundamental rights, often adopting a restrictive interpretation of privilege.

  • ADM Jabalpur vs. Shivkant Shukla (1976): This case (though largely discredited post-emergency) initially suggested a limited role for judicial review of parliamentary actions.
  • Prakash Singh vs. Union of India (2000): While not directly about parliamentary privilege, it emphasized the importance of judicial review to safeguard fundamental rights.
  • Lily Thomas vs. Union of India (2013): This case, while primarily about disqualification of convicted legislators, highlighted the importance of accountability even for those enjoying parliamentary privilege.

The Evolving Landscape

The rise of digital media and increased public scrutiny has further complicated the relationship between parliamentary privilege and fundamental rights. Online criticisms of MPs, even if originating outside Parliament, can impact their reputation and potentially trigger actions under parliamentary privilege. The debate continues regarding the extent to which these criticisms should be protected under Article 19(1)(a).

Table: Comparison of Parliamentary Privilege and Fundamental Rights

Aspect Parliamentary Privilege Fundamental Rights
Nature Immunities and powers granted to Parliament Guaranteed rights of citizens
Source Common Law, Historical Practice, Article 105 Part III of the Constitution
Scope Primarily relates to parliamentary proceedings Applies to all citizens
Limitations Subject to constitutional limits and judicial review (limited) Subject to reasonable restrictions under Article 19(2) & 19(6)

Case Study: The 2G Spectrum Case

Title: The 2G Spectrum Case and Parliamentary Scrutiny

Description: The 2G spectrum allocation scam involved allegations of corruption and irregularities. A parliamentary committee investigated the matter, summoning officials and examining documents. While the committee's actions were generally protected under parliamentary privilege, the investigation itself and subsequent actions based on its findings faced scrutiny regarding potential violations of fundamental rights of those implicated, particularly regarding the right to a fair trial and freedom of expression.

Outcome: The case highlighted the delicate balance between parliamentary oversight and the protection of individual liberties. While the committee's actions were largely shielded, the legal proceedings stemming from the investigation were subject to judicial review.

Conclusion

In conclusion, the relationship between parliamentary privilege and fundamental rights is a dynamic and evolving one. While parliamentary privilege remains essential for the functioning of a democratic legislature, it is not immune from constitutional scrutiny. The courts have consistently emphasized that the exercise of parliamentary privilege must be reasonable and not violate the fundamental rights of citizens. A continued dialogue between the legislature, judiciary, and civil society is crucial to ensure that both principles are upheld, fostering a robust and accountable democracy.

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
Immunities and rights granted to legislators to enable them to perform their duties effectively without fear of interference from external bodies like the judiciary or the executive.
Exclusion from Subjudication
The principle that proceedings within Parliament are immune from judicial review, meaning courts cannot intervene in or question the actions taken during parliamentary debates or proceedings.

Key Statistics

According to a 2018 report by PRS Legislative Research, the number of parliamentary committees has increased significantly in recent years, highlighting the growing need for oversight and scrutiny.

Source: PRS Legislative Research, 2018

The 2G spectrum scam, estimated to have caused a loss of ₹1.76 lakh crore to the exchequer (CAG report, 2010), spurred extensive parliamentary scrutiny and legal challenges.

Source: CAG Report, 2010

Examples

Criticism of MPs on Social Media

Instances of individuals criticizing MPs on social media platforms raise questions about the extent to which such criticism is protected under Article 19(1)(a) and whether it can trigger actions under parliamentary privilege. The lines are increasingly blurred in the digital age.

Summoning of Bureaucrats by Parliamentary Committees

Parliamentary committees frequently summon government bureaucrats to answer questions and provide information. While essential for oversight, the process must respect the fundamental rights of those summoned, ensuring fair treatment and due process.

Frequently Asked Questions

Can Parliament amend the Constitution to remove fundamental rights?

No. The 'basic structure' doctrine established by the Supreme Court in Kesavananda Bharati prevents Parliament from amending the Constitution in a way that would fundamentally alter its core principles, including the protection of fundamental rights.

What are the reasonable restrictions on freedom of speech in Parliament?

Article 19(2) allows for reasonable restrictions on freedom of speech in Parliament, including considerations of defamation, breach of privilege, and incitement to violence.

Topics Covered

PolityConstitutional LawFundamental RightsParliamentPrivileges