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Q9.

"Article 194, which is an exact reproduction of Article 105, deals with the State Legislatures and their members and committees.” On this background, comment that both the Articles are complementary to each other and should be read together.

How to Approach

This question requires a comparative analysis of Article 194 and Article 105 of the Constitution. The approach should begin by defining both articles and highlighting their similarities – being exact reproductions of each other. Then, elaborate on the distinct provisions of each article concerning legislative privileges and immunities for state legislatures and their members. Finally, emphasize how reading them together ensures a comprehensive understanding of parliamentary privilege within the Indian federal structure. A table comparing key aspects will enhance clarity.

Model Answer

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Introduction

The Indian Constitution guarantees certain rights and privileges to its legislators to ensure freedom of speech and expression within the legislative chambers without fear of undue interference. Article 105 deals with Parliament and its members, while Article 194 mirrors it for State Legislatures. The question highlights a crucial aspect: both are “exact reproductions” of each other, implying a shared underlying rationale. This signifies that principles governing parliamentary privilege at the Union level apply analogously to state legislatures. Understanding their complementary nature is vital for comprehending the framework of legislative immunity within India’s federal structure.

Understanding Article 105 and Article 194

Article 105 of the Constitution deals with privileges of Parliament and its members, while Article 194 addresses similar privileges for State Legislatures. The core similarity lies in their verbatim repetition – a deliberate choice by the framers to ensure uniformity in legislative immunity across both levels of government.

Key Provisions of Article 105

  • Freedom of Speech: Members of Parliament have freedom of speech in Parliament and its committees, not subject to any undue restrictions.
  • Publication of Proceedings: The publication of reports, papers, votes, and proceedings of Parliament is deemed as privileged. This protects the process of legislative deliberation from external interference.
  • Contempt of Houses: Any act that obstructs or interferes with the functioning of Parliament can be considered contempt.

Key Provisions of Article 194

  • Freedom of Speech (State Legislature): Similar to Article 105, members of State Legislatures enjoy freedom of speech within the state legislature and its committees.
  • Publication of Proceedings (State Legislature): Publication of reports, papers, votes, and proceedings of the State Legislature are also considered privileged.
  • Contempt of Houses (State Legislature): Any action that obstructs or interferes with the functioning of a State Legislature is subject to contempt proceedings.

Why Read Articles 105 & 194 Together?

While seemingly identical, reading both articles together provides a broader perspective on legislative privilege in India.

Ensuring Consistency and Federal Balance

  • Uniformity of Principle: The repetition highlights the constitutional intent to treat both Union and State legislatures with equal respect regarding their internal workings.
  • Federal Structure: It underscores the principle of federalism, where legislative autonomy is essential for effective governance at both levels.

Illustrative Examples & Case Studies

Consider instances where debates in state assemblies have been challenged on grounds of defamation or breach of privilege. Reading Article 194 alongside Article 105 strengthens the argument for legislative immunity, drawing parallels from established precedents concerning Parliament.

The Role of Committees

Both articles explicitly extend privileges to committees formed by the respective legislatures. This is crucial as much legislative work happens within these committees. The privilege extends to reporting and deliberation processes.

Potential Challenges & Interpretations

Despite their similarity, interpretations can differ based on specific contexts. Courts often consider the spirit of the Constitution while adjudicating matters related to parliamentary/legislative privilege.

Feature Article 105 (Parliament) Article 194 (State Legislature)
Subject Matter Privileges of Parliament and its members Privileges of State Legislatures and their members
Freedom of Speech Guaranteed for Members in Parliament & Committees Guaranteed for Members in State Legislature & Committees
Publication of Proceedings Considered Privileged Considered Privileged
Contempt Acts obstructing Parliamentary functioning are contempt Acts obstructing State Legislative functioning are contempt

Limitations and Judicial Scrutiny

While legislative privileges are significant, they aren’t absolute. The Supreme Court has repeatedly emphasized that these privileges must be exercised reasonably and not violate fundamental rights guaranteed by the Constitution (Article 19, Article 21).

Conclusion

In conclusion, Articles 105 and 194 are intrinsically linked; their identical language underscores the constitutional commitment to safeguarding legislative independence at both Union and State levels. Reading them together offers a holistic understanding of parliamentary privilege in India's federal framework. While these privileges are vital for robust debate and scrutiny, they must be exercised responsibly, respecting fundamental rights and adhering to judicial interpretations that prevent abuse and maintain a balance between legislative autonomy and constitutional values.

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 enjoyed by members of Parliament or State Legislatures to enable them to discharge their duties effectively without fear of interference from outside agencies.

Key Statistics

In 2019, the Lok Sabha saw 36 notices for breach of privilege, highlighting the frequent invocation and potential for misuse of these powers. (Source: PRS Legislative Research)

Source: PRS Legislative Research

According to data from 2021, over 50 notices for breach of privilege were issued by various State Legislative Assemblies. (Source: The Hindu)

Source: The Hindu

Examples

Shehla Rashid Case

In 2018, the J&K Assembly issued a privilege notice to Shehla Rashid for allegedly posting objectionable comments on social media regarding a parliamentary delegation. This case illustrates the ongoing tension between legislative privilege and freedom of expression.

Frequently Asked Questions

Can legislative privileges be challenged in court?

While Article 105 & 194 provide immunity, judicial review exists. The Supreme Court can examine whether the exercise of these privileges is constitutional and doesn't violate fundamental rights.

Topics Covered

PolityConstitutional LawParliamentary PrivilegesConstitutional Law