CONSTITUTIONALITY OF DECLARATION OF EMERGENCY 1975

 On 25th June 1975 emergency was declared by Former PM Indira Gandhi u/d the Presidency of Fakhruddin Ali Ahmed, whereby the period of ‘black chapter’ of India’s history had begun. It was the second time when due to the governmental affair the people of India had lost their freedom/ independence (first when the British ruled). At the time when the  proclamation signed by the President of India, the goal of the 21-month long Emergency in the country to control the ‘internal disturbance’ whereby the constitutional rights including freedom of speech and expression were suspended and withdrawn.


1975 emergency


There were 3 main grounds as per Former PM Indira Gandhi on which the emergency was proclaimed are as follows:

1.  Security and democracy of India was in danger owing to the movement started by Jayaprakash Narayan.

2.    There was a need for rapid economic development and upliftment of the underprivileged.

3.    There was an intervention of foreign nations which could reasonably destabilize and weaken India.

But the main grounds which the Former PM Indira Gandhi could not handle were growing unemployment, rampant inflation, and scarcity of food. The unwanted condition of the Indian economy together with widespread riots and protest against Gandhi’s government (GG) and trouble started in Gujarat, spread to Bihar and other Northern states raging against GG. With all this, a petition against the Former PM Indira Gandhi in Allahabad High Court regarding election came to the doorstep of her.

The 4 main occurrence of the 1970s for which Indira Gandhi declared emergency:

1.      Navnirman Andolan

A protest started in Gujarat by the students of LD Engineering College, Ahmedabad who went on strike to protest against the hike in school fees. It after a month the student protest in Gujarat University got erupted as the protest was joined by factory workers, demanding the dismissal of the state govt. under the leadership of the notorious head, Chimanbhai Patel AKA chiman chor, resulting in the suspension of L. Assembly and the president rule was imposed.

“ The last act of Gujarat drama was played in March 1975 when faced with continuing agitation and fast unto death by Morarji Desai, Indira Gandhi dissolved the assembly and announced the fresh election to it in June”[i].

2.      The JP movement

Inspired by the success of Gujarat, in March 1974 a student protest erupted in Bihar to which opposition forces lent their strength. The movement was headed by 71-year-old freedom fighter Jayaprakash Narayan, popularly called JP. JP movement was noteworthy in determining Indira Gandhi to declare an emergency. The movement changed its name from the Bihar movement to JP movement. He was the one who motivated students to boycott the classes, it also leads to clashes with police, courts, schools, colleges, and offices which made them shut down. A ‘total revolution’ movement was called by him in 1974 adjoining by the students, traders, factory workers, etc., from Northern India and other opposition parties of the state were able to pull down the Congress govt.  JP movement was denounced by Indira Gandhi as extra-parliamentary movement and challenged him in 1976 election. JP formed National Coordination Committee and soon emergency was imposed.

3.      The railway's protest

The  country was paralyzed by the 3-week strike in May 1974 led by socialist George Fernandes, resulted in the halt of the movement of goods and people. In the strike as many as a million railwaymen participated in the movement. “There were militant demonstrations in many towns and cities- in numerous places, the army was called out to maintain the peace,”[ii]. Gandhi’s government came down heavily on the protesters. Thousands of employees were arrested and their families were thrown out of their quarters. The protest also resulted in the detention and looting of many business families by the government. The businesses were shut down, assets and valuables including immovable property were seized by the government inappropriately, with pressure hundreds of them died.

4.      The Raj Narain Verdict

A new threat emerged against Indira Gandhi, when a petition was filed against her by a social activist Raj Narain in Allahabad High Court who lost out to Indira Gandhi in Raebareli parliamentary election of 1971. The charges against were of corrupt practices in the election and using of pre-inked party named ballot (defiance). On 12 June 1975, Justice Sinha of Allahabad High Court held in the judgment in the declaring Indira Gandhi’s election to Parliament as null and void. After 3 days she became the first Indian PM to testify in court. The appeal filed in the Supreme Court, where a conditional stay was put whereby she can attend the parliament but can’t vote unless the court pronounced on her appeal. The judgment gave imputes to JP movement convincing them for resignation of PM Indira Gandhi. A day after the SC pronounced judgment against her, she proclaimed the ordinance of internal Emergency and the President signed immediately.

The reason given in an interview with journalist Jonathan Dimbleby in 1978[iii] for an emergency was the potential threat to security to India, but the real truth was the potential threat was to her security and her future career in politics. With all the tactics she can use, to save her position as PM.

What happened at the time of emergency, which is being challenged by a 94-year-old widowed in Supreme Court after 45 years to declare it unconstitutional?

As above stated the emergency was declared on the above 4 occurrences by PM Indira Gandhi to have control over the internal aggression generated by her own acts leading to the unwanted results, based on some of the major activity during an emergency. Under Art. 352 of COI the President of India proclaimed emergency on 25th June 1975 with an order promulgating the emergency was published in the Gazette of India- Extraordinary on 26th June 1975. The rights were suspended guaranteed u/d Part III of COI by virtue of Art. 358. Right to move to the SC u/d Art. 32 were also suspended. Whereby no person can move to the SC seeking direction for the inequality and difficulty faced. The Gandhi govt. inappropriately plundered and forcefully confiscated the immovable property of many families amounted crores of rupees, imprisoning the people for no substantial cause, also plundered movable property including jewelry, artifacts, figurines, painting, sculptures and other valuable. By the time the emergency was revoked many people had died due to the pressure of the GG or had to leave the country for the difficulty faced. The below case is filed by Veera Sarin the petitioner u/d Art. 32 of COI, one of the victims of the Emergency of 1975.

A petition filed by a 94-year-old widowed in Supreme Court seeking the declaration of Emergency 1975 to be declared unconstitutional and for the compensation of Rs. 25 crores referring to the judgment of 2017 of KS Puttaswamy (Ret) v. UOI[iv] which overruled the decision of 5 Judge bench in ADM Jabalpur v. Shiv Kant Shukla, where it was held that the end of the darkest chapter of Indian democracy is yet to bring closure to the petitioner who had faced difficulties at the hands of those in power during an Emergency.

The injustice is faced by the people of India is similar to that injury faced by the atom bomb victim of Hiroshima and Nagasaki in Japan. The situation deteriorated after her relatives and friends left them in a lurch. The act of emergencies resonates her mentally with psychological pain which can be put to peace by declaring the Proclamation of Emergency unconstitutional[v].

The case is filed seeking justice and compensation for lifetime misery and suffering spent due to atrocities faced by her. The plea is filed against the govt. who ruled at that point of time and not the current govt. on the grounds that her husband was detained on baseless orders whereby they had to escape the country due to the govt.’s organized looting and plundering of business and homes of the victims.

The case was filed for the recovery of the stolen valuables impounded from her husband worth crores of rupees in Delhi High Court in 2014; however which was dismissed by ending the proceeding. Her husband HK Sarin had flourishing business of art and gem in Karol Bagh and Connaught Place of jewellery, artefacts and valuables, which was closed because of the emergency imposed in 1975 and raids conducted and the items were seized during that time in the account of “suspected violation” of the Customs Act, which was not returned and the violation was not proved even after the emergency was revoked.

The plea is likely to be heard on 7th December 2020, before the bench headed by Justice SK Kaul. The question before the court is, Who is liable to repay for the restitution to put an end to the enduring trauma if the emergency is declared unconstitutional? 

 Written by 

Kaushal Modi (Intern at Advicebiz) 

(GLS Law College, Ahmedabad)


[i] Bipin Chandra, ‘India since Independence’

[ii] Ramchandra Guha, Gandhi: The Years That Changed the World

[iii] http://indianexpress.com/article/research/four-reasons-why-indira-gandhi-declared-the-emergency-5232397/

[iv] (2019) 1 SCC 1

[v] https://www.opindia.com/2020/12/94-years-old-widow-moves-sc-to-declare-emergency-as-unconstitutional/

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