The golden triangle of the Constitution: Articles 14, 19 & 21

  1. Articles 14, 19 & 21
    1. Article 14
    2. Article 19
    3. Article 21
  2. What do these articles mean and why are they important?
  3. Landmark Judgements
  4. Conclusion

“The golden triangle of our Constitution is composed of Articles 14, 19 and 21. Incorporation of such a trinity in our paramount parchment is for the purpose of paving such a path for the people of India which may see them close to the trinity of liberty, equality, and fraternity.” This was precisely observed in the case of T.R. Kothandaraman v. T.N. Water Supply & Drainage Board, (1994) 6 SCC 282.

Articles 14, 19 & 21

Article 14

Equality before the law, the state shall not deny any person equality before the law or equal protection of law within the territorial limits of India or prohibition on the grounds of race, caste, religion, sex or place of birth.

Article 19

Protection of certain rights regarding freedom of speech and expression. All citizens shall have the right to:-

  1. To freedom of speech and expression,
  2. To assemble peacefully and without arms,
  3. To form associations or unions,
  4. To move freely throughout the territory of India,
  5. To reside and settle in any part of India, and
  6. To practice freely any profession or to carry on any occupation, trade or business.
The golden triangle of the Indian Constitution: Articles 14, 19 & 21

Article 21

Protection of life and personal liberty, no person shall be deprived of his personal liberty except according to the procedures established by law.

They’re a triangle because they need to be read together; the triangle is golden because they’re important to the protection of freedoms and prevention of government capriciousness and arbitrariness.

What do these articles mean and why are they necessary?

The article 14 of the constitution talks about equality before the law, it’s a negative concept which states that people in similar situations should be treated alike, in both privileges & liabilities imposed whereas, the concept of ‘equal protection of the laws’ requires the State to give special treatment to persons in different situations in order to establish equality among all. It is positive in character.

Therefore, the necessary corollary to this would be that equals would be treated equally, whilst unequal would have to be treated unequally.

Article 19 extends from freedom of peaceful association to freedom of speech and expression, then to practice of trade and profession to the residence, occupation, etc.

The article 21 talks about right to life and personal liberty, ‘Life’ in Article 21 does not connote mere animal existence, It has a much wider meaning which includes right to live with human dignity, right to livelihood, right to health, etc. it is only logical and fair for the state to impose certain rights and regulations when it comes to human life. This applies to everyone who challenges this article and it’s scope.

Landmark Judgements

One of the historic cases in India was the case of Maneka Gandhi v Union of India. It was observed by the supreme court of India that Article 21 is not to be read in isolation; all violations and procedural requirements under Article 21 are to be tested for Article 14 and Article 19 also. The Supreme Court in the above case had adopted the widest possible interpretation of the right to life and personal liberty, guaranteed under Article 21 of the Constitution.

“The expression ‘personal liberty’ in Article 21 is of the widest amplitude and it covers a variety of rights which go to constitute the personal liberty of man and some of them have raised to the status of distinct fundamental rights and given additional protection under Article 19.”

The golden triangle of the Indian Constitution: Articles 14, 19 & 21

Also, with respect to the relationship between Article 19 and Article 21, the Court held that Article 21 is controlled by Article 19, i.e. it must satisfy the requirement of Article 19. The Court observed: “The law must therefore now be settled that Article 21 does not exclude Article 19 and that even if there is a law prescribing a procedure for depriving a person of personal liberty, and there is consequently no infringement of the fundamental right conferred by Article 21 such a law in so far as it abridges or takes away any fundamental right under Article 19 would have to meet the challenges of that Article.”

Thus a law “depriving a person of ‘personal liberty’ has not only to stand the test” of Article 21, but it must stand the test of Article 19 and Article 14 of the Constitution as well.

The scope of articles 14, 19 and 21 were first challenged in cases such as Bacchan Singh V/s State of Punjab, Kanhaiyalal V/s UOI and in the recent major cases like the Sabarimala verdict, the Aruna Shanbaug case, the surrogacy bill, and such endless scenarios.

Article 21 of the Constitution has been in question quite a few times when deciding historic cases. For e.g., when the question of mercy killing or euthanasia arises, it’s hard to choose one’s right to live with dignity or one’s right to life. Then there’s the question relating to religious rights such as a woman’s right to enter places of prayer or issues such as triple talaq, etc.


In conclusion, it can be said from the observation that these three articles play a major role in the operation of our judicial system and affect our day to day lives, they also have an impact on our rights as citizens in this society

Taruni Lakkaraju

Just another one of those law aspirants who can't keep a pen away from the paper for too long, always hoping that their love for writing and their compassion for law will result in something beautiful. Currently pursuing second year of LLB from the prestigious Government Law College, Mumbai.
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