Citation: (1978) 1 SCC 248 · Supreme Court of India · 7-Judge Bench
The Court held that the "procedure established by law" under Article 21 must be fair, just and reasonable, and that Articles 14, 19 and 21 are interconnected (the "golden triangle"). Any law depriving life or liberty must satisfy all three.
Expanded Article 21 enormously — the State cannot take away liberty through an arbitrary or unfair procedure. It linked the rights to equality, freedom and life together.