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CHANAKYA NATIONAL LAW UNIVERSITY, PATNA

Submission of Final Draft

TOPIC: RIGHT TO PRIVACY AND ADHAR CARD

Submitted To: Dr..Manoranjan Kumar

Submitted By: Siddharth Raj

Roll No.:-1382
CONSTITIONAL LAW - I

ACKNOWLEDGEMENT

I would like to thank Dr. Manoranjan Kumar whose guidance helped me a lot with
structuring my project. I owe the present accomplishment of my project to my friends, who
helped me immensely with materials throughout the project and without whom I couldnt
have completed it in the present way.

I would also like to extend my gratitude to my parents and all those unseen hands who helped
me out at every stage of my project.

Thank you,

SIDDHARTH RAJ

Roll no-1382.

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CONSTITIONAL LAW - I

DECLARATION

I hereby declare that the work reported in the project entitled Right to Privacy and Adhar
Card submitted at CHANAKYA NATIONAL LAW UNIVERSITY is an authentic record
of my work carried out under the supervision of Dr. Manoranjan Kumar sir. I have not
submitted this work elsewhere for any other degree or diploma. I am fully responsible for the
contents of my Project Report.

Siddharth Raj

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TABLE OF CONTENTS:

1. ACKNOWLEDGEMENT 2
2. DECLRATION 3
3. OBJECTIVE OF STUDY 5
4. HYPOTHESIS 5
5. RESEARCH METHODOLOGY 5
6. SOURCES OF DATA 5
7. LIMITATION OF STUDY 5
8. SCOPE OF STUDY 5
9. INTRODUCTION 6
10. ADHAR ACT IS NOT VIOLATIVE OF ARTICLE 19 7
11. ADHAR ACT IS NOT VIOLATIVE OF ART 21 9
12. INTERNATIONAL REFRENCES 13
13. ADHAR ACT IS POSITIVE OBLIGATION OF STATE 15
14. CONCLUSION 17
15. BIBLIOGRAPHY 19

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OBJECTIVES OF THE STUDY

The objectives of the study to

(i) To study about Adhar Act.


(ii) To study about the consequence of Adhar Act on privacy of people.
(iii) To study the constitutionality of summary suits.

HYPOTHESIS

The researcher comes with the following hypothesis that the Adhar Act is infringing the
privacy of people but it does not infringe any fundamental right.

RESEARCH METHODOLOGY

The researcher depend upon the existing materials like books, case laws, thus the researcher
opted doctrinal method of research. The researcher visited library and refer the primary and
secondary sources available there.

SOURCES OF DATA

The researcher went for primary and secondary sources of data. Secondary sources are all
those work done on primary sources.

LIMITATIONS OF THE STUDY

The researcher had time limitation as he has to complete this project within one month.

SCOPE OF THE STUDY

This research will be a source for a further researcher. This research will give him/her the
basic ideas in a very simple manner.

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INTRODUCTION

The right to privacy is a fundamental right guaranteed under Art. 21 as a part of personal
liberty.1 Article 21 is not to read in isolation, all violations and procedural requirements under
Art. 21 are to be tested with Art. 14 and Art. 19 also.2

Privacy under personal liberty of the citizen of India has not been violated by the Adhar Act,
2014 as the act does not violate Art. 14 of the constitution Art. 19 of the constitution Art. 21
of the constitution.3 The articles of international convention4 also explains the privacy and
the reasonable restrictions imposed on it.

The State shall not deny to any person equality before law or the equal protection of the laws
within the territories of India.5 Equality before law is a concept implying absence of any
special privilege by reason of birth, creed or like in favor of any individual, and also the equal
subject of all individuals and classes to the ordinary law of the land.6

The Adhar card was provided free of cost to every citizen of India. The Govt. of India also
notifies that every citizen should comply with order issued in the notification of 13 th Jan.
2015 and penal actions will be initiated in case of non-compliance. The counsel contends that
providing Adhar card free of cost to every citizen of India without any discrimination on the
basis of birth, cast, creed and likes shows no discriminatory action of the State and so there is
no arbitrary action of the State to be challenged which is in contravention Right to Equality
guaranteed under Art. 14 of the Constitution. Again, it was notified by the Govt. that every
citizen who do not comply with order issued in notification of 13th Jan. 2015 will be liable for
penal actions. This shows that the Govt. does not discriminate on the above given basis.
Therefore question of violation of Art. 14 do not arise.

1
Supra Note 7.
2
Maneka Gandhi Vs. Union of India, (1978) 2 SRC 621.
3
Constitution of Mandia is pari materia to Constitution of India [hereinafter referred as Constitution .
4
Universal Declaration of Human Rights, 1948 & International convenant of civil and political rights.
5
The Constitution of India,1950 Art.14.
6
M.P. Jain Indian Constitutional Law Page 877 (7 th Edition, 2016)

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ADHAR ACT IS NOT VIOLATIVE OF ART. 19

Every person has the right to freedom of speech and expression7 which includes right to
remain silent.8 But such act of speech and expression or of remaining silent shall not affect
the operation of any existing law, or to prevent the state from making any law in so far as law
imposes reasonable restrictions on the exercise of the rights conferred in interest of
sovereignty and integrity of India, the security of the state friendly relation with foreign state,
public order, decency or morality or in relation to contempt of court, defamation or
incitement of an offence.9

In the given circumstances the actions Govt. of India seeking the data in Adhar card may
seem to be violative of freedom of speech and expression10 as such right also grants the right
to remain silent but it is to be considered that reasonable restrictions can also be imposed11 on
that right guaranteed under Art. 19(1)(a) of the Constitution.

A no. of cases came before the Supreme Court of India in which the reasonable restrictions
were challenged. In Babulal Parate Vs. State of Madras12 court held that anticipatory action to
prevent disorder is within the ambit of Sec.19(2) of Constitution of India and hence
considered imposing reasonable restriction. In another case State of U.P. Vs. Kaushaliya13
court held that the reasonable restriction could be imposed on the grounds of decency. There
are many provisions in the legislations14 which enables the state to infringe the fundamental
rights of citizen mentioned in 19(1)(a) in case of threat to national security and public peace
and tranquility.

Social interest in individual liberty may well be subordinated to other greater interests.15 The
counsel contends that the security of the state and social order are major objectives of Adhar
project and the act does not violates the right to freedom of speech and expression
guaranteed under Art. 19(1)(a) as Art. 19(2) gives the power to the state make laws in

7
Art. 19(1)(a) Constitution of India,1950.
8
Nandani Saptpadi Vs. P.L. Dani (1978) AIR 1025.
9
Art. 19(2) Constitution of Inda, 1950.
10
Supra Note 18.
11
Supra Note 20.
12
(1961) AIR SC 884.
13
(1964) AIR SC 416.
14
Post Office Act, 1898 Sec. 26 & Information Technology Act,2008 Sec. 69.
15
A. K. Gopalan Vs. State of Madras (1950) AIR SC 27.

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interest of security of state, maintenance of social order and many more and nothing
mentioned in 19(1)(a) shall affect the operation of such law. A restriction should strike a
proper balance between the freedom guaranteed by any clause and the social control, so that
the freedom is limited only to the extent necessary to protect the society of which citizen is
only a part.16 This introduces the principle of proportionality which means that the restriction
should not be arbitrary or of excessive nature, beyond what is required for achieving the
objects of legislation. A restriction cannot be called as reasonable unless it strikes a proper
balance between the fundamental right guaranteed and the restrictions imposed thereon.17
Further, a restriction to be valid must have a direct and proximate nexus or a rational relation
with the object which the legislature seeks to achieve and must not be in excess of the
object.18 The Adhar Act does not impose unreasonable restriction as stated above and the
methods applied to achieve the objective of the act is in nexus with the object and is not
excessive. As the state aims to eradicate corruption by providing unique identification to
every citizen so that the govt. could directly reach to the citizen and provide benefit cutting
out all middle men. De-duplication of voter cards will also result in restriction of mala-fied
practices in election, de-duplication of PAN card would result in restriction on black money
and due to single database and de-duplicated identities PDS schemes would function properly
and the citizen will enjoy govt. aid without any barriers and corruption of middle men.

16
M.R.F. Ltd Vs. Inspector Kerla Govt. (1999) 8 SCC 227.
17
Chintaman Rao Vs. State of Madhya Pradesh (1950) SRC 188.
18
Arunachala Nadar Vs. State of Madras (1959) AIR SC 300.

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ADHAR ACT IS VIOLATIVE OF ART. 21

No person shall be deprived of his life or personal liberty except according to procedure
established by law.19 Procedure in Article 21 means fair, not formal procedure. Law is
reasonable law, not any enacted piece.20 It was established that the law should be just, fair,
and reasonable.21 The right to privacy is guaranteed under Art. 21 of the Constitution22 and its
evolution took place in 1604 where it was stated that the house of everyone is to him as his
castle and fortress.23 The question here arises is whether any legislation can violate this right
guaranteed under Art.21. In Maneka Gandhi Vs. Union of India24 it was held that any law
interfering with personal liberty of a person must satisfy a triple test: (i) it must prescribe a
procedure; (ii) the procedure must withstand the test of one or more of the fundamental rights
conferred under Article 19 which may be applicable in a given situation; and (iii) it must also
be liable to be tested with reference to Article 14. So according to the rule derived in Maneka
Gandhi case that there is a scope of interference with public liberty when the interference is
the procedure established by law and not any law but the law which is just fair and
reasonable. Interference with personal liberty must follow a procedure of triple test rule.25

The right to privacy is held to be fundamental right26 and in the judgment making right to
privacy a fundamental right27 it was said that, in case it is found that the privacy has been
breached then following test must apply The infringement should be by legislation. The
legislation should have definite sate aim, The aim of state should be in nexus with public
interest.

We are following the doctrine that every legislation passed by parliament is presumed to be
constitutional unless proven otherwise.28 The Adhar project is supported by the legislation
passed on 11th Aug. 2014.29 The legislation was held to constitutional in Honble High Court

19
Art. 21, Constitution of India,1950.
20
Madhav Hayawadanrao Hoskot vs State Of Maharashtra (1979) 1 SRC 192.
21
Supra Note 11.
22
Supra Note 7.
23
Saymans Case 1604.
24
Supra Note 11.
25
Naz Foundation Vs. Govt. of Nct of Delhi WP (civil) 7455/2001.
26
Supra Note 7.
27
Ibid.
28
Ashok Kumar Thakur Vs. Union of India (2008) 6 SCC 1.
29
Moot Proposittion Pg. 3 Para.. 12.

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of Delhi and according to the doctrine stated above the Adhar Act is a constitutionally valid
legislation and the steps taken to implement the project are in accordance with the
legislation.30

The Supreme Court of India defined what should be the legitimate aims of govt. for a
legislation which infringe right to privacy: The legitimate aims of the state would include for
instance protecting national security, preventing and investigating crime, encouraging
innovation and preventing the dissipation of social welfare benefits.31

In the given case Govt. of India issued a notification on 12th Oct. 2009, declaring the definite
aims of the state which the state wants to achieve through Adhar project. The definite aims of
the state as notified in Govt. notification of 12th Oct. 2009 are as follows:

To identify citizens for various benefits given by the government.

Save duplicity of identities.

Identify illegal immigrants in the country and to deport them to their respective
countries.

Check the leakage in government schemes and to prevent corruption happening in


PDS and other subsidy providing schemes of the government.

That the duplicity of election cards will also be checked through Adhar Cards.

Eliminating all forms of terrorism by finishing off sleeping modules and local support
base of terrorists in the country.

Hawala transactions and foreign contributions to suspect NGOs can be checked by


making payments, salaries and other financial transactions online and linking them
with Adhar system.

Data mining with the object of ensuring that the resources are properly deployed to legitimate
beneficiaries is a valid ground for the state to insist on collection of valid data. The Adhar Act
proposes definite aim of the govt. which are legitimate and justified aim of the govt. It is also

30
Adhar Act,2014, 2014.
31
Supra Note 7.

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to be considered that the aims proposed by the govt. in Adhar Act is in accordance with the
aims suggested by J. Chandrachud in the judgment of K.S. Puttaswami Vs. Union of India32.
So the Adhar Act is directed with definite state aim which is in public interest.

The aim of the state mentioned above is in public interest and is made for peace and safety of
public. Similar cases have come to Supreme Court of India, in the case of Kartar Singh Vs.
State of Punjab33 the court upheld the constitutional validity as it is of public interest. In
another case34 the court said that the parliament possesses power under Art. 248 and entry 97
of list I of the seventh schedule of the constitution of India to legislate the act. Need for the
act is a matter of policy and the court cannot go into the same. Mere possibility of abuse
cannot be a ground for denying the vesting of powers or for declaring a statue
unconstitutional.35

The acts such as TADA was legislated for protection of public interest and was challenged on
the ground of being violative of fundamental right guaranteed under Art.21 but the court
upheld the constitutionality of the act as it was in nexus with public interest. This shows that
the State action against terrorism is held to be in nexus with public interest.36 The Adhar Act
also aims to counter terrorism37 which shows that the act of the state is in nexus with public
interest.

Where there is a clash of two Fundamental Rights, the right which would advance the public
morality or public interest, would alone be enforced through the process of Court, for the
reason that moral considerations cannot be kept at bay and the Judges are not expected to sit
as mute structures of clay, in the Hail, known as Court Room, but have to be sensitive, in the
sense that they must keep their fingers firmly upon the pulse of the accepted morality of the
day.38

Social interest in individual liberty may well be subordinated to other greater interests.39 The
counsel contends that state govt. aims to achieve various goals through Adhar project such as
the aim for anti-corruption in public distribution and anti-terrorism to protect the life of the

32
Supra Note 7.
33
(1994) 3 SCC 569.
34
Peoples Union for Civil Liberties Vs. Union of India (2004)9 SCC 580.
35
Peoples Union for Civil Liberties Vs. Union of India (2004)9 SCC 580.
36
Supra Note 45.
37
Moot Proposition Pg. 1 Para.. 3.
38
Mr. 'X' vs. Hospital 'Z' (1998) 8 SCC 296.
39
Supra Note 26.

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citizens. The right to privacy is being infringed by the Adhar Act under reasonable
restrictions. But the breach of right to privacy of individuals can be subordinated by the right
to life and personal liberty and many more fundamental rights which will be breached if these
preventive actions are not taken.

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INTERNATIONAL REFERENCES

No one shall be subjected to arbitrary interference with his privacy, family, home or
correspondence nor to attacks upon his honor and reputation. Everyone has the right to the
protection of the law against such interference or attacks.40

No one shall be subjected to arbitrary or unlawful interference with his privacy, family, home
and correspondence, nor to unlawful attacks on his honor and reputation.41

A right to respect for ones private family and life, his home and his correspondence subject
to certain restrictions that are in accordance with law and necessary in democratic society. 42

In a case43 data was obtained via the Global Positioning System (GPS) by the investigation
agencies and was used against him in a criminal proceeding. In this case, the applicant was
suspected of involvement in bomb attacks by the left-wing extremist movement. The Court
unanimously concluded that there had been no violation of Article 8 and held as follows:
GPS surveillance of Mr. Uzun had been ordered to investigate several counts of attempted
murder for which a terrorist movement had claimed responsibility and to prevent further
bomb attacks. It therefore served the interests of national security and public safety, the
prevention of crime and the protection of the rights of the victims.

The international conventions also recognize the importance of right to privacy but it did not
consider it as an absolute right as there are provisions for breach of the right to privacy. The
given case44 shows us that if the breach of privacy is for the purpose of national security then
it is not violative of Art. 8 of European Convention of Human Rights, which guarantees the
right to privacy. Honble court should consider the rationale of the judgment given in Uzun
Vs. Germany and should recognize the importance of national security. Adhar Act aims to
bring peace in society by eliminating all forms of terrorism by finishing off sleeping modules
and local support base of terrorists in the country.45 It also aims to curb the terror finance

40
Art. 12 Universal Declaration of Human Rights (1948).
41
Article 17 International Covenant of Civil and Political Rights.
42
Art. 8 European Convention on Human right.
43
Uzun Vs. Germany.
44
Supra Note 54.
45
Moot Proposition Pg. 1 para.. 3.

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coming from hawala transaction.46 Keeping this in regard that the Adhar Act aims to finish
terrorism and enforce national security, so it should not be made unconstitutional.

46
Supra Note 56.

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ADHAR CARD IS POSITIVE OBLIGATION OF STATE

The state shall strive to promote the welfare of the people by securing and protecting as
effectively as it may a social order in which justice, social, economic and political, shall
inform all the institutions of national life.47 The state shall direct its policy towards the
ownership and control of material resources of the community are so distributed as best to
sub serve the common good.48 The Directive Principle of State Policy is also relevant in
considering whether a restriction on fundamental right is reasonable or not. A restriction
which promotes Directive Principle is generally regarded as reasonable.49

The constitution embodies the jurisprudential doctrine of distributive justice. The concept of
distributive justice is removal of economic inequalities rectifying the injustice resulting from
dealing and transactions between unequals in society.50 It is direction from the constitution to
the state that state shall direct its policy towards the removal of economic inequalities. The
Adhar project aimed and removal of corruption for better functioning of PDS schemes and
for the recovery of the black money which could be further used for other social schemes.
The aims of the Adhar project were not in contravention with fundamental right of the citizen
as shown above but were in accordance with the directive principles of state policy. The
Adhar Act should be validated as it aims to achieve the social welfare through de-duplication
of identities and removing corruption. Due to a large numbers of identities only containing
demographic data, duplicity is very easy and cannot be checked. With the implementation of
Adhar project every identity of the citizens will be linked to a single unique number,
duplication of which is not possible as it contains the biometric identity of every citizen. This
will help in de-duplication of PAN cards and other identities such as ration cards and LPG
gas cards. This will further help in canceling false registrations in PDS and the Govt. aid will
be provided to the needed persons.

The state shall within the limits of its economic capacity and development, make effective
provision for securing the right to work, to education and public assistance in case of
unemployment, old age, sickness and disablement, and in other cases of undeserved wants.

47
Constitution of India,1950 Art. 38(1).
48
Constitution of India, 1950 Art. 39(2).
49
State of Bombay Vs. Balsara 1951) AIR SC 318.
50
Central Inland Water Transport Corporation Vs. Brojo Nath Ganguly (1986) 3 SCC 156.

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It is directive to the state that within its economic capacity the state shall provide
employment, education and public assistance for the person who are unemployed, old and
those who are suffering from any disease. The Adhar project along with collecting
demographic and biometric identities collects the information about any disease or life
threating disease which they are suffering from. The project aims to identify the citizens of
India who are suffering from any disease or who are disabled or who are unemployed or their
age, so that the govt. can implement any measures or aid which could be made available to be
in compliance with the directive principles. So the Adhar Act should not invalidated on the
ground that information sought under Adhar scheme is very intimate and integral to ones
personality. As the information sought under the scheme is not violative of fundamental right
and is collected for social welfare of the state.

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CONCLUSION

The Supreme Court has cut straight to the heart of the issue in the Aadhaar petitions. On
behalf of all Indian citizens, it asks the current government to address the most basic
questions in a democracy governed by the law: what are the privacy rights of its citizens; and
are they protected equally, with the same justice for the rich and the poor alike?
In the 20th century, governments that recognised no private sphere of thought, expression,
and action outside their reach and the ruling partys reach were called totalitarian. Aware
that such governments are antithetical to freedom, the worlds democracies were willing to
sacrifice tens of millions of their citizens lives in the Second World War to defeat them
militarily. The democratic constitutions that rose on the ashes of European totalitarianism
explicitly recognised the integrity of a private sphere that governments may not invade, as the
U.S. Constitutions Bill of Rights, as interpreted by its Supreme Court, has also done. The
post-Independence Indian Constitution does this as well.
In the 21st century, a government that cannot or will not protect its citizens privacy rights
cannot credibly maintain a democratic regime of equal treatment under the rule of law.
Freedom of opinion and association; freedom of religion (or irreligion); the ability to make
choices and decisions autonomously in society free of surrounding social pressure, including
the right to vote all of these depend on the preservation of the private sphere.

Yet, the Government of India (GoI), speaking through its Attorney-General, has repeatedly
declared that it is the governments position that Indian citizens have no constitutional right
of privacy. Whether GoI is ultimately prepared to restate that position and risk a political loss
before the Supreme Court remains to be seen.
The pressure on the government very much increased last week, when the Supreme Court
refused simultaneous applications by multiple agencies demanding relief from the Supreme
Courts interim order limiting the use of Aadhaar pending the Courts final decision. By
referring these government applications to a constitutional bench whose composition has
been announced last week, the court has assured Indians that a decision on their fundamental
rights will not be long delayed.
The Attorney-General argued that the poor, whose welfare is at stake in the continuance of
subsidy payments and other benefits, must be prepared to surrender their right of privacy, if

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any, in order to continue receiving benefits. This argument was sharply rejected by the bench,
which recognises that the poor have the same rights as the rich, ad interim as well as
permanently, in any democratic society.
This is not, as GoI has been claiming, a conflict between the needs of the poor and 1 or 2 or
10 persons who care about everyones fundamental right to privacy. The governments most
basic obligation is to protect its citizens rights both their right to sustenance and their
right to the privacy that enables freedom equally. The ultimate resolution of this present
controversy must recognise both the need for Aadhaar in order to provide efficient and
honest government services to citizens and the need for stringent rules concerning access
to and security of citizens biometric data, in order to preserve their privacy.
GoI cannot adopt the posture that only one aspect of governments protective responsibility
matters that the costs of privacy destruction can be imposed upon the poor in return for
LPG subsidies, or any other social benefit on which they absolutely depend. The Supreme
Courts action this week ensures that GoI must respond to both halves of the problem.
In particular, the Indian Supreme Court is likely to find itself asking GoI about what in Indian
and U.S. law is called the doctrine of unconstitutional conditions. Both Supreme Courts
have held that the government cannot condition receipt of public benefits on waiver of
fundamental rights. This is in sharp contradiction to the argument offered in the Supreme
Court this week by the counsel for Center for Civil Society, when he told the bench that a
person who has a right to privacy should be allowed to waive it for greater benefit.
We are about to begin one of the most important constitutional cases of Indias post-
Independence legal history. The good news is that the Supreme Court has shown it knows
exactly whats at stake. In any democracy, thats a necessary place to start.

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BIBLIOGRAPHY

CONSTITUTION:

1. The Constitution of India.

CASES:

1. NIRMA LTD. VS. LURGI LENTJES ENERGIETECHNIK GMBH AND ANR. (2002 ) 5 SCC
520.
2. PRITAM SINGH VS. THE STATE (1950) AIR 169
3. DALBIR KAUR VS. STATE OF PUNJAB (1997) 1 SRC 280
4. M.P. SINGH & OTHERS V. SATISH CHANDRA & OTHERS (1954) AIR SC 300 :
5. KHARAK SINGH V. STATE OF U.P. & OTHERS (1963) AIR SC 1295
6. JUSTICE K S PUTTASWAMY (RETD.), AND ANR. VS. UNION OF INDIA
AND ORS (SC), W.P. (CIVIL) 494, 2012
7. TIRUPATI BALAJI DEVELOPERS PVT. LTD. VS. STATE OF BIHAR (2004) AIR SC
2351
8. MANEKA GANDHI VS. UNION OF INDIA, (1978) 2 SRC 621
9. BABULAL PARATE VS. STATE OF MADRAS (1961) AIR SC 884
10. STATE OF U.P. VS. KAUSHALIYA (1964) AIR SC 416
11. A. K. GOPALAN VS. STATE OF MADRAS (1950) AIR SC 27
12. M.R.F. LTD VS. INSPECTOR KERLA GOVT. (1999) 8 SCC 227
13. CHINTAMAN RAO VS. STATE OF MADHYA PRADESH (1950) SRC 188
14. ARUNACHALA NADAR VS. STATE OF MADRAS (1959) AIR SC 300
15. MADHAV HAYAWADANRAO HOSKOT VS STATE OF MAHARASHTRA (1979) 1 SRC
192
16. SAYMANS CASE 1604
17. NAZ FOUNDATION VS. GOVT. OF NCT OF DELHI WP (CIVIL) 7455/2001

18. ASHOK KUMAR THAKUR VS. UNION OF INDIA (2008) 6 SCC 1


19. KARTAR SINGH VS. STATE OF PUNJAB
20. PEOPLES UNION FOR CIVIL LIBERTIES VS. UNION OF INDIA (2004)9 SCC 580
21. PEOPLES UNION FOR CIVIL LIBERTIES VS. UNION OF INDIA (2004)9 SCC 580
22. MR 'X' VS. HOSPITAL 'Z' (1998) 8 SCC 296

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23. UZUN VS. GERMANY


24. STATE OF BOMBAY VS. BALSARA 1951) AIR SC 318
25. CENTRAL INLAND WATER TRANSPORT CORPORATION VS. BROJO NATH GANGULY
(1986) 3 SCC 156

BOOKS REFFERED:

1. Jain M.P, Indian Constitutional Law, 6th Edition 2011, LexisNexis Butterworth
Wadhwa
Nagpur.
2. Basu D.D., Constitution of India, 14th Edition 2009, LexisNexis Butterworths
Wadhwa Nagpur
3. Seervai H.M., Constitutional law of India, 4th Edition 2002, Volume 2,
Universal Book Traders.
4. Shukla V.N., Constitution of India, 11th Edition 2008, Eastern Book Company.

LEGAL DATABASES
1. Manupatra
2. SCC Online
3. Westlaw
4. Hein Online
LEGISLATIONS

1. Adhar Card Act, 2016

2. Post Office Act, 1898

3. Information Technology Act,2008

CONVENTIONS

1. Universal Declaration of Human Rights (1948)

2. International Covenant of Civil and Political Rights

3. European Convention on Human right.

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