LIVE Online Course on NDPS by Riva Pocha and Adv. Taraq Sayed. Starting from 24th May. Register Now!!
LAW Courses

Share on Facebook

Share on Twitter

Share on LinkedIn

Share on Email

Share More


  • The Golden Triangle of the Indian Constitution is made up of Articles 14, 19, and 21.
  • Democracy cannot exist in India without the aforementioned Golden Triangle.
  • In the case of Maneka Gandhi v. Union of India, Justice Bhagwati had ruled that Articles 14, 19, and 21 are not mutually exclusive and that the three are interrelated to create a Golden Triangle.


Our Constitution's golden triangle is comprised of Articles 14, 19, and 21. The incorporation of such a trinity is intended to provide a road for the people of India to lead them to the trinity of “liberty, equality, and brotherhood.” Democracy is impossible without the Golden Triangle. The Constitution of India states India to be a sovereign, socialistic, secular, democratic republic that guarantees its inhabitants justice, equality, and liberty while also attempting to encourage brotherhood among them.Fundamental Rights are vital because they provide a framework for democracy to operate in our country according to the preferences of its citizens. They also enable the people to maintain a check on the government's behavior so that it would not become exceedingly dominating. It has been discovered that Articles 14, 19, and 21 of the Indian Constitution are linked and that collectively they safeguard the people against the government's arbitrariness. These Articles are dubbed the 'Golden Triangle of the Indian Constitution,' with Golden representing the importance of Indian people’s freedom and the Triangle representing that these laws should be construed jointly and collectively.


ARTICLE 14 of the Constitution of India provides that the State must not deny to any person equality before the law or the equal protection of the laws within the territory of India.

ARTICLE 19 provides the right to freedom of speech and expression; the right to assemble peaceably and without arms; the right to form associations or unions or cooperative societies; the right to move freely through the territory of India; right to reside and settle in any part of the territory of India; and right to practice a profession, occupation, trade or business.

ARTICLE 21 provides the Right to Life and Personal Liberty. Within the meaning of the Article, Life does not imply simple animal existence, but rather the right to live with human dignity, the right to health, the right to a livelihood, the right to get an education, the right to a clean environment, and so on.


The three elements of the Golden Triangle, Article 14 (Right to Equality), Article 19 (Right to Freedom), and Article 21 (Right to Life and Personal Liberty), are critical to the concept of rule of law because they together provide full protection to citizens' rights by ensuring that the government does not encroach on these rights arbitrarily.

Article 14 is considered principally as a basic right against arbitrariness. Furthermore, it checks the laws by codifying the principle of 'Equality before the Law'. The rule of law is a legal idea that states that the nation should be ruled by the law, not by the chosen representatives of the people who form the government. It considers the Law to be superior to all State acts and decisions. The Constitution of India is the ultimate power in the nation, from which the legislative and the executive gain their authority.

These rights are recognized as fundamental principles for the proper operation of our country's people’s lives. Individuals are fully protected by the golden triangle from any infringement on their rights by society and others. The clause is especially significant since its adoption results in the abolition of some inhumane traditional practices in our nation.


1. A.K Gopalan v. State of Madras (1950 AIR 27)

It is a significant decision since the Supreme Court compared and decided on many Articles at the same time. The court interpreted Article 21 literally.

A.K Gopalan was a communist politician. He was imprisoned under the 'Prevention of Detention Act.' He filed a writ suit under Article 32(1), alleging that his arrest violated Article 21. Taking the literal interpretation of Article 21, the Supreme Court concluded that the protection provided by the Article is only accessible to those who are free and not in prison. The court prioritized Article 19 above Article 21. The court's decision, in this case, was overturned over 30 years later.

2. Shankari Prasad Singh Deo vs. Union of India [1951 AIR 458]

In this case, the issue of whether fundamental rights might be altered under Article 368 was raised. The Supreme Court ruled that the Parliament has the authority to amend Part III of the Constitution under Article 368, which makes a constitutional amendment legal even if it abridges any of the fundamental rights.

3. IC Golaknath and others vs. State of Punjab [1967 AIR 1643]

In this case, the Hon’ble Supreme Court overturned the judgment of the Shankari Prasad case and held that the Parliament lacked the authority to change Part III of the Constitution by the Rule of Law concept. However, the Constitution (24th Amendment) Act of 1971 introduced a new clause that restored the competence of Parliament to change the constitution by addition, alteration, or repeal by the method outlined in Article 368.

4. Maneka Gandhi v. Union of India [1978 SC 597]

Under Section 10(3)(c) of the Passport Act of 1967, the Passport Authority of India requested Maneka Gandhi to return her passport. She was denied the chance to be heard, therefore she filed a writ petition under Article 32, alleging that the passport authority's decision violated the Fundamental Rights available to her under Article 21. Justice Bhagwati ruled that Articles 14, 19, and 21 are not mutually exclusive and that the three are interrelated to create a Golden Triangle. The method established by legislation in Article 21 must be fair, just, and reasonable, and it must not be arbitrary or repressive. It must also comply with Article 19 and not violate Equality before the law in Article 14.


These three Articles play an important part in the functioning of our country and have a significant impact on our daily lives; they even have an impact on our rights as citizens in society. Originally, there was no Golden Triangle; nevertheless, it was realized that when the rights to equality, freedom and personal liberty are joined, they play a significant role in running the legal system, keeping the government in check, and defending individuals' rights.

"Loved reading this piece by khushi doshi?
Join LAWyersClubIndia's network for daily News Updates, Judgment Summaries, Articles, Forum Threads, Online Law Courses, and MUCH MORE!!"

Tags :

Category Others, Other Articles by - khushi doshi 


Post a Suggestion for LCI Team
Post a Legal Query