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The most important rights in the constitution are those of Equality (Article 14), Freedom (Article 19), and Life and Liberty (Article 21), collectively known as the “trinity of the Indian Constitution” and widely recognized as the golden triangle. The relationship between these rights was established by the nation’s highest court in the landmark case of Maneka Gandhi v. Union of India.[1]


The world has never developed a Constitution that is longer than the one in India. There are 12 schedules and 470 articles divided into 25 parts every item of legislation and provision that is outlined in this compact documentation is described in full as a text that is both rigorous and pliable. Our constitution is dynamic as it accepts modifications in the form of amendments but only after ensuring a clear procedure outlined in the provisions of the constitution. The Preamble is regarded as the summary of the enormous handwritten book of the institutions that the Indian people gave to themselves. It offers us the values of socialism, republicanism, justice, freedom, liberty and brotherhood.


Part III of this Constitution is concerned with the Fundamental Rights, which are also known as the Magna Carta of the Constitution. Since our Constitution drafters adopted ideas from other international constitutions, the American Constitution had a significant impact on the concept of a fundamental right (Bill of Rights). There are seven rights in the family of basic rights that have been given the designation of fundamental rights given that they are vital for a citizen of a nation to live in dignity and freedom. After the 44th constitutional amendment, which was passed in 1978, the Right to Property was moved from the list of Fundamental Rights to Article 300A. Article 14 (the right to equality), Article 19 (the right to freedom), and Article 21 (the right to life and liberty) are ranked highest out of the six fundamental rights. Human very survival is in jeopardy without these rights. Three of these rights seem to be contributing in accomplishing Karl Marx’s vision of safeguarding the helpless from the tyranny of exploitation. Liberty, equality, and fraternity serve as the fundamentals of democratic nations.


The Golden Triangle also known as the Trinity of the Indian Constitution is made up of three of the most crucial rights that are provided to us by the family of Fundamental Rights these are Article 14, Article 19 and Article 21.

Article 14: “Equality before law The State shall not deny to any person equality before the law or the equal protection of the laws within the territory of India. Prohibition of discrimination on grounds of religion, race, caste, sex or place of birth”[2]

No person shall be deprived of equality before the law and should get equal protection from the law.

Article 19: “All citizens shall have the right

(a) to freedom of speech and expression;

(b) to assemble peaceably and without arms;

(c) to form associations or unions;

(d) to move freely throughout the territory of India;

(e) to reside and settle in any part of the territory of India; and

(f) to practice any profession, or to carry on any occupation, trade or business”[3]

Article 19 provides different types of freedoms, from speech and expression to peaceful assemblage, from forming unions and associations to free movement in the territory of India and many more.

Article 21: “Protection of life and personal liberty. No person shall be deprived of his life or personal liberty except according to procedure established by law”[4]

This article is very crucial and sensitive as it talks about the Right to life, not about mere animal existence instead it talks about a life full of dignity and mental peace, a life free of external oppression and dangers. The trio is made from digging out the common path for fraternity, liberty and equality to protect an individual’s well-being in a state that is democratic.

According to our framers, these rights are essential for the development of an individual and the maintenance of democracy and protect it from turning into a theocratic or dictatorial state. These rights together are the password to the coffer of the wellness of the nation as a whole. All these rights exist together as without one other two are incomplete. Their existence is dependent on each other. If a person’s life and liberty are at stake then that person is also likely to face a violation of his right to equality and freedom. Their correlation can be better understood by looking at the facts and judgment of the landmark case of Maneka Gandhi v. Union of India[5].


Maneka Gandhi is an environmentalist, animal right and political activist. She had held the title of Lok Sabha Member. Her passport was confiscated by the authorities when she was asked to relinquish it by them in accordance with the Passport Act’s 1967 stipulations in July 1977. It’s noteworthy to note that she received her passport on June 1st of 1976, a year earlier. Respondents declined to provide a suitable response when the petitioner questioned them about the grounds for the external affairs ministry’s action and instead only offered the arbitrary and ambiguous justification that the public interest was at stake. According to Article 32, which gives a person the ability to submit a writ petition directly in the highest court of the country against the breach of the basic rights, the petitioner sought the Apex court of the nation.

 After hearing all of the arguments from the petitioner and respondent sides, a seven-judge SC panel overturned the ruling in A.K. Gopalan v. State of Madras[6] in which the court ruled that Article 21 of the constitution did not require Indian courts to apply a due process of law standard[7] said that Article 21 cannot be read in isolation or independently and that all cases involving the concepts of life and liberty must also be evaluated in light of Articles 14 and 19 of the constitution along with Article 21. The apex Court expanded the application and purview of Article 21 in this instance. The term “personal liberty” that is included in Article 21 has a broad scope and should be addressed in light of another freedom mentioned in article 19.


We have read about the relationship that these three rights share among themselves. They are beads of a common string and cannot be seen independently. One justifies the meaning of the other, can also be said in a way that one completes the other. Citizens of a democratic nation have the right to freedom, also considered the natural right by Locke. He too was aware of the fact that an individual cannot live a life without freedom and accompanying it right to equality is that crucial right which sheds the walls of exploitation and provides an opportunity to live a life without facing discrimination on any basis and both these rights cannot be proved fruitful unless there is no danger to one’s life and that an individual is provided full liberty to profess these rights.

Author(s) Name: Anamika Sharma (Institute of Legal Studies, Panjab University)


[1] Maneka Gandhi vs Union of India 1978, AIR 597

[2] Constitution of India, 1950, art 14

[3] Constitution of India, 1950, art 19

[4] Constitution of India, 1950, art 21

[5] Maneka Gandhi vs Union of India 1978, AIR 597

[6] A.K.Gopalan vs State of Madras 1950, AIR SC 27

[7]The Indian Express Staff, ‘AK Gopalan’s Petition Dismissed’, (The Indian Express) (20 May 1950)  01