The S.R. Bommai v. Union of India case is a landmark judgment of the Supreme Court of India, delivered by a nine-judge bench on March 11, 1994. Its origin lies in the arbitrary dismissal of the Janata Dal government led by Chief Minister S.R. Bommai in Karnataka on April 21, 1989, under Article 356 of the Constitution. The judgment was necessitated to curb the rampant misuse of Article 356, which allows the imposition of President's Rule in a state.
The core mechanism established by the judgment is the judicial restriction on the President's power under Article 356. The ratio decidendi of the case is that the power to dismiss a state government is a "conditioned power" and must be used "sparingly". The judgment mandated that the Presidential Proclamation under Article 356 is subject to judicial review on grounds of mala fide intention or extraneous considerations. Crucially, it held that the majority of the government must be tested only on the floor of the Assembly, not based on the subjective opinion of the Governor. Furthermore, the President can only suspend the Legislative Assembly until the Proclamation is approved by both Houses of Parliament under Article 356(3). If Parliament does not approve it within two months, the Proclamation lapses, and the dismissed government is revived.
This judgment connects directly to the principles of Federalism and the Basic Structure Doctrine, affirming that secularism and federalism are essential features of the Constitution. The principles laid down were consistent with the recommendations of the Sarkaria Commission (1988). The core principles of judicial review and the supremacy of the floor test have not been replaced or amended and remain the constitutional standard for the application of Article 356.