Background of the Case:
- Raj Narain, who lost the 1971 Rae Bareli election to Indira Gandhi, filed a petition in the Allahabad High Court alleging electoral malpractices and misuse of government machinery.
- The case was ultimately heard by Justice Jagmohan Lal Sinha, who pronounced the verdict on June 12, 1975.
Allahabad High Court Verdict:
- The court found Indira Gandhi guilty of corrupt electoral practices under the Representation of the People Act, 1951.
- Her election to the Lok Sabha was declared void, and she was disqualified from holding any elected office for six years.
- This was unprecedented—the first time the judiciary invalidated a sitting Prime Minister’s election.
Aftermath – Declaration of Emergency:
- Just 13 days later, on June 25, 1975, Indira Gandhi declared a National Emergency under Article 352 citing “internal disturbance”.
- This led to a 21-month suspension of fundamental rights, press censorship, mass arrests of opposition leaders, and curbing of democratic institutions.
SC verdict in Raj Narain Case (Appeal):
- The Supreme Court observed that the right to free and fair elections is a part of the basic structure of the Constitution.
- It referred to the landmark Keshavananda Bharati case (1973), where it was held that Parliament cannot make amendments that alter the basic structure of the Constitution.
- The Court emphasized that rule of law and judicial review are essential to democracy, and Parliament cannot bypass these principles through constitutional amendments.
- Regarding Indira Gandhi’s appeal, the Court found that there was no strong evidence to prove that she had misused government resources or violated election laws, and thus her election was upheld in the final ruling.
Why in News?
- June 12, 2025 marks the 50th anniversary of the Allahabad High Court judgment (1975) that set aside Prime Minister Indira Gandhi’s 1971 election, triggering the Emergency.

