The key issue was whether the expulsion of a Member of the Bihar Legislative Council (MLC) for remarks made against the Chief Minister was legally valid and proportionate. The petitioner, Sunil Kumar Singh, challenged his expulsion under Article 32 of the Constitution.
He was expelled for making remarks in the House that were considered objectionable and derogatory towards the Chief Minister of Bihar.
Yes. The Supreme Court held that legislative actions such as expulsions are not immune from judicial review, especially when they raise questions of proportionality and legality. Article 212(1) does not protect such substantive decisions.
Article 212(1) bars courts from inquiring into procedural irregularities of legislative proceedings. However, the Court clarified that this protection does not extend to substantive decisions like expulsion, particularly when they involve constitutional or fundamental rights violations.
Article 142 empowers the Supreme Court to deliver complete justice. Exercising this power, the Court quashed the expulsion and directed the reinstatement of Sunil Kumar Singh, finding the punishment excessive and disproportionate.
During the proceedings, the Election Commission announced a bye-election to fill the vacant seat. The Supreme Court stayed the declaration of the results for that election while the matter was still under judicial consideration.
The Court applied the test of proportionality and found the punishment of expulsion excessive relative to the conduct. It observed that such overreach undermines constitutional principles and democratic representation.
The verdict reinforces that even legislatures must act within constitutional limits. Courts can intervene when legislative actions are arbitrary, disproportionate, or violate fundamental rights, thereby upholding the rule of law and democratic accountability.
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