The central 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. The Court clarified that Article 212(1) does not protect such substantive decisions.
Article 212(1) bars courts from inquiring into procedural irregularities in legislative proceedings. However, the Court clarified that this bar does not apply to substantive actions like expulsions when they potentially violate constitutional or fundamental rights.
Article 142 empowers the Supreme Court to do complete justice in any case. Invoking this power, the Court quashed the expulsion order and directed the reinstatement of Sunil Kumar Singh, holding that the punishment was excessive and disproportionate.
During the case, the Election Commission had announced a bye-election to fill the vacant seat. The Supreme Court stayed the declaration of results for that election while the matter was under judicial consideration.
The Court applied the test of proportionality and found that the punishment of expulsion was excessive relative to the conduct in question. It observed that such overreach undermines constitutional principles and the democratic process.
The verdict reaffirms that legislatures must act within constitutional limits. Courts can intervene when legislative actions are arbitrary, disproportionate, or violate fundamental rights, thus preserving the balance of powers and democratic accountability.
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