President’s Rule and Its Misuse: The Bommai Case, 1994

Article 356 lets the President dismiss a state government and run it directly from the Centre. Between 1950 and 1994, it was invoked close to 100 times — often against political rivals, not genuine breakdowns. One dismissal, of Karnataka’s S.R. Bommai in 1989, led to the Supreme Court judgment that changed all of this.

1.What is Article 356, and how was it overused before 1994?

Article 356 allows the President to impose “President’s Rule” over a state. This dismisses the state’s government and runs it directly from the Centre. It can be used whenever the state’s constitutional machinery is said to have broken down.

Between 1950 and 1994, the provision was invoked close to 100 times, frequently against non-Congress state governments. Critics called this a pattern of political misuse, not genuine constitutional breakdown.

S.R. Bommai became Chief Minister of Karnataka’s Janata Dal government on 13 August 1988. He was dismissed when President’s Rule was imposed on 21 April 1989, after legislators defected.

2.How did Bommai’s dismissal actually happen?

Nineteen legislators sent Karnataka’s Governor letters withdrawing their support from Bommai’s government. Bommai asked for a floor test in the Assembly, and even presented a resolution signed by his own party’s legislators.

Seven of those 19 legislators then retracted their letters, saying their signatures had been obtained by deceit. The Governor ignored this and still recommended President’s Rule.

3.What did the 1994 Bommai judgment actually decide?

The Supreme Court’s 9-judge bench decided S.R. Bommai v. Union of India on 11 March 1994.

The Court held that a state government’s majority must be tested on the floor of the Assembly, not judged by the Governor’s own opinion. It also ruled that a President’s Rule proclamation is subject to judicial review.

• Courts can examine whether the President’s “satisfaction” was based on relevant material, or was mala fide.
• If a proclamation is found unconstitutional, courts can restore the dismissed government.
• A proclamation must get Parliament’s approval within two months, or it lapses.
• The Court held that secularism is part of the Constitution’s basic structure, and a state government acting against it could itself justify invoking Article 356.

4.Why did the Court reach different verdicts in the six clubbed states?

The Supreme Court heard six petitions together, from Karnataka, Meghalaya, Nagaland, Madhya Pradesh, Rajasthan and Himachal Pradesh. Nagaland’s government had already fallen in August 1988, and Meghalaya’s in October 1991, both before Bommai’s own dismissal. Madhya Pradesh, Rajasthan and Himachal Pradesh lost their BJP state governments in December 1992, right after the Babri Masjid demolition.

The nine judges struck down the Karnataka, Meghalaya and Nagaland proclamations as unconstitutional, restoring the floor-test principle. But the Court upheld the Madhya Pradesh, Rajasthan and Himachal Pradesh dismissals, since those governments were accused of undermining secularism after the demolition.

Five judges — Sawant, Kuldip Singh, Jeevan Reddy, Agrawal and Pandian — formed the majority view. Four judges — Ahmadi, Verma, Dayal and Ramaswamy — dissented in part.

5.What happened to Article 356 after Bommai?

Dr. B.R. Ambedkar had expressed hope during the Constituent Assembly debates that Article 356 would remain a “dead letter,” rarely used. The judgment’s effect was dramatic. Article 356 was invoked only around 29 times between 1995 and 2021. That compares to close to 100 times in the roughly 45 years before Bommai.

The Bommai case is considered a landmark in Indian federalism, strengthening state governments against arbitrary central intervention while leaving the provision available for genuine breakdowns.

6.Exam Angle: the usual traps here

• Trap 1: know precisely what changes under Article 356. The legislature’s powers shift to Parliament, but the Assembly can simply be kept in suspended animation rather than dissolved outright.
• Trap 2: don’t confuse the Bommai judgment’s date (11 March 1994) with Bommai’s own dismissal date (21 April 1989). That is a five-year gap exams like to test.
• Trap 3: remember the Bommai case split verdict. It is not a simple “struck down everywhere” story — three of the six clubbed proclamations were actually upheld.