Why in News?

12th June 2025 marks 50 years since the Allahabad High Court invalidated Indira Gandhi’s 1971 election, setting off a chain of events that led to the imposition of the National Emergency on 25th June 1975.

Key Concepts & Definitions

Term	Definition
Indira Nehru Gandhi v. Raj Narain (1975)	A landmark Supreme Court case that led to the invalidation of Indira Gandhi’s 1971 Lok Sabha election on grounds of electoral malpractice.
National Emergency (NE)	A constitutional provision (Article 352) allowing the Centre to take extraordinary powers during war, external aggression, or armed rebellion.
Representation of the People Act, 1951	Law governing the conduct of elections and specifying grounds for disqualification and electoral offences.

What Was the Indira Gandhi v. Raj Narain Case?

Aspect	Details
Background	In the 1971 elections, Indira Gandhi defeated socialist leader Raj Narain. He alleged misuse of government machinery for her electoral campaign.
Allahabad HC Verdict	On 12 June 1975, the Court found her guilty of electoral malpractice and invalidated her election. She was barred from holding office.
Supreme Court Appeal	Indira Gandhi appealed for a stay. Political unrest mounted.
Emergency Declaration	On 25 June 1975, a National Emergency was declared citing internal disturbance—effectively suspending civil liberties, elections, and press freedom.

National Emergency: Provisions at a Glance

Provision	Details
Grounds	War, External Aggression, or Armed Rebellion under Article 352.
Territorial Extent	Whole or part of India (42nd Amendment).
Approval	Parliament must approve within 1 month (44th Amendment, 1978).
Duration	Valid for 6 months; can be extended indefinitely with 6-month approvals.
Revocation	President can revoke anytime; LS can disapprove via resolution.
Judicial Review	Originally barred (38th Amendment), later restored (44th Amendment & Minerva Mills, 1980).

Impact of Emergency on Constitutional Framework

➤ Centre-State Relations

Area	Effect During Emergency
Executive	Centre can issue binding directions to states.
Legislature	Parliament can legislate on State List matters.
Financial	President can alter revenue sharing with states (valid until FY ends after Emergency).

➤ Life of Legislatures

Body	Extension Rule
Lok Sabha	Extended 1 year at a time during NE.
State Assemblies	Similar extension rule, capped at 6 months after NE ends.

➤ Fundamental Rights

Article	Effect
Article 358	Suspends Article 19 during war or aggression-based Emergency.
Article 359	Allows Presidential Order to suspend enforcement of FRs (except 20 & 21) in any type of Emergency.

In a Nutshell (Mnemonic)

“I.N.D.I.R.A.”

• I – Invalidated election
• N – National Emergency declared
• D – Democratic rights suspended
• I – Internal disturbance cited
• R – Rights (FRs) curtailed
• A – Amendments followed (38th & 44th)

Prelims Practice Questions

1. Which article allows the suspension of Article 19 during a National Emergency?
   A) Article 358
   B) Article 359
   C) Article 352
   D) Article 360
2. Under which amendment was the term “internal disturbance” replaced by “armed rebellion”?
   A) 38th Amendment
   B) 44th Amendment
   C) 42nd Amendment
   D) 52nd Amendment
3. The verdict in the Indira Nehru Gandhi v. Raj Narain case directly led to—
   A) Abolition of the Rajya Sabha
   B) Imposition of National Emergency in 1975
   C) Introduction of GST
   D) Implementation of Panchayati Raj reforms

Mains Practice Questions

1. Examine the constitutional safeguards during a National Emergency and evaluate the changes brought by the 44th Amendment Act. (GS-2, 2023)
2. Discuss the impact of the 1975 Emergency on Indian democracy. How did it shape subsequent constitutional reforms? (GS-2)

Prelims Answers & Explanations

Qn	Answer	Explanation
1	A	Article 358 suspends Article 19 during war/external aggression.
2	B	44th Amendment replaced “internal disturbance” with “armed rebellion”.
3	B	The 1975 verdict led directly to the imposition of Emergency.