State of Uttar Pradesh v. Raj Narain
Encyclopedia
The State of Uttar Pradesh v. Raj Narain was a 1975 case heard by the Allahabad High Court
Allahabad High Court
The Allahabad High Court or the High Court of Judicature at Allahabad is a high court having jurisdiction over the Indian state of Uttar Pradesh since 1950...

 that found the then-Prime Minister of India
Prime Minister of India
The Prime Minister of India , as addressed to in the Constitution of India — Prime Minister for the Union, is the chief of government, head of the Council of Ministers and the leader of the majority party in parliament...

 Indira Gandhi
Indira Gandhi
Indira Priyadarshini Gandhara was an Indian politician who served as the third Prime Minister of India for three consecutive terms and a fourth term . She was assassinated by Sikh extremists...

 guilty of electoral malpractices. Ruling on the case that had been filed by the defeated opposition candidate Raj Narain
Raj Narain
Raj Narain was an Indian politician who, as a candidate of Janata Party for the Lok Sabha in 1977, ran for office in Rae Bareli constituency and defeated Indira Gandhi, the then Prime Minister of India...

, Justice Jagmohanlal Sinha
Jagmohanlal Sinha
Jagmohanlal Sinha was a former Indian Permanent Judge. He was known mostly for his 1975 ruling in State of Uttar Pradesh v. Raj Narain on the election of then Indian Prime Minister, Indira Gandhi, in which he declared the election invalid...

 invalidated Indira's win and barred her from holding elected office for six years. The decision caused a political crisis in India that led to the imposition of a state of emergency by Indira's government from 1975 to 1977.

Background

Raj Narain had contested the Indian general election, 1971
Indian general election, 1971
India held general elections to the 5th Lok Sabha. This fifth general elections, which were conducted for 518 seats from 518 constituencies, represented 27 Indian states and union territories. Indira Gandhi steered the Congress to a landslide victory in 1971...

 against Indira Gandhi, who represented the constituency of Rae Bareilly in the Lok Sabha
Lok Sabha
The Lok Sabha or House of the People is the lower house of the Parliament of India. Members of the Lok Sabha are elected by direct election under universal adult suffrage. As of 2009, there have been fifteen Lok Sabhas elected by the people of India...

, the lower house of the Indian Parliament. Indira was re-elected from Rae Bareilly by a two-to-one margin of the popular vote, and her Indian National Congress (R)
Indian National Congress (R)
Indian National Congress was a split in Indian National Congress, created by Indira Gandhi in 1967 when a united opposition, under the banner of Samyukt Vidhayak Dal, won control over several states in the Hindi belt. Indira Gandhi, the daughter of Nehru, and Congress president, was then...

 party won a sweeping majority in the Indian Parliament. Raj Narain filed a petition to appeal the verdict, alleging that Indira Gandhi used bribery, government machinery and resources to gain an unfair advantage in contesting the election. Narain specifically charged Indira of using government employees as election agents and for organising campaign activities in the constituency while still on the payroll of the government.

Ruling

On June 12, 1975 Justice Jagmohanlal Sinha found Indira Gandhi guilty of electoral malpractices. Sinha declared the election verdict in the Rae Bareilly constituency "null and void," and barred Indira from holding elected office for six years. While Sinha had dismissed charges of bribery, he had found Indira guilty of misusing government machinery as a government employee herself. The court order gave the Congress (R) twenty days to make arrangements to replace Indira in her official posts. Indira appealed the verdict to the Supreme Court of India
Supreme Court of India
The Supreme Court of India is the highest judicial forum and final court of appeal as established by Part V, Chapter IV of the Constitution of India...

, which granted a conditional stay of execution
Stay of execution
A stay of execution is a court order to temporarily suspend the execution of a court judgment or other court order. The word "execution" does not necessarily mean the death penalty; it refers to the imposition of whatever judgment is being stayed....

 on the ruling on June 24, 1975. On November 7, 1975 the Supreme Court of India formally overturned the conviction.

Fallout

The verdict was criticised by many, including the country's largest English newspaper, The Times of India
The Times of India
The Times of India is an Indian English-language daily newspaper. TOI has the largest circulation among all English-language newspaper in the world, across all formats . It is owned and managed by Bennett, Coleman & Co. Ltd...

, which compared the verdict to "firing the Prime Minister for a traffic ticket". The Congress (R) also staged numerous protests across the country in support of Indira. However, the verdict helped galvanize the opposition political parties, who demanded that Indira Gandhi resign from office immediately. Jayaprakash Narayan
Jayaprakash Narayan
Jayaprakash Narayan , widely known as JP Narayan, Jayaprakash, or Loknayak, was an Indian independence activist and political leader, remembered especially for leading the opposition to Indira Gandhi in the 1970s and for giving a call for peaceful Total Revolution...

, the leader of the Janata Morcha
Janata Morcha
The Janata Morcha was a coalition of Indian political parties formed in 1974 to oppose the government of Indian Prime Minister Indira Gandhi and her Congress party...

, a coalition of opposition political parties, called for a campaign of civil disobedience
Civil disobedience
Civil disobedience is the active, professed refusal to obey certain laws, demands, and commands of a government, or of an occupying international power. Civil disobedience is commonly, though not always, defined as being nonviolent resistance. It is one form of civil resistance...

 to oust Indira's government. On June 26, 1975 a state of emergency was declared by the President of India
President of India
The President of India is the head of state and first citizen of India, as well as the Supreme Commander of the Indian Armed Forces. President of India is also the formal head of all the three branches of Indian Democracy - Legislature, Executive and Judiciary...

 Fakhruddin Ali Ahmed
Fakhruddin Ali Ahmed
Fakhruddin Ali Ahmed was the fifth President of India from 1974 to 1977.-Early life and background:Fakhruddin's grandfather, Khaliluddin Ali Ahmed, of Kacharighat near Golaghat, Assam, married in one of the families who were the relics of Emperor Aurangzeb's bid to conquer Assam Ahmed was born on...

, upon the advice of Prime Minister Indira Gandhi. The government argued that the political disorder was a threat to national security. Using the sweeping powers granted by the Emergency decree, thousands of opposition leaders and activists were arrested, press censorship was introduced and elections were postponed. During this period, Indira Gandhi's Congress (R) used its parliamentary majority to amend the Indian Constitution and overwrite the law that she had been found guilty of violating. When the government finally called elections in 1977, the opposition Janata Party
Janata Party
The Janata Party was an amalgam of Indian political parties opposed to the state of emergency imposed by the government of Prime Minister Indira Gandhi and her Indian National Congress...

alliance defeated Indira Gandhi's Congress (R) party. Raj Narain defeated Indira Gandhi in the Rae Bareilly constituency by a margin of 55,200 votes.
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