Citation: (1994) 3 SCC 1 | Court: Supreme Court of India (nine-judge Constitution Bench) | Decided: 11 March 1994 | Status: Good law -- the controlling precedent on Article 356, cited in every subsequent President's Rule dispute.
In S.R. Bommai v. Union of India, a nine-judge Constitution Bench held that the President's power under Article 356 to dismiss a state government and impose President's Rule is not immune from judicial review, that federalism is part of the Constitution's basic structure, and that a state government's majority should ordinarily be tested on the floor of the Assembly rather than through the Governor's own subjective assessment -- a ruling that has repeatedly checked the misuse of Article 356 since 1994.
Case background and the legal question
S.R. Bommai, the former Chief Minister of Karnataka, was one of several state Chief Ministers whose
governments were dismissed under Article 356 amid recurring allegations that the Centre was using
President's Rule as a political tool against opposition-ruled states, rather than reserving it for genuine
constitutional breakdown. Several such dismissals from different states were clubbed together, presenting
the Supreme Court with the central question: is the President's satisfaction under Article 356 -- the
Governor's report that a state's government cannot be carried on in accordance with the Constitution --
open to judicial review at all, or is it a purely political question the courts must stay out of?
What the Supreme Court held
The Court held, by majority, that the President's satisfaction under Article 356 is judicially reviewable,
though the scope of that review is limited to examining whether the satisfaction was based on relevant
material, was mala fide, or was based on wholly extraneous or irrelevant grounds -- courts don't substitute
their own political judgment for the executive's. The Court also held that a state government's majority in
the Assembly should ordinarily be tested through an open floor vote, not merely on the Governor's private
assessment, and that until both Houses of Parliament approve a Proclamation under Article 356, the President
cannot dissolve the state Assembly. Separately, the Court held that federalism and secularism are part of
the Constitution's basic structure.
Why this matters for NRIs, and the case's status today
For NRIs following developments in home-state politics, or holding property, business, or family
interests that can be affected by abrupt changes in state administration, Bommai is the reason a state
government's dismissal under Article 356 cannot simply be announced and left unchallenged -- it establishes
a real, judicially enforceable check, and the “floor test” principle it laid down remains the
standard mechanism Indian courts and Governors still apply today whenever a state government's majority is
genuinely in doubt. The judgment remains good law, is treated as one of the Supreme Court's most significant
federalism rulings, and continues to be cited whenever Article 356 is invoked or challenged.
Can courts review the President's decision to impose President's Rule on a state?
Yes -- S.R. Bommai established that this power is judicially reviewable, though the review is limited to
checking whether the decision was based on relevant material and made in good faith, not to substituting the
court's own political judgment.
What is the “floor test” and where does it come from?
The floor test is the principle, established in Bommai, that whether a state government still commands a
majority should ordinarily be tested through an open vote on the floor of the Legislative Assembly, rather
than relying solely on the Governor's own subjective assessment of the numbers.
Is federalism formally recognized as part of India's constitutional “basic structure”?
Yes -- Bommai held that federalism (along with secularism) is part of the basic structure of the
Constitution, meaning it cannot be abrogated even by a constitutional amendment.
