The S. R. Bommai v. Union of India case is a landmark judgment delivered by a nine-judge bench of the Supreme Court on March 11, 1994. The case originated from the arbitrary dismissal of the S.R. Bommai-led Janata Dal government in Karnataka in 1989 under Article 356 of the Constitution. The judgment was a direct response to the rampant political misuse of Article 356, which allows the imposition of President's Rule in a state.
The core ratio of the judgment is that the Presidential proclamation under Article 356 is not absolute and is subject to judicial review. This mechanism ensures the President's "satisfaction" is based on relevant material and not political expediency. The Court established that the majority of the Council of Ministers must be tested only on the floor of the House, not based on the subjective opinion of the Governor. Furthermore, the Legislative Assembly cannot be dissolved until the proclamation is approved by both Houses of Parliament.
The judgment significantly strengthened the principle of federalism and affirmed that democracy, secularism, and federalism are part of the Basic Structure of the Constitution. The principles laid down were consistent with the recommendations of the Sarkaria Commission Report (1988). Since the 1994 verdict, the use of Article 356 has been drastically curtailed, reinforcing its intended role as an extraordinary power and a last resort.