P.N BHAGWATI
Justice Prafullachandra Natwarlal Bhagwati, born on December 21st, 1921, in Ahmedabad, Gujarat, was a legal luminary whose contributions left an indelible mark on the Indian judicial landscape. His illustrious career, spanning decades, was characterized by a deep commitment to justice and the rule of law.
Early Life and Education
Justice Bhagwati’s journey into the legal realm commenced with an undergraduate degree in mathematics from Elphinstone College, Bombay, in 1941. His pursuit of legal knowledge led him to Government Law College, Bombay, where he studied law and honed his legal acumen, graduating in 1945.
Rise in the Legal Hierarchy
After over a decade of legal practice in the Bombay High Court, Justice Bhagwati’s talent and dedication were recognized when he was appointed as a Judge at the Gujarat High Court in 1960. His tenure at the Gujarat High Court was marked by excellence, and he served as its Chief Justice for six years. Notably, he also assumed the role of Gujarat’s Acting Governor in 1967 and 1973.
In 1973, Justice Bhagwati’s career reached new heights as he was appointed as a Judge at the Supreme Court of India. His keen legal mind and unwavering commitment to justice soon propelled him into the role of the 17th Chief Justice of India, a position he assumed on July 12th, 1985. He held the esteemed office of Chief Justice of India for 18 months, leaving a lasting impact on the nation’s legal landscape.
Contributions Beyond the Bench
Post his retirement from the Supreme Court, Justice Bhagwati continued to serve the cause of justice. He actively participated in various United Nations committees and missions, further extending his commitment to the principles of justice and human rights.
In recognition of his exemplary contributions to public affairs, Justice Bhagwati was awarded the Padma Vibhushan in 2007, a testament to his dedication to the welfare of society.
Judicial Legacy
Justice Bhagwati’s prolific judicial career is reflected in his extensive body of work. During his 13-year term at the Supreme Court, he authored 342 judgments and was an integral part of 820 benches. His legal expertise predominantly centered on criminal law matters, and he made significant contributions to constitutional law.
Pioneer of Legal Concepts
Justice Bhagwati introduced groundbreaking concepts to Indian jurisprudence. Notable among them are:
- Public Interest Litigation (PIL): He played a pivotal role in the development of PIL, making it an effective tool for citizens to seek justice for societal issues.
- Absolute Liability: In the case of MC Mehta v Union of India, he introduced the concept of absolute liability, holding that hazardous activities must adhere to a heightened standard of liability, ensuring accountability for damages caused, irrespective of negligence.
Landmark Judgments
Justice Bhagwati’s expansive approach to constitutional interpretation is evident in several landmark judgments:
- In the case of Francis Coralie Mullin v The Administrator, he broadened the scope of the right to life to include the Right to Live with Human Dignity, emphasizing adequate nutrition, clothing, and shelter.
- In SP Gupta v President of India and Ors, he highlighted the importance of increasing access to justice and encouraged the Court to respond to letters addressing public interest issues.
- Bandhua Mukti Morcha v Union of India saw him champion the Right to Work and ordered state authorities to take measures to end child labor and provide a safe working environment.
- In Maneka Gandhi v Union of India, he expanded the scope of Article 21, asserting that personal liberty encompasses all rights that constitute an individual’s personal liberty, and no one can be deprived of this right except according to a fair and reasonable procedure established by law.
Justice Prafullachandra Natwarlal Bhagwati’s legacy is one of legal brilliance, unwavering commitment to justice, and a tireless pursuit of a just and equitable society. His contributions continue to shape India’s legal framework and inspire generations of legal scholars and practitioners.
Written by – Anurag kesharwani
Student of BHU LAW FACULTY
