The Golden Triangle of the Constitution of India is a term used to describe the fundamental rights enshrined in Articles 14, 19, and 21 of the Indian Constitution. These articles are considered the most important and interdependent provisions of the Constitution and form the cornerstone of Indian democracy.

Article 14 of the Indian Constitution guarantees the right to equality before the law and equal protection of the laws to all persons. It prohibits discrimination on the grounds of religion, race, caste, sex or place of birth. This means that every person in India is entitled to equal protection of the law and equal treatment under the law, regardless of their background or social status.

Article 19 of the Indian Constitution guarantees certain freedoms to all citizens, such as the freedom of speech and expression, the freedom to assemble peacefully, the freedom to form associations or unions, the freedom to move freely throughout the territory of India, and the freedom to practice any profession or carry on any trade, business or occupation.

Article 21 of the Indian Constitution guarantees the right to life and personal liberty to all persons. It ensures that no person shall be deprived of their life or personal liberty except according to the procedure established by law.

These three articles together form the Golden Triangle of the Indian Constitution, which is essential to protect the fundamental rights of citizens and ensure that justice is served. The three articles are interdependent and cannot be interpreted in isolation. For example, the right to equality under Article 14 cannot be achieved without the freedom of speech and expression guaranteed by Article 19. Similarly, the right to life and personal liberty under Article 21 is dependent on the protection of equal rights and freedoms under Article 14 and Article 19.

The Golden Triangle of the Constitution of India reflects the values and principles of the Indian Constitution, and it plays a crucial role in protecting the fundamental rights and freedoms of all individuals in India.

Meaning Of Golden Triangle In Indian Constitution

The Golden Triangle in the Indian Constitution refers to the interdependent and interconnected nature of three fundamental rights enshrined in the Constitution, namely, Articles 14, 19, and 21. These three articles are considered the most important provisions of the Constitution and form the basis of democracy in India.

The Golden Triangle of the Indian Constitution signifies the interdependence and interconnected nature of these three fundamental rights. They are mutually reinforcing and provide a framework for protecting the basic rights and freedoms of all individuals in India. For instance, the right to equality before the law under Article 14 is necessary for ensuring the freedom of speech and expression guaranteed by Article 19, and the right to life and personal liberty under Article 21 is dependent on the protection of equal rights and freedoms under Article 14 and Article 19.

Together, these three articles form the Golden Triangle of the Indian Constitution. They are interdependent and cannot be interpreted in isolation. For example, the right to equality under Article 14 cannot be achieved without the freedom of speech and expression guaranteed by Article 19. Similarly, the right to life and personal liberty under Article 21 is dependent on the protection of equal rights and freedoms under Article 14 and Article 19.

The Golden Triangle of the Indian Constitution is considered crucial for the protection of fundamental rights and the maintenance of democracy in India. It ensures that every citizen is treated equally before the law and is entitled to basic freedoms and rights, such as the freedom of speech, assembly, and movement, and the right to life and personal liberty.

The Golden Triangle of the Indian Constitution reflects the values and principles of the Indian Constitution and plays a vital role in maintaining the democratic and constitutional fabric of India. It ensures that all citizens are treated equally and are entitled to basic freedoms and rights.

Fundamental Rights In Indian Constitution

The Fundamental Rights in the Indian Constitution are enshrined in Part III of the Constitution, which guarantees a set of rights and freedoms to every citizen of India. These rights are considered fundamental as they are essential for the development of the individual and the nation as a whole.

The fundamental rights in the Indian Constitution include the following:

1. Right to Equality (Articles 14-18): This right ensures that every individual is treated equally before the law and prohibits discrimination on the grounds of religion, race, caste, sex, or place of birth.
2. Right to Freedom (Articles 19-22): This right guarantees the freedom of speech and expression, the right to assemble peaceably and without arms, the right to form associations or unions, the right to move freely throughout the territory of India, and the right to practice any profession or occupation.
3. Right against Exploitation (Articles 23-24): This right prohibits all forms of forced labor, trafficking, and the exploitation of children.
4. Right to Freedom of Religion (Articles 25-28): This right guarantees the freedom of religion and the right to practice, profess, and propagate any religion of one's choice.
5. Cultural and Educational Rights (Articles 29-30): This right provides protection to the cultural and educational interests of minorities and other marginalized communities.
6. Right to Life and Personal Liberty (Article 21): This right guarantees the right to life and personal liberty and protects an individual from arbitrary arrest, detention, or torture.
7. Right to Constitutional Remedies (Article 32): This right provides citizens with the power to enforce their fundamental rights through the courts of law.

These fundamental rights are essential for the protection and development of the individual, and they also serve as a check against the potential misuse of power by the state. The Indian Constitution guarantees these rights to every citizen, and the government and the judiciary are responsible for ensuring that these rights are upheld and protected.

Article-14: Constitution Of India

Article 14 of the Constitution of India is a fundamental right that guarantees equality before the law and equal protection of the law to all individuals in India. It prohibits discrimination on the grounds of religion, race, caste, sex, or place of birth.

• The article states that the State shall not deny to any person equality before the law or the equal protection of the laws within the territory of India. It further explains that equality before the law means that every person, regardless of their social status, economic condition, or political influence, is subject to the same laws as others and is treated equally under the law.
   
• The principle of equal protection of the laws means that the State cannot discriminate between persons who are similarly situated and must treat them equally under the law. The State cannot make arbitrary or discriminatory laws that violate the principle of equality.
   
• Article 14 also prohibits discrimination by private entities in matters of employment, trade, and business. This means that private individuals or organizations cannot discriminate against any person based on their religion, race, caste, sex, or place of birth.
   
• The right to equality is not absolute and can be restricted in certain circumstances, such as in the interest of national security, public order, morality, or health. However, such restrictions must be reasonable and not arbitrary.
   
• Article 14 is a cornerstone of the Indian Constitution and is an essential feature of India's democratic and secular character. It ensures that all individuals are equal before the law and are entitled to equal protection of the law. The article has been interpreted and applied in numerous cases by the Indian judiciary to ensure that the principle of equality is upheld and that discrimination is eradicated from Indian society.

Article 14 of the Constitution of India is a crucial provision that ensures equality before the law and equal protection of the law to all individuals in India. It is a fundamental right that guarantees that every person is subject to the same laws and is treated equally under the law, regardless of their social status, economic condition, or political influence.

Article-14: Constitution Of India Landmark Judgement

There have been several landmark judgments in India that have interpreted Article 14 of the Constitution and expanded its scope.

Some of these judgments are:

• Keshavananda Bharati v. State of Kerala (1973):[i]
  This judgment established the basic structure doctrine, which held that certain fundamental principles of the Constitution, including the right to equality, cannot be amended by the Parliament. This ensured that the fundamental rights guaranteed by the Constitution are protected and cannot be diluted by the government.
   
• Maneka Gandhi v. Union of India (1978):[ii]
  This judgment expanded the scope of Article 14 and held that the right to travel abroad is an integral part of the right to personal liberty. It also established the principle of natural justice, which requires that any action taken by the government must be fair, just and reasonable.
   
• Indra Sawhney v. Union of India (1992):[iii]
  This judgment upheld the reservation policy for the Scheduled Castes and Scheduled Tribes but held that the reservation policy cannot exceed 50% of the available seats. It also established the principle of creamy layer, which excludes the economically and socially advanced members of the backward classes from the benefits of reservation.
   
• Naz Foundation v. Government of NCT of Delhi (2009):[iv]
  This judgment decriminalized homosexuality and upheld the right to equality of the LGBT community. It held that discrimination against individuals based on their sexual orientation violates Article 14 and the right to life and personal liberty guaranteed by Article 21 of the Constitution.

These judgments have helped to expand the scope of Article 14 and ensure that the right to equality is upheld in all spheres of life. They have also established the principle that the government must act fairly and justly in all its actions and policies.

Article 19: Constitution Of India

Article 19 of the Constitution of India guarantees certain fundamental freedoms to all citizens of India. These freedoms include the right to freedom of speech and expression, the right to assemble peacefully and without arms, the right to form associations or unions, the right to move freely throughout the territory of India, the right to reside and settle in any part of the country, and the right to practice any profession, occupation, trade, or business.

• The right to freedom of speech and expression includes the right to express one's views, opinions, thoughts, and beliefs through any medium such as speech, writing, or through audio-visual means. However, this right is subject to reasonable restrictions in the interest of sovereignty and integrity of India, security of the State, friendly relations with foreign States, public order, decency or morality, or in relation to contempt of court, defamation, or incitement to an offence.
   
• The right to assemble peacefully and without arms allows citizens to gather together for peaceful protests, demonstrations, and meetings without the use of weapons. However, this right is also subject to reasonable restrictions in the interest of public order and morality.
   
• The right to form associations or unions allows citizens to come together and form groups for a common purpose, such as a trade union, political party, or social organization. However, this right is also subject to reasonable restrictions in the interest of sovereignty and integrity of India, public order, and morality.
   
• The right to move freely throughout the territory of India allows citizens to travel within the country without any restrictions, subject to reasonable restrictions in the interest of public order, decency, and morality.
   
• The right to reside and settle in any part of the country allows citizens to live and work in any part of India, subject to reasonable restrictions in the interest of public order, health, and morality.

Overall, Article 19 is an important safeguard for the fundamental freedoms of citizens and is essential for upholding the principles of democracy and liberty.

Article-19: Constitution Of India Landmark Judgement

There have been several landmark judgments in India that have interpreted and expanded the scope of Article 19 of the Constitution.

Some of these judgments are:

• Romesh Thappar v. State of Madras (1950):[v]
  This judgment established the principle that the right to freedom of speech and expression includes the right to criticize the government and its policies, even if such criticism is unpopular or inconvenient.
   
• Maneka Gandhi v. Union of India (1978):[vi]
  This judgment expanded the scope of the right to freedom of movement to include the right to travel abroad. It also held that any restriction on this right must be reasonable and cannot be arbitrary.
   
• Secretary, Ministry of Information and Broadcasting v. Cricket Association of Bengal (1995):[vii]
  This judgment established the principle that the right to freedom of speech and expression also includes the right to receive information and ideas from any source, including the media.
   
• State of Gujarat v. Mirzapur Moti Kureshi Kassab Jamat (2005):[viii]
  This judgment held that the right to carry on any trade or business includes the right to conduct slaughterhouses, subject to reasonable restrictions in the interest of public health and hygiene.
   
• Puttaswamy v. Union of India (2017):[ix]
  This judgment upheld the right to privacy as a fundamental right under Article 19 and Article 21 of the Constitution. It held that any restriction on the right to privacy must be reasonable and must serve a legitimate state interest.

These judgments have helped to expand the scope of Article 19 and ensure that the fundamental freedoms guaranteed by the Constitution are upheld in all spheres of life. They have also established the principle that any restriction on these freedoms must be reasonable and cannot be arbitrary.

Article 21: Constitution Of India

Article 21 is a fundamental right enshrined in the Constitution of India, which guarantees the protection of the right to life and personal liberty of every citizen of India. It is considered as one of the most significant and sacrosanct provisions of the Constitution, as it ensures that every citizen has the right to life with dignity.

• The Article states that no person shall be deprived of his life or personal liberty except according to the procedure established by law. This means that the State can take away a person's life or personal liberty only if it follows the due process of law.
   
• Article 21 has been interpreted by the judiciary in various cases, and its scope has been expanded over the years to include the right to livelihood, the right to travel abroad, the right to privacy, the right to a pollution-free environment, the right to a fair trial, the right to legal aid, the right to health, and the right to die with dignity.
   
• The fundamental right to life and personal liberty under Article 21 is not only limited to the protection of physical existence but also extends to mental, social, and economic well-being. The judiciary has held that the right to life and personal liberty under Article 21 is a dynamic and evolving concept, and any action by the government that violates these rights must be fair, just, and reasonable.
   
• Article 21 is a cornerstone of the Indian Constitution and ensures that every citizen of India has the right to live with dignity and freedom. It is the duty of the State to protect and uphold this fundamental right and ensure that every citizen can exercise their rights and freedoms without any fear or coercion.

Article-21: Constitution Of India Landmark Judgement

There have been several landmark judgments in India that have interpreted and expanded the scope of Article 21 of the Constitution.

Some of these judgments are:

• Maneka Gandhi v. Union of India (1978):[x]
  This judgment expanded the scope of Article 21 and held that the right to life and personal liberty includes the right to travel abroad. It established the principle of natural justice and held that any action taken by the government must be fair, just, and reasonable.
   
• Olga Tellis v. Bombay Municipal Corporation (1985):[xi]
  In this case, the Supreme Court held that the right to livelihood is a part of the right to life and personal liberty under Article 21. The court observed that the right to livelihood is a basic human right and deprivation of this right would affect the right to life.
   
• State of Maharashtra v. Chandrabhan Tale (1983):[xii]
  In this case, the Supreme Court held that custodial violence and torture violated the right to life and personal liberty under Article 21. The court observed that the fundamental right to life and liberty cannot be restricted even if the person is in police custody or under arrest.
   
• Vishaka v. State of Rajasthan (1997):[xiii]
  In this case, the Supreme Court held that sexual harassment at the workplace violates the right to life and personal liberty of women under Article 21. The court laid down guidelines to prevent sexual harassment at the workplace, which are known as the Vishaka guidelines.
   
• Common Cause (A Regd. Society) v. Union of India (2018): [xiv]
  In this case, the Supreme Court recognized the right to die with dignity as a part of the right to life and personal liberty under Article 21. The court legalized passive euthanasia and laid down guidelines for it.

These landmark judgments have expanded the scope of Article 21 and ensured that the right to life and personal liberty of every citizen is protected. The judiciary has interpreted Article 21 in a way that guarantees not only physical but also mental, social, and economic wellbeing.

Supreme Court Landmark Judgement: Golden Triangle

The Golden Triangle case is a landmark judgement delivered by the Supreme Court of India on 30th March 1989 in the case of Parmanand Katara v. Union of India [xv]. The judgement dealt with the issue of emergency medical aid to victims of road accidents and the duty of hospitals and doctors to provide such aid.

• In this judgement, the Supreme Court recognized the fundamental right to life under Article 21 of the Constitution, which includes the right to emergency medical aid. The court observed that the right to life includes the right to live with human dignity, and any act or omission that impairs this right is a violation of Article 21.
   
• The court further held that it is the duty of every hospital and doctor to provide emergency medical aid to the victims of road accidents without waiting for procedural formalities or the arrival of the police. The court also observed that the duty of doctors and hospitals to provide medical aid arises from their professional commitment to society and their ethical obligations.
   
• The judgement also established the concept of the "Golden Hour," which refers to the critical hour after a traumatic injury, during which timely medical intervention can make the difference between life and death. The court held that every hospital and doctor must take necessary steps to ensure that victims of road accidents receive emergency medical aid within the "Golden Hour."
   
• The Golden Triangle case has had a significant impact on the provision of emergency medical aid in India. It has helped to raise awareness about the importance of timely medical intervention in saving lives, and has led to the development of various schemes and programs aimed at improving emergency medical services in the country.

Overall, the Golden Triangle case is a landmark judgement that has helped to strengthen the right to life under Article 21 of the Constitution and has emphasized the importance of the duty of hospitals and doctors to provide emergency medical aid to victims of road accidents.

Conclusion
In conclusion, the Golden Triangle of the Constitution of India, consisting of Articles 14, 19, and 21, represents the fundamental rights of citizens to equality before law, freedom of speech and expression, and the right to life and personal liberty, respectively. These three articles are interrelated and provide the foundation for the protection of the basic rights and freedoms of citizens in India.

The Supreme Court of India has played a significant role in interpreting and expanding the scope of these fundamental rights through various landmark judgements. The Golden Triangle case, in particular, has emphasized the importance of the duty of hospitals and doctors to provide emergency medical aid to victims of road accidents and has helped to strengthen the right to life under Article 21 of the Constitution.

The Golden Triangle case, in particular, has emphasized the importance of the right to life and the duty of hospitals and doctors to provide emergency medical aid to victims of road accidents within the critical "Golden Hour"

Overall, the Golden Triangle serves as a powerful reminder of the fundamental principles of equality, freedom, and dignity that underlie the Indian democracy. The Government and the Judiciary of India must continue to uphold and protect these fundamental rights, thereby ensuring that the citizens of India can enjoy their freedom and dignity without any hindrance.

References:

• https://blog.ipleaders.in/golden-triangle-indian-constitution/
• https://lawcorner.in/golden-triangle-of-indian-constitution/
• https://www.lawcolumn.in/the-rule-of-golden-triangle-of-the-indian-constitution-under-article-21/

End-Notes:

1. (1973) 4 SCC 225
2. 1978 AIR 597, 1978 SCR (2) 621
3. AIR 1993 SC 477
4. 160 Delhi Law Times 277
5. (AIR 1950 SC 124)
6. 1978 AIR 597, 1978 SCR (2) 621
7. 1995 AIR 1236, 1995 SCC (2)161
8. 8 SCC_534
9. (2008) 6 SCC
10. 1978 AIR 597
11. 1985 SCC (3) 545
12. 1983 SCR (3) 327
13. (1997) 6 SCC 241
14. (2018) 5 SCC
15. (1989) 4 SCC 286