Jun 19,2021 | 10 min read

The Golden Triangle of The Indian Constitution: Articles 14, 19 and 21

The Golden Triangle of The Indian Constitution: Articles 14, 19 and 21


Author : Pooja Dua

Embodied with 449 articles, 12 schedules, 25 parts, 5 appendices and 101 amendments, The Indian Constitution is the longest written constitution in the world with around 146,385 words in its English version. All the branches of the government receive their respective powers from the constitution and are bound by it. The Preamble of The Indian Constitution declares India to be a sovereign, socialist, secular, democratic republic that assures its citizens, justice, equality and liberty, and promote fraternity.

Observed in the case of T.R. Kothandaraman v. T.N. Water Supply & Drainage Board, “The golden triangle of our Constitution is composed of Articles 14, 19 and 21. Incorporation of such articles was made for the purpose of paving such a path for the people of India which may see them close to the gathering of liberty, equality, and fraternity. It could also be said that the trio assists the deprived class and also destroys the exploiters of the depressed class.”

The Golden Triangle of Indian Constitution

Articles 14, 19 and 21

 Article 14

Equality in the eyes of law. Article 14 of the Constitution states that the State shall not deny equality before the law or the equal protection of the laws within the territory of India or prohibition of discrimination on grounds of religion, race, caste, sex or place of birth, to any individual.

Every person within the territory of India is equal in the eyes of law and shall not be discriminated against on the basis of religion, race, caste, sex or place of birth i.e., every person shall be treated likewise in both privileges and liabilities imposed.

Article 19

Protection of certain rights regarding freedom of speech and expression.

All citizens shall have the right-

  • To freedom of speech and expression

  • To assemble peacefully and without arms

  • To form associations or unions

  • To move freely throughout the territory of India

  • To reside and settle in any part of the territory of India, and

  • To practice any profession or to carry on any occupation, trade or business

Article 19 provides a variety of rights such as freedom of speech and expression, right to assemble peacefully, right to form associations, right to move freely, etc. However, this article does not provide an absolute right to people. There are some specific restrictions on freedom of speech and expression which protects the integrity of the country.

Article 21

Protection of life and personal liberty, no person shall be deprived of his life or personal liberty except according to procedure established by law.

Right to life and personal liberty does not mean the mere existence of life but a life with dignity and worth living and also all other attributes of human personality that are essential for the full development of a person. A number of composite and inferred rights have been derived through a liberal interpretation of this article by the Supreme Court of India.

Landmark Cases

Maneka Gandhi v. Union of India

This case is considered to be one of the most important cases of all time. It was held by the supreme court that Article 21 is not to be read alone and all the violations and procedural requirements under Article 21 are to be read along with Article 14 and Article 19 also. The Supreme Court in this case adopted the widest possible interpretation of the right to life and personal liberty, guaranteed under Article 21 of the Constitution.

Parmanand Katara V. Union of India

In this medico-legal case, the Supreme Court of India held ‘Right to Health’ as a Fundamental Right under Article 21. No individual shall be deprived of any medical assistance. Supreme Court held it obligatory to both private and public medical assistance groups/hospitals to provide immediate medical aid to a victim of a road accident. 

People’s Union of Civil Liberties (PUCL) v. Union of India

In this case, the Supreme Court of India distinguished the “right to vote” and the “freedom of voting" as a part of the freedom of expression under Article 19(1)(a) of the Constitution.

Justice K.S.Puttaswamy(Retd) vs Union Of India

In this case, the Right to Privacy was said to be a fundamental right within the meaning of Article 21. The Hon’ble Court upheld the Aadhaar Act and stuck down the provision of the Act which was unconstitutional. It was held by the Court that the Right to Privacy of the citizens has to be protected as an intrinsic part of the right to life and personal liberty under Article 21 and as a part of the freedoms guaranteed by Part III of the Constitution.

Anuradha Bhasin V. Union of India and Ors.

The freedom to practice any profession or any trade, business or occupation over the medium of the internet is protected by Article 19(1)(a) and Article 19(1)(g), but with specified restrictions, held by the Supreme Court. The Internet is an important platform for trade and commerce and plays a significant role in the world of e-commerce business and marketing.


In conclusion, it can be said that these three articles play a very important role in the functioning of our judicial system and are the paramount safeguards against the arbitrary actions of the government, against all the violations and exploitations of human rights and freedom. The incorporation of the trinity is paving such a path for the people of India so the trinity is viewed in the highest regard and structure of liberty, equality and fraternity. These articles are so important to our jurisprudence that their interconnection is rightly known as the "Golden Triangle of The Constitution". This paper gives detailed information about Golden triangle in Indian Constitution. 

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Lawyered Team

Lawyered Team