Which case gave a narrow interpretation to Art. 21 of

Solution

In the case of A. K Gopalan Vs. State of Madras 1950 A.K Gopalan was a communist leader. He was detained in jail under 'Prevention of Detention Act'. He moved with a writ petition under Article 32(1) and challenged his detention for violation of Article 21. The apex court by taking the literal meaning of Art. 21 held that the protection under the Article is only available to a person who is free and not in jail. The court gave importance to Art. 19 rather than Art. 21.