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Comparative Study of Judicial Review in India , USA
and U.K:
Name – NIKHIL GANGAPPA MANTUR
Profession – Assistant Professor
Institution – BLDE LAW COLLEGE, JAMKHANDI
"It is emphatically the province and duty of the judicial department to say what the law is. Those who apply the
rule to particular cases, must of necessity expound and interpret that rule. If two laws conflict with each other, the
courts must decide on the operation of each." Chief Justice John Marshall
ABSTRACT:
In India, the essence of judicial review is the supremacy of law. It is the power of the court to review the actions of
legislative, executive and judiciary. It is the great weapon in the hands of the court to hold unconstitutional and
unenforceable any law and order which is in conflict with the basic law of the land. This paper will deal with the
various doctrines formulated by the Apex Court on the basis of judicial review, for e.g., Doctrine of Severability,
Doctrine of Eclipse, Doctrine of Prospective Over-ruling etc. The paper will also focus on Judicial Review of
Constitutional Amendments, Judicial Review of Legislative Actions and Judicial Review of Administrative
Actions. The paper will further look into the stand of judicial review in USA and UK. Judicial review had mainly
originated in USA from the notable landmark case of Marbury vs. Madison. But originally Lord Coke’s decision
in, Dr. Bonham vs. Cambridge University had rooted the scope of judicial review first time in 1610 in England.
This paper will discuss as to how the U.S. Constitution does not provide power of judicial review expressly but
Articles III and VI of the U.S. Constitution touch down this concept. There being no written Constitution in UK,
the paper will also deal with the principle of “Parliamentary Sovereignty” which dominated the Constitutional
democracy. Parliament Supremacy in UK incorporates the will of the people and the Courts cannot scrutinize the
actions of Parliament. Parliament prevents the scope of judicial review to primary legislation except in few cases
related to human rights and individual freedom. But secondary legislations are subject to judicial review. Court
can review the administrative and executive actions in UK. Through this paper the author has made an attempt to
present a comparative analysis of judicial review in India, U.S.A and U.K1.
Key words: Judicial review, Constitution, Parliament, Human Right, Sovereignty, Amendments
INTRODUCTION:
Supremacy of law is essence of Judicial Review. It is power of the court to review the actions of legislative and
executive and also review the actions of judiciary, it is the power to scrutinize the validity of law or any action
whether it is valid or not. It is a concept of Rule of Law. Judicial Review is the check and balance mechanism to
maintain the separation of powers. Separation of power has rooted the scope of Judicial Review. It is the great
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weapon in the hands of the court to hold unconstitutional and unenforceable any law and order which is
inconsistent or in conflict with the basic law of the land.. The two principal basis of judicial review are “Theory of
Limited Government” and “Supremacy of constitution with the requirement that ordinary law must confirm to the
Constitutional law.”Judicial Review is a mechanism and therefore the Concept of Judicial Activism is a part of this
mechanism. So far as the, Indian constitution has created an independent judiciary which is vested with the power
of judicial review to determine the legality of any validity of law and any executive action. Supreme Court of India
formulated various doctrines on the basis of Judicial Review like “Doctrine of Severability, Doctrine of Eclipse,
and Doctrine of Prospective Overruling” etc. In India Judicial Review based on three important dimensions, these
are” Judicial Review of Constitutional Amendments”, Judicial Review of Legislative Actions, “Judicial Review of
Administrative Actions”. To determine the unconstitutionality of legislative Acts is the fundamental objects of
judicial review. It adjusts constitution to the new condition and needs of the time. To uphold the supremacy of
constitutional law and to protect the fundamental rights of the citizens and also to maintain federal equilibrium
between Centre and the States are the main concerns of objectives of judicial review in India. Legislative and
administrative powers between Centre and the State of constitution are also the main concern of judicial review. It
is the duty of the judiciary the constitution to keep different organs of the state within the limits power conferred
upon them by the constitution. The legitimacy of judicial review is based in the Rule of Law, and the need for
public bodies to act according to law. Judicial review is a means to hold those who exercise public power
accountable for the manner of its exercise, especially when decisions lie outside the effective control of the
political process. Judicial Review is a great weapon through which arbitrary, unjust harassing and unconstitutional
laws are checked. The concept of Judicial Review is basically originated in USA in the historic landmark case
Marbury vs. Madison. But originally Lord Coke decision in, Dr. Bonham vs. Cambridge University 1 had rooted
the scope of judicial review first time in 1610 in England. The US Constitution doesn’t provide power of judicial
review expressly but Article III of the U.S. Constitution as "the judicial power of the United States which includes
original, appellate jurisdiction and also matter arising under law and equity jurisdiction incorporates judicial power
of Court. Art. VI of the Constitution provides” All powers of government are exercisable only by on the authority
of the organ established by the Constitution. Thus Art VI incorporates “Constitution of USA is the supreme law of
the land”. Judicial review is not expressly provided in the US Constitution, but it is the formulation by the Court.
Supreme Court of US has power to check the action of Congress and State Legislatures from delegating the
essential legislative function to the executive. The principle “due process of law” creates a democratic balance in
US by declaring the arbitrary and illegal laws. But in UK, there is no written constitution. Earlier, there was no
scope of judicial review in UK. The principle of “Parliamentary Sovereignty” dominated to Constitutional
democracy in United Kingdom. There is Parliament Supremacy UK which incorporates the will of the people and
Courts cannot scrutinize the actions of Parliament. In UK, Parliament prevents the scope of Judicial Review to
Primary legislation (legislation enacted by Parliament) except in few cases related to Human Rights and individual
freedom, therefore Primary legislation is outside the purview of judicial review. But, as regards to Secondary
legislation (rules, regulation, act of Ministries) are subject to Judicial Review. Court can review the actions of
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administrative and executive actions in UK. Judicial Review in UK is basically on procedural grounds which are
largely related to Administrative actions.2
COUNTRIES FOLLOWING JUDICIAL REVIEW DOCTRINE:
UNITED KINGDOM:
Origin of Judicial Review in the United Kingdom Origin of the Judicial review in the United Kingdom can be
traced from 17th century. In 1610,Dr. Bonham vs. Cambridge University3 case was decided by Lord Coke laid
the foundation of judicial review in England. But in the case of City of London v. Wood4 Chief Justice Holt
remarked that “An Act of Parliament can do no wrong, though it may do several things that look pretty odd.” This
remark Chief Justice Holt establishes the ‘Doctrine of Parliamentary Sovereignty’ which means that the court has
no power to determine the legality of Parliamentary enactments. About a century later, in a Scottish case Andrew
v Murdoch5, Lord Hermand stated in the Court of Session that "there is a power paramount to acts of Parliament,
and that is the power of right reason, to which Kings and Parliaments themselves must be subject". This may
indicate a freer attitude towards parliamentary supremacy on the part of Scottish lawyers, but it is worth noting
that these and other dicta of Lord Hermand were subsequently disapproved by Lord Holland in the House of
Lords. The last case in this line is Forbes v Cochrane6, in which Best J stated that he would refuse to recognise a
statute legitimising slavery, since it would be "against the law of nature and God". Earlier, there was no scope of
judicial review in United Kingdom., but after the formation of European Convention of Human Rights, the scope
of judicial review became wider. The enactment of Human Rights Act, 1998 also requires domestic Courts to
protect the rights of individuals. In United Kingdom, there is no written Constitution and Parliamentary
Supremacy is the foundation. Principle of “Parliamentary Sovereignty” dominates the constitutional democracy in
United Kingdom. In England, there was judicial review of administrative action but the courts do not have the
power to review the acts of Parliament, since Parliament is supreme. In England, for a long time there has been
resistance against a written bill of rights because the English people are brought up on the faith that the liberty of
the subject is sacrosanct and the courts will allow its infraction only if it is supported by a provision of law. The
following celebrated quote form Lord Atkin amply demonstrates such faith. The learned judge said: In accordance
with British jurisprudence no member of the executive can interfere with the liberty or property of a British subject
except on the condition that he can support the legality of his action before a court of justice. Over the years, even
in England, parliamentary sovereignty has been considerably eroded in practice as well as in law. England has
joined the European Convention on Human Rights and has accepted the jurisdiction of the European Court on
Human Rights. Further, the house of Lords in England has held that a European Community law would prevail
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3
(1610) 8 Co. Rep.114
4
(1701) 12 Mod. Rep.669
5
(1806) Buch Rep 1
6
(1824) 2 B & C 448
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over an Act of British Parliament. This has been provided by the European Communities Act, 1972 but the above
decision of the House of Lords whereby an earlier statute of Parliament was held to prevail over a later statute was
clearly a constitutional revolution and meant the virtual demise of the Dicey’s theory of parliamentary sovereignty.
The United Kingdom has after a long hesitation enacted the human Rights Act, 1998, which contains a declaration
of rights. These rights act as limitations upon the executive and though theoretically they do not limit the power of
the British Parliament, they would indirectly do so because the courts would presume that the act of Parliament
could not be contrary to the rights given by that Act. These developments have doubtless changed the nature of the
judicial review in the United Kingdom.
Parliamentary Sovereignty in United Kingdom:
In England, people are the source of all the powers and they are also the sovereign power. But, the people
snatching all essential powers from the Monarch respond to them in Parliament. Due to this, Parliament can
legislate any matter and Constitution assigns no limitations to enact any legislation. The Act of the Parliament
cannot be answerable to any authority whether it is unjust or contrary, no matter how it is. There is unlimited
power of Parliament in United Kingdom. There is no scope of judicial review of legislative Act in United
Kingdom. The legislative Act of Parliament is also known as Primary Legislation and the delegation by the
Parliament to the executive with adequate legislative guidance are known as Secondary legislation, secondary
legislation are administrative in nature, therefore it is subject to judicial review in United Kingdom . In England,
before the doctrine of Parliamentary Sovereignty came into eminence, legislative acts were subject to judicial
control, though with a very little practical effect; but even after the emergence of the doctrine of parliamentary
sovereignty, judicial review is permissible regarding violation of the rules of delegated legislation and also in the
field of subordinate legislation.
Present Position of Judicial Review in United Kingdom:
The Courts in United Kingdom, in present scenario, strictly follow the principles of judicial review with regard to
administrative actions and secondary legislations. So far as primary legislations, they are outside the purview of
judicial review but with some exceptional cases. Judicial review of administrative actions which are executive in
nature are mostly subject matter of judicial review in United Kingdom. In, R. (on the application of Drammeh) v
Secretary of State for the Home Department7, where an immigration detainee who had failed to take his
medication for schizo-affective disorder and had gone on hunger strike, but who did not lack mental capacity,
failed to establish that his detention was unlawful by virtue of his pre-existing serious mental illness where the
facts indicated that his actions were calculated to avoid deportation. The claimant applied for judicial review of the
lawfulness of his immigration detention. The Court in these case held that, there was no doubt that the effect of
detention on a detainee's mental health was a very relevant factor in evaluating what constituted a "reasonable
period" of detention. The secretary of state's policy in Chapter 55.10 of the Enforcement Instructions and
Guidance in relation to the detention of the mentally ill imposed a duty to inquire into the relevant circumstances
of a detainee to assess whether serious mental illness existed and whether it could be satisfactorily managed in
7
[2015] EWHC 2
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detention. Further held that, where a detainee had capacity, his refusal to consent to medical treatment put him
outside the scope of the secretary of state’s policy statements.
UNITED STATES OF AMERICA:
The Constitution of U.S.A. didn’t expressly vest this function of guardianship in the judiciary. But the common
law doctrine of ultra vires, according to which courts had the power and duty to invalidate the act of an inferior
body which transgressed the mandate of a superior authority which is binding on the inferior or subordinate body.
One of the fundamental process in the U.S. to determine the validity of law is Judicial Review. The power of
judicial review to declare the laws unconstitutional and to scrutinise the validity of law implicitly incorporated in
the Art.III and IV of the Constitution of United States of America. As early as 1803, Marbury’s Case, Marshall
C.J., placed the doctrine upon a sure footing by saying that since the Judges, as directed by the Constitution itself,
took oath to support the Constitution, which constitutes the paramount law of the nation, it was the duty of the
Judges to annul any law made by the Legislature which violated the Constitution or was repugnant to it.
According to the Bernard Schwartz8, “The decision on the question of constitutionality of a legislative act is the
essence of the judicial power under the Constitution of America”.
In Minersville School Dt. v. Gobitis9, Felix Frankfurter J. observed, “Judicial Review as limitation on popular
government and is a part of constitutional scheme of America.” In Cooper v. Aaron10, the federal basis of judicial
review was emphasised by the Court that Article VI of the Constitution makes the Constitution the ‘supreme Law
of the Land’. In Baker v. Carr11, Brennan J. for the majority said, “Deciding whether a matter has in any measure
been committed by the Constitution to another branch of Government, or whether the action of that branch
exceeds whatever authority has been committed, is itself a delicate exercise of constitutional interpretation, and is
a responsibility of this court as ultimate interpreter of the Constitution.”
Current position of Judicial Review in U.S.A.:
After Marbury’s case the expansion of judicial review in U.S.A. is very broad in nature, its widened the scope of
judicial review in U.S.A. in present scenario. The Supreme Court in the recent case of Reed v. Town of Gilbert,
Arizona12, in this case an ordinance was passed concerned with Gilbert town which prohibits the display of
outdoor sign except some signs which are political signs which defined as designed to influence the outcome of an
election, and ideological signs which defined as communicating ideas and another one directional signs which
defined as directing the public to church or other qualifying event. This ordinance was challenged by a church and
its priest. Clarence Thomas J., on behalf of the majority held that distinctions drawn by the ordinance were
impermissible. It was held that all “content based law” requires the exacting form of judicial review and strict
8
Bernard Schwartz, The Powers of Government (2nd, The Macmillan Company, New York 1963) p.19.
9
(1940) 310 US 586 (600)
10
(1958) 358 US 5 (16-17).
11
(1962) 369 US 186 (211).
12
US Reports Slip Opinion Volume 13-502 (2014)
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scrutiny. Court further held that content based law which are target speech based on its communicative content are
presume to be unconstitutional and may be justified only if the Government proves that they are narrowly tailored
to serve compelling State interests.
INDIA:
Judicial review is recognized as a necessary and a basic requirement for construction up of a novel civilization in
order to safeguard the liberty and rights of the individuals. The power of judicial review is significantly vested
upon the High Courts and the Supreme Court of India. Under Article 13 of the Indian Constitution, the compulsion
of judicial review was described in fundamental rights in Part III. It is stated that the State or the Union shall not
make such rules that takes away or abridges the essential rights of the people. If any law made by the Parliament
or the State Legislature contravenes the provisions of this Article, shall be void13.
Meaning of Judicial Review in India:
Judicial Review can be understood as a form of court proceeding, usually in the Administrative Court where the
lawfulness of a decision or action is reviewed by the judge. Where there is no effective means of challenge,
judicial review is available. The concern behind Judicial Review is that whether the law has been correctly applied
with and right procedures have been followed.
Judicial Review as a part of the Basic Structure:
In the celebrated case of Keshavanda Bharathi v. State of Kerela, the Supreme Court of India the propounded
the basic structure doctrine according to which it said the legislature can amend the Constitution, but it should not
change the basic structure of the Constitution, The Judges made no attempt to define the basic structure of the
Constitution in clear terms. S.M. Sikri, C.J mentioned five basic features:
1. Supremacy of the Constitution.
2. Republican and democratic form of Government.
3. Secular character of the Constitution.
4. Separation of powers between the legislature, the executive and the judiciary.
5. Federal character of the Constitution.
He observed that these basic features are easily discernible not only from the Preamble but also from the whole
scheme of the Constitution. He added that the structure was built on the basic foundation of dignity and freedom of
the individual which could not by any form of amendment be destroyed. It was also observed in that case that the
above are only illustrative and not exhaustive of all the limitations on the power of amendment of the Constitution.
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The Constitutional bench in Indira Nehru Gandhi v. Raj Narain14 , held that Judicial Review in election
disputes was not a compulsion as it is not a part of basic structure. In S.P. Sampath Kumar v. Union of India15,
P.N. Bhagwati, C.J., relying on Minerva Mills Ltd. case16 declared that it was well settled that judicial review
was a basic and essential feature of the Constitution. If the power of judicial review was absolutely taken away,
the Constitution would cease to be what it was. In Sampath Kumar the Court further declared that if a law made
under Article 323-A(1) were to exclude the jurisdiction of the High Court under Articles 226 and 227 without
setting up an effective alternative institutional mechanism or arrangement for judicial review, it would be violative
of the basic structure and hence outside the constituent power of Parliament.
In Kihoto Hollohan v. Zachillhur17 another Constitution Bench, while examining the validity of para 7 of the
Tenth Schedule to the Constitution which excluded judicial review of the decision of the Speaker/Chairman on the
question of disqualification of MLAs and MPs, observed that it was unnecessary to pronounce on the contention
whether judicial review is a basic feature of the Constitution and para 7 of the Tenth Schedule violated such basic
structure. Subsequently, in L. Chandra Kumar v. Union of India18 a larger Bench of seven Judges unequivocally
declared: "that the power of judicial review over legislative action vested in the High Court’s under Article 226
and in the Supreme Court under Article 32 of the Constitution is an integral and essential feature of the
Constitution, constituting part of its basic structure". Though one does not deny that power to review is very
important, at the same time one cannot also give an absolute power to review and by recognizing judicial review
as a part of basic feature of the constitution Courts in India have given a different meaning to the theory of Checks
and Balances this also meant that it has buried the concept of separation of powers, where the judiciary will give
itself an unfettered jurisdiction to review anything everything that is done by the legislature.
Judicial review has evolved in three dimensions:
To protect the legality of essential rights under Part III of the Indian Constitution.
To authorize the disinterest of organizational achievement.
Interrogation of public interest.
Article 13 of the Indian Constitution:
Laws inconsistent with or in derogation of the fundamental rights: (1) All laws in force in the territory of India
immediately before the commencement of this Constitution, in so far as they are inconsistent with the provisions
of this Part, shall, to the extent of such inconsistency, be void
(2) The State shall not make any law which takes away or abridges the rights conferred by this Part and any law
made in contravention of this clause shall, to the extent of the contravention, be void
14
1975 Supp SCC 1
15
(1987) 1 SCC 124 at 128
16
(1980) 3 SCC 625.
17
1992 Supp (2) SCC 651, 715, para 120
18
(1997) 3 SCC 261)
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(3) In this article, unless the context otherwise requires law includes any Ordinance, order, bye law, rule,
regulation, notification, custom or usages having in the territory of India the force of law; laws in force includes
laws passed or made by Legislature or other competent authority in the territory of India before the
commencement of this Constitution and not previously repealed, notwithstanding that any such law or any part
thereof may not be then in operation either at all or in particular areas
(4) Nothing in this article shall apply to any amendment of this Constitution made under Article 368 Right of
Equality.
Judicial Review In India:
Judicial review plays an important role as a protector when the executive, judiciary and legislature harm the
Constitutional values and deny the rights. The judicial assessment is considered as an indispensable feature in the
country. In India, there is parliamentary form of democracy where every section of people is involved in decision
making and policy making process. It is true that the primary duty of the court to apply rule of law and is the
groundwork of social equality. By exercising new powers of Parliament, rule of law which is to be applied by the
court cannot be modified. All those here, who are doing public duty, are accountable. They have to work within
the democratic provisions of the Constitution of India. The concept of separation of power and rule of law is
judicial review. The influence of judicial assessment has been so long under Articles 226 and 227 in case of High
Court and Articles 32 and 136 of the Constitution of India for the review.
Mechanisms of Judicial Review:
In India, three aspects are covered by judicial review that are as follows:
Judicial review of legislative action
Judicial review for judicial decision
Judicial review of administrative action
These facets of judicial review were pronounced by the Supreme Court of India in case L. Chandra Kumar v.
Union of India19, stating that the judges of higher court have to interpret legislation up to this end that the
Constitutional values are not to be interrupted. To achieve this end, the judges have to keep in mind that the
equilibrium of control, specified in the Constitution is not disturbed.
Judicial Pronouncements:
Shankari Prasad v. Union of India20:
It was held by six judge bench, five judges not agreed to amending the essential rights under the Indian
Constitution. However, in case of Keshavanand Bharti v. state of Kerala where six judges out of seven judges held
19
Appeal (civil) 481 of 1980
20
AIR 1951 SC 458
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that Parliament modifying influence has and at all portion of the Constitution can be amended and over ruled the
Golaknath case. The Supreme Court held that the essential rights cannot be modified in such a method, which will
touch the elementary construction of the Constitution.
Mitthu v. State of Punjab21:
The Supreme Court of India has struck down Section 303 of Indian Penal Code, 1860. This section had made
death sentence mandatory. In case Article twenty-one of the Indian Constitution was illustrated by the S.C.I.
complete its frequent pronouncement.
P.U.C.L v. U. O. I22:
The Indian Supreme Court, in its historical verdict stated that to disregard or disobey the decision given by the
court, the lawmakers of India have no power to ask for the instrumentality, if the legislature has influence over the
subject matter.
CONCLUSION:
To conclude this, let me say that the Judicial Review makes the Constitution legalistic. Doctrine of Judicial
Review is very dynamic concept in a present scenario. In various countries Judiciary is acting as a guardian of the
constitution by help of the doctrine of Judicial Review. It enables the Court to maintain harmony in the State.
Judicial Review is of great importance in a republic, not only to guard the society against the oppression of its
rulers; but to guard one part of the society against the injustice of the other part. To perform this task,
Constitutional Courts have been regarded as the most appropriate branch of government, and thus they currently
possess legal monopoly to declare what the constitution must be. Despite the undeniable differences, in India,
U.S.A., U.K. and some other countries, courts have been playing a very important role in the preservation of
individual liberties. The need for an effective check on legislative majorities, thus seems to be the main force
compelling different legal systems to confer upon their courts-constitutional or not the power to review legislation
repugnant to the constitution23.
21
AIR 1983 SC 473.
22
AIR 1997 SC 568.
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