Justice HR Khanna, the lone sentinel of liberty during Emergency
In the landmark Additional District Magistrate (ADM), Jabalpur vs Shivkant Shukla case of 1976, the Supreme Court delivered a judgment that remains a black mark on India’s constitutional history.
Updated At : 06:36 AM Jun 28, 2025 IST
Justice HR Khanna’s stance underscores that the right to question authority lies at the heart of a constitutional democracy.
On June 25, 1975, democracy in India entered a dark tunnel. Indira Gandhi’s government declared a state of Emergency, suspending fundamental rights, detaining political opponents and gagging the press. Among the many institutional capitulations during this period, perhaps the most devastating came from the judiciary itself. In the landmark Additional District Magistrate (ADM), Jabalpur vs Shivkant Shukla case of 1976, the Supreme Court delivered a judgment that remains a black mark on India’s constitutional history. Yet, even in that moment of collective judicial failure, one judge chose courage over compliance — Justice Hans Raj Khanna.
