ADM Jabalpur v. Shivkant Shukla decision
E448911
The ADM Jabalpur v. Shivkant Shukla decision was a controversial 1976 Indian Supreme Court ruling during the Emergency that held citizens had no locus to challenge unlawful detentions when fundamental rights were suspended, later widely criticized and effectively overruled.
All labels observed (1)
| Label | Occurrences |
|---|---|
| ADM Jabalpur v. Shivkant Shukla decision canonical | 1 |
How this entity was disambiguated
This entity first appeared as the object of triple T4514491 — resolving that mention is where its identity was fixed. The disambiguator weighed these candidate entities and picked the highlighted one (or “None”, minting a new entity). This is how homonymy is resolved: the same surface form can point to different entities.
NED1
Entity disambiguation (via context triple)
gpt-5-mini-2025-08-07
Target entity: ADM Jabalpur v. Shivkant Shukla decision Context triple: [Indian Emergency (1975–1977), impactOnJudiciary, ADM Jabalpur v. Shivkant Shukla decision]
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A.
Narmada Water Disputes Tribunal Award
The Narmada Water Disputes Tribunal Award is a landmark legal decision that allocated the waters of the Narmada River among Indian states and set key conditions for projects like the Sardar Sarovar Dam.
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B.
Kesavananda Bharati v. State of Kerala
Kesavananda Bharati v. State of Kerala is a landmark 1973 Supreme Court of India judgment that established the basic structure doctrine, limiting Parliament’s power to amend the Constitution.
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C.
Narmada Bachao Andolan v. Union of India
Narmada Bachao Andolan v. Union of India is a landmark Supreme Court of India case that examined environmental, displacement, and development issues surrounding large dam construction on the Narmada River.
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D.
INS v. Chadha
INS v. Chadha is a landmark 1983 U.S. Supreme Court case that struck down the legislative veto as unconstitutional, significantly reshaping the balance of power between Congress and the executive branch.
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E.
Protection of Human Rights Act, 1993
The Protection of Human Rights Act, 1993 is an Indian law that establishes the framework for protecting and promoting human rights in the country, including the creation and powers of human rights commissions.
- F. None of above. chosen
- G. Unsure - the case is ambiguous/there is not enough information to decide.
NED2
Entity disambiguation (via description)
gpt-5-mini-2025-08-07
Target entity: ADM Jabalpur v. Shivkant Shukla decision Target entity description: The ADM Jabalpur v. Shivkant Shukla decision was a controversial 1976 Indian Supreme Court ruling during the Emergency that held citizens had no locus to challenge unlawful detentions when fundamental rights were suspended, later widely criticized and effectively overruled.
-
A.
Narmada Water Disputes Tribunal Award
The Narmada Water Disputes Tribunal Award is a landmark legal decision that allocated the waters of the Narmada River among Indian states and set key conditions for projects like the Sardar Sarovar Dam.
-
B.
Kesavananda Bharati v. State of Kerala
Kesavananda Bharati v. State of Kerala is a landmark 1973 Supreme Court of India judgment that established the basic structure doctrine, limiting Parliament’s power to amend the Constitution.
-
C.
Narmada Bachao Andolan v. Union of India
Narmada Bachao Andolan v. Union of India is a landmark Supreme Court of India case that examined environmental, displacement, and development issues surrounding large dam construction on the Narmada River.
-
D.
INS v. Chadha
INS v. Chadha is a landmark 1983 U.S. Supreme Court case that struck down the legislative veto as unconstitutional, significantly reshaping the balance of power between Congress and the executive branch.
-
E.
Protection of Human Rights Act, 1993
The Protection of Human Rights Act, 1993 is an Indian law that establishes the framework for protecting and promoting human rights in the country, including the creation and powers of human rights commissions.
- F. None of above. chosen
Statements (47)
| Predicate | Object |
|---|---|
| instanceOf |
Supreme Court of India judgment
ⓘ
constitutional law case ⓘ habeas corpus case ⓘ |
| acknowledgedAsWrongBy | Supreme Court of India in later cases ⓘ |
| acknowledgedAsWrongIn | K. S. Puttaswamy v. Union of India (2017) NERFINISHED ⓘ |
| alsoKnownAs | Habeas Corpus case NERFINISHED ⓘ |
| benchStrength | 5-judge bench ⓘ |
| characterization |
highly controversial judgment
ⓘ
widely criticized as anti-liberty ⓘ |
| citation | ADM Jabalpur v. Shivkant Shukla, (1976) 2 SCC 521 NERFINISHED ⓘ |
| context | preventive detention of political opponents during the Emergency ⓘ |
| country | India ⓘ |
| court | Supreme Court of India NERFINISHED ⓘ |
| dateDecided | 28 April 1976 ⓘ |
| dissentHeldThat | right to life and personal liberty is not solely a gift of the Constitution and cannot be taken away even during Emergency ⓘ |
| dissentingJudge | H. R. Khanna NERFINISHED ⓘ |
| effect | denial of judicial remedy against unlawful detention during Emergency ⓘ |
| heldThat |
detention orders could not be challenged in court during the suspension of fundamental rights
ⓘ
no person had locus to move any writ petition for habeas corpus during the Emergency when Article 21 was suspended ⓘ |
| impact |
influenced later emphasis on judicial review as part of basic structure
ⓘ
triggered debate on basic structure and non-derogable rights ⓘ |
| languageOfJudgment | English ⓘ |
| laterAssessment | considered one of the darkest moments in Indian constitutional jurisprudence ⓘ |
| legalDomain |
constitutional rights jurisprudence
ⓘ
public law ⓘ |
| legalIssue |
maintainability of habeas corpus petitions during Emergency
ⓘ
scope of Article 21 of the Constitution of India ⓘ suspension of fundamental rights ⓘ |
| legalProvisionInvolved |
Article 21 of the Constitution of India
NERFINISHED
ⓘ
Article 359 of the Constitution of India NERFINISHED ⓘ Presidential Order under Article 359(1) ⓘ |
| majorityJudges |
A. N. Ray
NERFINISHED
ⓘ
M. H. Beg NERFINISHED ⓘ P. N. Bhagwati NERFINISHED ⓘ Y. V. Chandrachud NERFINISHED ⓘ |
| overruledBy | K. S. Puttaswamy v. Union of India (2017) NERFINISHED ⓘ |
| period | Indian Emergency (1975–1977) NERFINISHED ⓘ |
| petitioner | Shivkant Shukla NERFINISHED ⓘ |
| politicalContext |
Indira Gandhi government
NERFINISHED
ⓘ
suspension of civil liberties ⓘ |
| ratio | suspension of the right to move any court for enforcement of Article 21 meant no remedy for illegal detention ⓘ |
| respondent | Additional District Magistrate, Jabalpur NERFINISHED ⓘ |
| status | effectively overruled ⓘ |
| subjectMatter |
Emergency powers
ⓘ
habeas corpus ⓘ personal liberty ⓘ |
| yearDecided | 1976 ⓘ |
How these facts were elicited
The pipeline generated the facts above by prompting gpt-5.1 with this entity's name + description and the instruction below.
Instruction
You are a knowledge base construction expert. Given a subject entity and a description of it, return factual statements that you know for the subject as a JSON list of dictionaries(triples), where keys must be "subject", "predicate" and "object". The number of facts may be very high, between 25 to 50 or more, for very popular subjects. For less popular subjects, the number of facts can be very low, like 5 or 10. # Requirements - If you don't know the subject at all, return an empty list. - If the subject is not a named entity, return an empty list. - Include at least one triple where predicate is "instanceOf". - Do not get too wordy. - Separate several objects into multiple triples with one object.
Input
Subject: ADM Jabalpur v. Shivkant Shukla decision Description of subject: The ADM Jabalpur v. Shivkant Shukla decision was a controversial 1976 Indian Supreme Court ruling during the Emergency that held citizens had no locus to challenge unlawful detentions when fundamental rights were suspended, later widely criticized and effectively overruled.
Referenced by (1)
Full triples — surface form annotated when it differs from this entity's canonical label.