“Role Of Justice Krishna Iyer in Balancing the Fundamental Rights & Directive Principles of State Policy”: Full Text Of The Lecture by CJI BR Gavai

11th Justice V.R. Krishna Iyer Memorial Law Lecture

“Role Of Justice V R Krishna Iyer in Balancing the Fundamental Rights & Directive Principles of State Policy”

Justice B.R. Gavai, Chief Justice of India

1. Justice Nitin Jamdar, Chief Justice of the High Court of Kerala, and my dear friend;

Justice Devan Ramachandran, Judge, High Court of Kerala;

Justice K. Balakrishnan Nair, President, Sarada Krishna Satgamaya Foundation For Law and Justice, Kochi;

Other esteemed Judges of the High Court of Kerala; Justice Joseph, former Judge of the Supreme Court;

Former Chief Justice of Kerala High Court, Justice Manikumar; Ld. Advocate General for the State of Kerala;

Ld. Chief Secretary;

President of the Bar Association;

Esteemed members of the Bar and Bench, distinguished guests, dear students who are sitting on the balcony, and friends,

2. About a year back, there was a strong likelihood that I would, on the 14th of May 2025, adorn the highest judicial office. A young boy from Kerala, who has been assisting us in so many public interest litigations, one day said to me: Sir, after you adorn the office of the Chief Justice of India, you will have to come to Kochi to deliver a lecture in the memory of Justice Krishna Iyer. It was a boon in disguise for me to get an opportunity to speak in honour of the person to whom I have worshipped, and therefore, when Parameshwar gave me an offer, I had no option but to accept it.

3. And then after I assumed the office, I myself rang Parameshwar that we had decided that I will speak in memory of Justice Krishna Iyer at Kochi, and then he got in touch with Justice Devan Ramachandran. Justice Ramachandran rang me, and that's how I am here to pay my tribute to the person whose journey has inspired many of us, including me.

4. It is both a privilege and a solemn honour to stand before you today for the 11th Justice V.R. Krishna Iyer Memorial Law Lecture, an occasion that is not merely a remembrance but a celebration of one of India's most transformative judicial minds.

5. When we think of Justice Krishna Iyer, we remember him not just as a judge, but as one of the few jurists who revolutionized the jurisprudence of the country.

6. As a young student of law in 1981, I had the distinct privilege of meeting Justice Krishna Iyer in Nagpur. My father was then the chairman of Dr Babasaheb Ambedkar Smarak Samiti at Nagpur. He had invited Justice Krishna Iyer to speak at Deeksha Bhoomi, where Dr Ambedkar had embraced Buddhism along with millions of his followers, on the silver jubilee of Dr. Ambedkar embracing Buddhism. It was really an opportunity for me, which I will never forget in my life.

7. Justice Krishna Iyer, known for his remarkable jurisprudence and unwavering commitment to the marginalized, was deeply connected to the cause of the people. His presence at such a symbolic event exemplified his lifelong dedication to the values of social justice, human rights, and the empowerment of the marginalized. It was evident that his legal philosophy was not confined to the courtrooms; it was a living, breathing force that resonated with the struggles of the common man.

8. As a lawyer, I was profoundly influenced by the jurisprudence of Justice Krishna Iyer. His approach to law, characterized by a deep sense of compassion and a commitment to social justice, had a significant impact on my legal career. I often referred to his judgments during my practice in support of my arguments.

9. I took oath as a judge on 14 November 2003, which Justice Devan Ramachandran had just shared, incidentally a date [14 November 1980] on which Justice Krishna Iyer demitted his office as a Supreme Court Judge. I relied on Justice Krishna Iyer's judicial philosophy in many cases, and I am still doing that. I will not refer to many of my judgments, because today I am here to speak about Justice Krishna Iyer's contribution in balancing the Directive Principles of State Policy with Fundamental Rights. As a Judge of the Bombay High Court in 2017,1 I had the occasion to preside over a significant batch of matters involving the rights of street vendors under the Street Vendors (Protection of Livelihood and Regulation of Street Vending) Act, 2014. The petitioners, including hawkers' associations and individual street vendors, challenged certain actions of the Municipal Corporation of Greater Mumbai and the State Government.

10. The core grievance of the petitioners before us was that Town Vending Committees, which were bodies envisaged as central to the Act's framework, were either not constituted or were functioning without the mandatory representation of street vendors. Petitioners had challenged the legitimacy of schemes and actions undertaken by municipal authorities in the absence of properly formed Town Vending Committees.

11. In our judgment, we held that the 2014 Act was enacted with a clear intention to protect the livelihood rights of street vendors—a recognition flowing from Article 21 of our Constitution. We emphasized that the law could not be selectively implemented. The constitution of proper Town Vending Committees, with at least 40% representation from vendors themselves, was not a formality but a statutory mandate.

12. We also clarified that while the rights of vendors are constitutionally recognized, they are not absolute. The interests of pedestrians, vehicular traffic, and general public safety must also be balanced.

13. In doing so, I strongly relied upon Justice Krishna Iyer's judgments. Let me quote from the judgment, “Justice Krishna Iyer observed that codified law is legislatively crystallised politico-economics. It has been further emphasized that, therefore an attempt has to be made to widen and deepen the search and interlaced. His Lordship further observes that no doubt that where legislation is found to be colourable and mala fide, judges can very well declare the law to be unconstitutional. However, his Lordship further gives a word of caution that the Court must be circumspect not to rush in where serious reflection will make them fear to tread nor to resort to adroit circumvention because of economic allergy to a particular legislative policy.” (end quote)

14. As a Judge of the Supreme Court, in the last year, I have referred to his several decisions. Recently, in the last year, in the Constitution bench of 7 judges in the case of State of Punjab v. Davindar Singh (2024), the Supreme Court permitted sub-classification of Scheduled Castes for the purpose of reservation. In this judgment, I referred to Justice Krishna Iyer's words in State of Kerala v. NM Thomas (1976), where he had stated, and I quote: “[E]very step needed to achieve in action actual, equal, partnership for the [Scheduled Caste], alone amounts to social justice. He observed that if this is not done, the solemn undertakings in Articles 14 to 16 read with Articles 46 and 335 may be reduced to a 'teasing illusion or promise of unreality'… He observed that the law must come to terms with life and must be able to recognize the genuine differences and disparities that exist in human nature” (end quote). I will mention the relevance of NM Thomas judgment after a few minutes.

15. Justice Krishna Iyer was a philosopher on the Bench, a poet in jurisprudence, and a visionary in public life. His judgments were more than legal pronouncements. They were moral compasses infused with compassion, equity, and deep constitutional insight. He saw the Constitution not as a static legal document, but as a dynamic instrument of social transformation. In doing so, he brought a unique blend of legal expertise, social awareness, and moral commitment to his rulings, making him a key figure in the evolution of Indian legal thought.

16. Overall, his influence is not only recorded in law reports but resonates in the heartbeat of our constitutional democracy, especially through his unwavering effort to achieve a harmonious balance between Fundamental Rights and the Directive Principles of State Policy. Today, we delve into how Justice Iyer, with his unique vision and judicial prowess, navigated and, indeed, shaped this crucial balance. In today's lecture, I will also reflect on his personal qualities.

17. Justice Iyer's life trajectory, moving from activist lawyer to minister, and then a judge, provides a unique lens through which to understand his judicial philosophy. Justice Krishna Iyer stood up for the poor and the underprivileged, and remained a human rights champion, a crusader for social justice and the environment, and a doyen of civil liberties, throughout his life.2

18. In 1967, it was that Justice M S Menon, Kerala's Chief Justice, asked Justice Iyer whether he would join the bench. A reluctant Justice Iyer agreed to be—in his words— “robejacked”.3

19. In an autobiographical account written in 2001, Justice Iyer reflected on the memorable events of his life as a judge. He wrote in his book that he asked himself, “What were my guiding goals I tried to practise on and off the bench?” He listed certain lessons. Justice Devan Ramachandran has already referred to them.

20. The first lesson, fundamental to life and law, which he learnt on the bench, was humility without hubris and humanist hearing without “high bench” pride. The second value, which touched his judicial heart, was the compassionate treasury of the Preamble to the Constitution, particularly its five opening words, “We, the People of India”, as the democratic imperative which bound him. The third imperative was to hear either side fairly since courage and independence obligated him “to give (even) the devil his due”, whether he be in the right or in the wrong. Among the last things he learnt was that “perfect justice is a mirage”. As he wrote, “In the pursuit of the illusion of perfect justice, we jeopardise the justice that is within our grasp.” 4

21. Being appointed as a Judge of the Supreme Court of India in 1973, Justice Iyer played an important role in an era of judicial activism, public interest litigation, affirmative action, and a wide-ranging exercise of judicial review. He earned fame and recognition for his fair judgments, for his way of penning down the verdicts, and for his mastery over the English language. He was a thinker ahead of his time and wrote many landmark judgments.5

22. As we now reflect on the theme of the lecture, let me quote Granville Austin, who calls Parts III and IV “the conscience of the Constitution”.6 At the time when the Directive Principles were drafted into the Constitution, opinions on them varied from “a variable dustbin of sentiment”7 to “the instrument of instructions.”8 Views were expressed in the Constituent Assembly that the Directive Principles are no more than mere “pious hopes”, “pious expressions” and “pious superfluities”, that they can be equated to “resolutions made on New Year's day which are broken at the end of January”, that they are “vague” and “a drift”, that they are “a cheque on a bank payable when able”.9

23. Defending the inclusion of Directive Principles, Dr. B.R. Ambedkar observed that in enacting Part IV, the Constituent Assembly was giving certain guiding mandate to the future legislature and future executive to show in what manner they are to exercise legislative and executive powers they will have, that these principles should be made the basis of all executive and legislative action that they may be taking thereafter in the matter of the governance of the country.10

24. In the initial days, from 1950 to 1973, the various judicial pronouncements would show that the Supreme Court had held that wherever there was a conflict between the Directive Principles and Fundamental Rights, the Directive Principles will have to give way to Fundamental Rights, that the Fundamental Rights are superior and the Directive Principles are inferior to them.

25. For the first time, this conflict was resolved by a 13-judge bench in Kesavananda Bharati (1973). Though, this judgment is widely known for the doctrine of basic structure, the amending power of the Constitution, wherein six judges held that the powers of the Constitution to amend the Constitution are limited, and the six judges, on the other hand, held that they were unlimited. It was the view by Justice HR Khanna wherein he held that though the Parliament has ample power to amend the Constitution, including taking away the Fundamental Rights, it does not have the power to amend the basic structure.

26. But I think that Kesavananda Bharati also needs to be remembered for giving equal importance to Fundamental Rights and Directive Principles, and for resolving the conflict between them. All of the judges were on the same page, where they held that Fundamental Rights and Directive Principles together, and together alone, are the conscience of the Constitution. They run parallel and they intersect at certain points.

27. I also taking pride in saying that one of the authors of that judgment, another illustrious jurist from this State, while underpinning the importance of Directive Principles, held that even the judges are a State within the meaning of Article 12, and while discharging their judges, they are bound to follow the directive principles.

28. Justice Krishna Iyer, with his distinctive blend of legal knowledge and social empathy, built on this balance. He understood that the Framers of our Constitution envisioned a nation where individual liberties would thrive, yet not at the cost of collective welfare and social justice. He championed the idea that Fundamental Rights and Directive Principles are not antagonistic but symbiotic, two sides of the same constitutional coin, both essential for the realization of the Preamble's promise of social, economic, and political justice.

29. Justice Iyer's compassionate view on the connection between the right to life and socio-economic rights first became visible in his engagement with the abolition of capital punishment. As a young lawyer, he had watched as an innocent man was nearly hanged for a crime he did not commit. Subsequent cases convinced him that the death penalty was barbarous and uncivilised.11 Not many on the bench shared this position. The Court had only just upheld capital punishment in Jagmohan Singh v. State of U.P. (1973).12 But undeterred as he was, in Ediga Anamma v. State of Andhra Pradesh (1974),13 he outlined the positive indicators against the death sentence under Indian law and commuted the death sentence of a convict to life imprisonment. This decision has been followed in several other cases. In Rajendra Prasad v. State of Uttar Pradesh (1979),14 he restricted the scope of the death sentence under S. 302 IPC. Even outside the Court, he advocated for the abolition of the death sentence.15

30. In State of Kerala v. NM Thomas (1975)16, Justice Krishna Iyer joined the court in changing the jurisprudence on affirmative action. Prior to NM Thomas, the view of the Supreme Court in earlier judgments was that clause 4 of Article 16 was by way of an exception to main clause 1 of Article 16. It was treated as an exception to the equality clause under Article

16(1). However, by a majority, the 7-judge bench in NM Thomas held that Article 16(4) is a facet of the larger right under Article 16(1).

31. Justice Krishna Iyer, in his judgment, went further to describe Article 16(4) as “an emphatic statement” of equal opportunity, emphasizing that it was not a mere exception but a vital part of the constitutional guarantee of equality. He viewed it as “an illustration of constitutionally sanctified classification,” inserted separately, “due to the over-anxiety of the draftsmen to make matters clear beyond possibility of doubt.” In doing so, Justice Krishna Iyer helped reshape the understanding of affirmative action, affirming that such measures were an essential and constitutionally legitimate means of achieving substantive equality, rather than a mere deviation from the principle of equal treatment to unequals.

32. In 1980, in Akhil Bhartiya Soshit Karamchari Sangh v. Union of India (1981)17, in his concurring opinion, he wrote beautifully, and I quote: “In a given situation of large social categories being submerged for long, the guarantee of equality with the rest is myth, hot reality, unless it is combined with affirmative State action for equalisation geared to promotion of eventual equality. Article 16(4) is not a jarring note but auxiliary to fair fulfilment of Article 16(1). The prescription of Article 16(1) needs, in the living conditions of India, the concrete sanction of Article 16(4) so that those wallowing in the social quagmire are enabled to rise to levels of equality with the rest and march together with their brethren whom history had not so harshly hamstrung.” (end quote)

33. In both these cases, Justice Krishna Iyer read Article 16(4) with Article 46, a Directive Principle, to state that, and I quote, the “luscent intent of the Constitution framers emerges that the exploited lot of the [Scheduled Castes] in the past shall be extirpated with special care by the State. The inference is obvious that administrative participation by SC&ST shall be promoted with special care by the State” (end quote). He held that “Every Directive Principle is fundamental in the governance of the country and it shall be the duty of the State to apply that principle in making law.”

34. The view in NM Thomas was later upheld by the 9-judge bench in Indra Sawhney v. Union of India (1992)18 and is now an established constitutional principle.

35. Now, let us consider his seminal contribution to the expansive interpretation of Article 21 in the case of Maneka Gandhi v. Union of India (1978)19, where he expressed: “Personal liberty makes for the worth of the human person”. With this powerful assertion, he underscored that the right to life and personal liberty under Article 21 is not a narrow or procedural right, but one that embraces dignity, freedom, and the full development of the individual.

36. Now the Supreme Court has expanded Article 21, and applied it with Directive Principles of State Policy, and various rights which were never framed to be the Fundamental Rights have been considered to be a fundamental right: the right to portable water, right to food, right to shelter, right to pollution- free environment, right to medical treatment, and so on. The list is endless and ever-growing.

37. In the Municipal Council, Ratlam v. Shri Vardhichand (1980),20 he started a trend for judges to leave the courtroom and go out there to see with their own eyes the situation on the ground. The inhuman practice of the human beings carrying the excreta of other human beings was strongly deprecated by him. This judgment laid the foundation for the concepts of distributive justice and polluter pays and further established that a municipality cannot plead lack of funds to evade its statutory duty to provide basic sanitation and abate public nuisances.21

38. In Som Prakash Rekhi vs Union Of India (1981)22, he expanded the definition of “State” for enforcing the fundamental rights, and observed, “In our constitutional scheme where the commanding heights belong to the public sector of the national economy, to grant absolution to government companies and their ilk from Part III may be perilous. The court cannot connive at a process which eventually makes fundamental rights as rare as

'roses in December, ice in June'.”

39. The case of Som Prakash Rekhi examined whether Bharat Petroleum Corporation Ltd., having acquired Burmah Shell, qualifies as “State” under Article 12 of the Constitution, thereby allowing a writ petition under Article 32 for a former employee's reduced pension and stopped benefits.

40. Justice Krishna Iyer's deep and abiding respect for life and liberty, rooted in the values enshrined in the Fundamental Rights and Directive Principles of State Policy, is also reflected in his judgments on the humane treatment of prisoners. Drawing strength from the constitutional ideas, he underscored the State's duty to secure just and humane conditions in prisons. In several landmark decisions, he not only exposed the deplorable conditions of incarceration but also offered constructive and forward-looking suggestions for prison reform, issuing directions to ensure that even those behind bars are treated with dignity and compassion within the framework of the existing law and constitutional principles.23

41. The case of Sunil Batra v. Delhi Administration (1978),24 is one of the significant milestones in Indian jurisprudence, wherein the court dealt with the treatment and harassment of a death row inmate by highlighting the differences in the Prison Act of 1894 and constitutional rights. Justice Iyer in this case rightly observed: “Karuna is a component of Jail Justice. Basic prison decency is an aspect of Criminal justice.”.

42. Justice Krishna Iyer also strongly believed that undertrials should not be kept in jail for long periods without trial. He is well known for breaking new ground in the Indian judiciary by asserting what was once considered a taboo: “Bail is the rule, and jail is the exception.”25 In the recent past, this principle was somewhat forgotten. I am happy to state that I had the opportunity in the last year, 2024, to reiterate this legal principle in the cases of Prabir Purkayastha, Manish Sisodia, and Kavita v. ED.

43. In Gudikanti Narasimhulu v. High Court of Andhra Pradesh (1978),26 Justice Iyer opened his order with the poser: “Bail or Jail?” He outlined the relevant factors, which included the period in prison already spent and the prospect of the appeal being delayed for hearing. He was in favour of granting bail, stipulating protective and curative conditions. He was definitely against imposing onerous conditions relating to security and sureties.27 As he ruled, and I quote: “Heavy bail from poor man is obviously wrong. Poverty is society's malady and sympathy, not sternness, is the judicial response”28 (end quote).

44. Justice Iyer was equally concerned about the historically subjugation of women. He once asserted: “Speaking of equality before the law what is desiderated is not a mechanical or formal but dynamic jurisprudence of non-discrimination where gender is no disability and unfoldment of personality suffers no inhibition because of sex.”29 In the case of C. B. Muthamma vs Union Of India & Ors (1979)30, the issue revolved around gender discrimination within the Indian Foreign Service. CB Muthamma, the first woman to be appointed as an Indian Foreign Service officer, had alleged discriminatory practices prevalent in the service, because of which she was denied the benefit of promotion. Justice Iyer's judgment resulted in the removal of discrimination against women officers, setting the balance right. Thus, he broke through the “glass ceiling” with gender parity in traditional practices in public employment.31

45. Everybody is aware about his judgment in the case of Air India v. Nergesh Mirza, wherein the air hostesses who had children, had to discontinue their jobs after the first pregnancy. Justice Krishna Iyer came down heavily with the observations that if a man after having children can continue as a flight staff, then why a woman, merely because she has to discharge her duty in the aircraft, be deprived of such a right. He held that such a restriction that prejudicially affects the natural instincts of a woman to be a mother must not be permitted.

46. By 1980, Justice Bhagwati and Justice Krishna Iyer became senior judges and took the Supreme Court in a new direction while evolving humane principles. Justice Iyer, a revolutionary at heart, principally triggered this internal revolution in the thought processes of his colleagues, a movement vigorously carried forward by Justice Bhagwati and Justice Chinnappa Reddy.32

47. A new public interest jurisprudence was developed, the traditional “locus standi” norms were abandoned, epistolary litigation was promoted, and a strategy for assisting the disadvantaged and underprivileged was devised. As a result of this profound shift, the Supreme Court gained significant worldwide prominence and attention.33

48. This innovative weapon, which was initially employed by public-spirited citizens to file PILs on behalf of sections of the society that were unable to do so on their own on account of the economic and social constraints, is still bringing about unheard-of improvements in people's daily lives today. Justice Iyer rightly observed in this regard, “When the history of the judiciary in India comes to be written, PIL will be glorified as the noblest ally of the little Indian”.34

49. In one such case of PIL, he treated a prisoner's letter posted from jail as a writ petition, commenting: “Freedom behind bars is part of our constitutional tryst...If wars are too important to be left to the generals, surely prisoners' rights are too precious to be left to the jailors”.35

50. In all, Justice Iyer defined fundamental rights as well as charters of freedom, not just to acquire and hold wealth, but freedom from poverty and misery. Furthermore, his unfailing courtesy to the Counsel - Senior and Junior alike, and his spontaneous and unreserved appreciation of the assistance received, endeared him to the Bar. This is evident from his observations in State of Punjab v. Gurdial Singh (1980),36 wherein he praised the conduct of the Government Counsel and observed: “Counsel in Court are 'robed' representatives, within the parameters of the adversary system, geared to the higher cause of justice, not amoral attorneys paid to ventriloquize the case of the principal.”37

51. To summarise, Justice Iyer's more than seven-year tenure on the Supreme Court left a permanent mark. He frequently provided relief to litigants from “weaker sections” of society who might otherwise have been denied justice on technicalities. His influence stemmed from his unique values, unconventional approach, innovative methods, and the distinctive language and style of his judgments, all of which continue to be studied and admired even today.

52. Justice Iyer's jurisprudence fundamentally reshaped the relationship between Fundamental Rights and Directive Principles. He moved the courts beyond a mere legalistic interpretation to a dynamic, socio-economic revolution.38

53. He demonstrated how judicial activism, particularly through the pioneering of PIL, could be a powerful tool to bridge the gap between constitutional ideals of Directive Principles and lived realities of Fundamental Rights, making justice accessible and meaningful for all.39

54. His approach teaches us that constitutional interpretation requires a nuanced understanding of the aspirations of the people, the socio-economic realities, and the transformative goals embedded in our founding document. As we reflect on the contributions of Justice V.R. Krishna Iyer, his abiding legacy inspires us to continue his empathic, proactive jurisprudence.

55. I am really indebted to the organisers, to Parameshwar, and to Justice Devan Ramachandran for giving me an opportunity to come to Kochi, and pay my tribute to a person whom I have always considered a guiding star to me, to be a role model, and to be a lighthouse. In my journey, as a judge for the last 22 years, I have attempted to follow Justice Krishna Iyer's legacy towards commitment to socio-economic justice. I do not know how successful I have been. I am really indebted to all of you, for giving me a patient hearing, and for giving me this opportunity.

56. I would say that every time a bench prioritizes substantive justice over technicalities, every time a judgment expands the protective umbrella of fundamental rights for the vulnerable, every time the Court exercises its power to uphold human dignity and social equity, Justice Krishna Iyer's legacy is not just honoured, but actively lived. Thank you!

1. Azad Hawkers Union v/s Union of India, 2017 SCC OnLine Bom 10261

2. Justice V.R. Krishna Iyer; [https://lawmin.gov.in/sites/default/files/2015-02-02%20-](https://lawmin.gov.in/sites/default/files/2015-02-02%20-)

3. Justice V.R. Krishna Iyer; [https://lawmin.gov.in/sites/default/files/2015-02-02%20-](https://lawmin.gov.in/sites/default/files/2015-02-02%20-)

4. Ibid. at 473

5. Ibid.

6. Raghavan, Vikram, “V R Krishna Iyer: A Long Life in Law and Politics,” Economic and Political Weekly, vol. 50, no. 3, 2015, pp. 26–30. [http://www.jstor.org/stable/24481118](http://www.jstor.org/stable/24481118)

7. Jagmohan Singh v. State of U.P., (1973) 1 SCC 20

8. Ediga Anamma v. State of Andhra Pradesh, (1974) 4 SCC 443

9. Rajendra Prasad v. State of Uttar Pradesh, (1979) 3 SCC 646, 687

10. A Rare Judge by P. P. Rao; [https://docs.manupatra.in/newsline/articles/Upload/46E30B59-F90D-451A-9E6B-BA31219CE635.pdf](https://docs.manupatra.in/newsline/articles/Upload/46E30B59-F90D-451A-9E6B-BA31219CE635.pdf)

11. 1976 (1) SCR 906

12. 1981 SCR (2) 185; AIR 1981 SC 298

13. AIR 1993 SC 477

14. Maneka Gandhi v. Union of India -[1978] 1 SCC 248

15. Municipal Council, Ratlam vs Shri Vardhichand & Ors, AIR 1980 SUPREME COURT 1622

16. Justice V.R. Krishna Iyer; [https://lawmin.gov.in/sites/default/files/2015-02-02%20-](https://lawmin.gov.in/sites/default/files/2015-02-02%20-)

17. Som Prakash Rekhi vs Union Of India & Anr, AIR 1981 SC 212

18. A Rare Judge by P. P. Rao; [https://docs.manupatra.in/newsline/articles/Upload/46E30B59-F90D-451A-9E6B-BA31219CE635.pdf](https://docs.manupatra.in/newsline/articles/Upload/46E30B59-F90D-451A-9E6B-BA31219CE635.pdf)

19. Sunil Batra v. Delhi Administration, (1978) 4 SCC 494, 509

20. Justice V.R. Krishna Iyer; [https://lawmin.gov.in/sites/default/files/2015-02-02%20-](https://lawmin.gov.in/sites/default/files/2015-02-02%20-)

21. Gudikanti Narasimhulu v. High Court of Andhra Pradesh, (1978) 1 SCC 240

22. A Rare Judge by P. P. Rao; [https://docs.manupatra.in/newsline/articles/Upload/46E30B59-F90D-451A-9E6B-BA31219CE635.pdf](https://docs.manupatra.in/newsline/articles/Upload/46E30B59-F90D-451A-9E6B-BA31219CE635.pdf)

23. Gudikanti Narasimhulu v. High Court of Andhra Pradesh, (1978) 1 SCC 240

24. Opening the gates of the judicial castle for the oppressed: Justice Krishna Iyer's indelible legacy; [https://the-judicial-castle-for-the-oppressed-justice-krishna-iyers-indelible-legacy](https://the-judicial-castle-for-the-oppressed-justice-krishna-iyers-indelible-legacy)

25. C. B. Muthamma vs Union Of India & Ors, 1980 SCR (1) 668

26. Supra note 1

27. A unique blend of judicial virtues; [https://Justice-Krishna-Iyer/article62114948.ece](https://Justice-Krishna-Iyer/article62114948.ece)

28. Ibid.

29. Ibid.

30. Ibid; Sunil Batra Etc vs Delhi Administration And Ors. Etc, 1979 SCR (1) 392

31. State of Punjab v. Gurdial Singh, (1980) 2 SCC 471, 477

32. Remembering the People's Judge: The Judicial Philosophy of Justice Krishna Iyer; [https://philosophy-of-justice-krishna-iyer](https://philosophy-of-justice-krishna-iyer)

33. Judicial Implementation Of Directive Principles Of State Policy: Critical Perspectives – Manupatra; [https://docs.manupatra.in/newsline/articles/Upload/8CEA8CDA-BCBD-4D03-B8EF-8C3E8FFD21E4.1-b-_Constitution.pdf](https://docs.manupatra.in/newsline/articles/Upload/8CEA8CDA-BCBD-4D03-B8EF-8C3E8FFD21E4.1-b_Constitution.pdf)

34. Justice V.R. Krishna Iyer; [https://lawmin.gov.in/sites/default/files/2015-02-02%20-](https://lawmin.gov.in/sites/default/files/2015-02-02%20-)