On 29 May 2026, a two-judge bench awarded ₹11 lakh in constitutional compensation for 24 days of illegal incarceration after a parole-release order, reiterating the 'obey first, appeal later' principle.
On 28 April 1976, in the depths of the Emergency, a five-judge Constitution Bench held by 4:1 that a person detained under the Maintenance of Internal Security Act could not move habeas corpus because the right to life and personal liberty under Article 21 stood suspended by the Presidential Proclamation under Article 359. Justice H.R. Khanna's sole dissent — that life and liberty are not the Constitution's gift to be taken away by it — cost him the Chief Justiceship. Forty-one years later, in K.S. Puttaswamy v. Union of India, a nine-judge Bench explicitly overruled the majority and adopted the Khanna dissent as the constitutional position. A digest of the judgment, its setting, the dissent, the supersession, and the doctrine that has supplanted it.