ValkyaEditorial

Tagged “proportionality”

16 articles on proportionality.

Supreme CourtSupreme Court of India

Surekha Domaji Bele v. MSEDCL (2026): after a vitiated inquiry is remanded, the disciplinary authority must apply its mind afresh to punishment

The Supreme Court partly allowed an electricity-company clerk's appeal, holding that once a defective departmental inquiry is set aside and misconduct is later proved on fresh evidence, the disciplinary authority cannot mechanically fall back on the old, pre-remand show-cause notice and reimpose dismissal — it must independently apply its mind to the quantum of punishment. A digest of the facts, the holding on proportionality and natural justice, and what it means for service-law practice.

Valkya Editorial··7 min
High CourtHigh Court of Delhi

Telegram FZ LLC v. Union of India (2026): Section 69A empowers blocking an entire platform, not just specific content

A Delhi High Court vacation bench dismissed Telegram's challenge to a temporary, nationwide block imposed ahead of the NEET-UG 2026 re-examination. Justice Tejas Karia held that Section 69A of the IT Act lets the Centre block an entire intermediary platform — not merely individual URLs or content — and that the emergency block cleared the proportionality test as the least restrictive measure available.

Valkya Editorial··8 min
Supreme CourtSupreme Court of India

Excel Crop Care v. CCI (2017): relevant turnover and proportionality in competition penalties

In 2017 a two-judge Supreme Court Bench upheld the 'relevant turnover' approach to competition penalties, holding that 'turnover' in section 27 of the Competition Act means turnover from the goods affected by the contravention, not a firm's total turnover. A digest of the bid-rigging facts, the proportionality reasoning, the DG's investigative scope, and how the 2023 Amendment has since changed the penalty base.

Valkya Editorial··9 min
Supreme CourtSupreme Court of India

IMAI v. RBI: striking the crypto banking circular

On 4 March 2020 a three-judge bench of the Supreme Court struck down the RBI Circular of 6 April 2018 that had directed banks and other RBI-regulated entities to refuse banking services to cryptocurrency exchanges. The judgment is the foundational Indian authority on proportionality review of regulator action affecting the Article 19(1)(g) right to trade — and is widely misreported as having legalised cryptocurrency, which it did not do.

Valkya Editorial··13 min
Supreme CourtSupreme Court of India

Lafarge Umiam Mining v. Union of India: environmental clearance, proportionality and the National Regulator direction

On 6 July 2011, a three-judge Bench of Chief Justice S.H. Kapadia, Justice Aftab Alam and Justice K.S. Panicker Radhakrishnan — within the T.N. Godavarman writ — dismissed the Shella Action Committee's challenge and upheld the revised environmental clearance, site clearance and Stage-I forest clearance granted to Lafarge for its limestone mine at Nongtrai, East Khasi Hills, Meghalaya. Part II of the judgment used the occasion to issue forward-looking guidelines under section 3(3) of the Environment (Protection) Act, 1986 — directing the appointment of a National Regulator, the expansion of Regional Offices, the constitution of Regional Empowered Committees, GIS-based decision-support databases, the sequencing of forest clearance before environmental clearance, and mandatory public hearing. A digest of the doctrinal architecture, the doctrine of proportionality, the anti-'fait accompli' principle, and the implementation record fifteen years on.

Valkya Editorial··14 min
Supreme CourtSupreme Court of India

Modern Dental College v. State of Madhya Pradesh: the four-prong proportionality test formally adopted in Indian rights adjudication

On 2 May 2016, a five-judge Constitution Bench of the Supreme Court — in a judgment authored by Justice A.K. Sikri — upheld the Madhya Pradesh Niji Vyavsayik Shikshan Sanstha (Pravesh Ka Viniyaman Avam Shulk Ka Nirdharan) Adhiniyam 2007, which subjected private unaided professional educational institutions to State regulation over admissions, fee fixation, reservation and eligibility criteria. The Bench formally articulated and applied the four-prong proportionality test — legitimate aim, suitability, necessity and balancing — as the working standard for assessing reasonableness of restrictions under Article 19(6) on the Article 19(1)(g) right of educational institutions. A close reading of Sikri J's reasoning, the post-T.M.A. Pai and Inamdar regulatory architecture, education as a noble occupation, the proportionality test's doctrinal afterlife in Puttaswamy, Aadhaar and Anuradha Bhasin, and the regulatory framework that NEET would inherit in CMC Vellore (2020).

Valkya Editorial··15 min
High CourtDelhi High Court

Roy & Roy v. CBI: Article 21 and the proportionality limits of Look Out Circulars

On 20 March 2026, Justice Sachin Datta of the Delhi High Court quashed Look Out Circulars against NDTV founders Prannoy and Radhika Roy, holding that an LOC sustained for ~6 years without a chargesheet — and after the underlying agency itself closed one of the two FIRs — is an unjustified curtailment of the Article 21 right to travel.

Valkya Editorial··8 min
LandmarkSupreme Court of India

Association for Democratic Reforms v. Union of India: how the Electoral Bonds Scheme was unanimously struck down

On 15 February 2024, a five-judge Constitution Bench unanimously struck down the Electoral Bonds Scheme and the Finance Act, 2017 amendments to the RBI Act, Companies Act, Income Tax Act, and Representation of the People Act that had enabled it. The judgment held the architecture violated the voter's right to information under Article 19(1)(a), failed the proportionality test, and could not be sustained on the asserted ground of donor confidentiality. A digest of the bench, the doctrinal logic, the consequential directions to SBI to disclose bond purchase and redemption data, and what the judgment now requires.

Valkya Editorial··9 min
Supreme CourtSupreme Court of India

Anuradha Bhasin v. Union of India: the internet as constitutionally protected medium and the proportionality four-step test

On 10 January 2020, a three-judge bench of the Supreme Court led by Justice N.V. Ramana — hearing challenges to the communications shutdown imposed on Jammu and Kashmir after the August 2019 abrogation of Article 370 — held that the freedom of speech and the freedom to practise trade and profession over the internet are protected under Articles 19(1)(a) and 19(1)(g) of the Constitution; that restrictions on those freedoms must satisfy a four-step proportionality test imported from Puttaswamy; that suspension orders under the Temporary Suspension of Telecom Services Rules 2017 must be published and subjected to mandatory periodic review; and that Section 144 CrPC cannot be deployed to suppress legitimate dissent. The companion judgment in Ghulam Nabi Azad v. Union of India laid down the operative directions on Section 144.

Valkya Editorial··15 min
TribunalSecurities and Exchange Board of India / Securities Appellate Tribunal

From ₹67 crore to ₹20 lakh: SAT's proportionality discipline reshapes the Winsome Yarns GDR penalty

On 28 April 2026, SEBI passed a final order in the long-running Winsome Yarns GDR matter against Arun Panchariya, recomputing the penalty from approximately ₹67 crore to ₹20 lakh after the Securities Appellate Tribunal had repeatedly directed reassessment on proportionality grounds. The order is a worked example of how SAT's proportionality jurisprudence — the requirement that penalty quantum reflect comparable precedents, the role of mitigation evidence, and the limits on penalty when gains are not conclusively established — operates in the GDR-fraud space.

Valkya Editorial··7 min
LandmarkSupreme Court of India

K.S. Puttaswamy v. Union of India: the unanimous nine-judge declaration of the right to privacy

On 24 August 2017, a nine-judge Bench of the Supreme Court held — without dissent, in 547 pages across six opinions — that the right to privacy is protected as a fundamental right under Articles 14, 19 and 21 of the Constitution. The judgment overruled M.P. Sharma (1954) and Kharak Singh (1962) in significant part, and supplied the three-prong proportionality test for state action affecting privacy. A close digest.

Valkya Editorial··11 min