Report No. 87
3. Sita Ram v. State of Uttar Pradesh, AIR 1979 SC 745 (753): 1979 (2) SCC 656 (669).
In this case the Supreme Court, while considering the validity of the Supreme Court Rules (1966), Order 21, rule 15(1)(c) and section ' 384 of the Code of Criminal Procedure, 1973, said that life and liberty had been the cynosure of special constitution attention in Article 21. The Court referred to Maneka Gandhi v. Union of India where the essence of the concept of natural justice as part of reasonable procedure had been brought out. That judgment showed how the Supreme Court had unravelled the fuller implications of Article 21 and how (since then) the Court had followed that prescription and even developed it in humane directions.