Meet Justice M. Hidayatullah and his Notable Judicial decisions
- ByPravleen Kaur --
- 17 Jun 2025 --
- 0 Comments
Justice Mohammad Hidayatullah (1905–1992) was one of India’s most distinguished jurists, serving as the 11th Chief Justice of India from February 25, 1968, to December 16, 1970. Born in Betul, Central Provinces (now Madhya Pradesh), he was educated at Morris College, Nagpur, and Trinity College, Cambridge, before being called to the Bar at Lincoln’s Inn in 1930. Hidayatullah’s career was marked by a series of “firsts”—he was the youngest Advocate General, the youngest Chief Justice of a High Court, and the youngest judge of the Supreme Court of India.
Judicial Career and Public Service
Justice Hidayatullah began his legal practice in Nagpur and quickly rose through the ranks, becoming Advocate General of the Central Provinces and Berar in 1943. He was appointed as a judge of the High Court in 1946, later serving as Chief Justice of the Nagpur and then Madhya Pradesh High Courts. He was elevated to the Supreme Court in 1958 and became Chief Justice of India in 1968.
His public service extended beyond the judiciary. He twice served as Acting President of India—first in 1969 after President Zakir Husain’s death, and again in 1982. After retiring from the Supreme Court, he was unanimously elected Vice President of India (1979–1984), presiding over the Rajya Sabha with distinction.
Landmark Judgments
1. Golaknath v. State of Punjab (1967)
Justice Hidayatullah was a key member of the bench in this historic case, which held that Parliament could not amend or abridge Fundamental Rights under Part III of the Constitution. The judgment was a milestone in Indian constitutional law, establishing limits on Parliament’s power and laying the groundwork for the later “basic structure” doctrine.
2. Ranjit D. Udeshi v. State of Maharashtra (1965)
In this seminal case on obscenity, Justice Hidayatullah authored the judgment upholding the conviction of a bookseller for selling an unexpurgated edition of “Lady Chatterley’s Lover.” His nuanced reasoning balanced the right to free speech with societal morality, setting enduring standards for obscenity law in India.
3. State of Rajasthan v. Union of India (1977)
Although this case was decided after his tenure, Hidayatullah’s earlier jurisprudence on federalism and the limits of executive power influenced the Supreme Court’s approach to questions of Centre-State relations and the scope of judicial review.
4. Special Reference No. 1 of 1964 (Presidential Reference on the Keshav Singh Case)
Justice Hidayatullah’s opinions in cases involving legislative privilege and the powers of Parliament and State Legislatures helped clarify the delicate balance between the judiciary and the legislature.
Legacy and Philosophy
Justice Hidayatullah was celebrated for his independence, erudition, and literary flair. His judgments were marked by clarity, fairness, and a deep commitment to constitutionalism and individual liberty. He also contributed to legal education as President of the Indian Law Institute and International Law Association, and his writings and lectures remain influential.
His unique distinction of having served as Chief Justice of India, Acting President, and Vice President underscores his stature in Indian public life. Justice Hidayatullah’s legacy endures in the principles of judicial independence, constitutional supremacy, and protection of fundamental rights that he so ably advanced.
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