Court caseAIR 1950 SC 27

Gopalan, a communist leader, was detained under the Preventive Detention Act 1950 and challenged the Act and his detention under Articles 19, 21 and 22.

The majority held that 'procedure established by law' means procedure prescribed by a validly enacted law, not natural justice or due process; that Article 19 applies only to free persons and not to a law of preventive detention; and that each fundamental right operates in its own compartment. Fazl Ali J dissented, reading the rights together. The detention was upheld, except for one section of the Act.