📌 Snapshot
- Traces the constitutional and political crisis culminating in the Emergency of 25 June 1975 — declared under Article 352 on the ground of "internal disturbance".
- Locates the trigger in the Gujarat–Bihar movements, the 1974 Railway Strike, the Allahabad High Court's invalidation of Indira Gandhi's election, and the executive–judiciary face-off after Kesavananda Bharati.
- Documents consequences — press censorship, preventive detention, suspension of Fundamental Rights, the 42nd Amendment, and the controversial habeas corpus ruling of April 1976.
- Ends with the 1977 verdict against Congress, the Janata Party experiment, its collapse, and Indira Gandhi's return in 1980 — establishing democracy's resilience and reshaping the party system.
- CUET treats this as the densest factual chapter of the book: dates (12 June 1975, 25 June 1975, 26 March 1977), Article 352, key actors (JP, Raj Narain, Justice J.M.L. Sinha, A.N. Ray, Fakhruddin Ali Ahmed, George Fernandes), and constitutional vocabulary (42nd Amendment, habeas corpus, preventive detention) are favourite stems.
📖 Detailed Notes
2.1 Core concepts
- Background to Emergency. Post-1967, Indira Gandhi had emerged as a towering leader after the 1971 Lok Sabha and 1972 State Assembly victories; her party and government had taken a much more pro-poor orientation. Yet party competition was bitter and polarised, and government–judiciary tensions grew over Parliament's power to amend Fundamental Rights and abridge property (NCERT §"Background to Emergency", p. 93). Many Congress dissenters and opposition leaders held that her style of functioning was undermining democratic institutions.
- Economic context. The slogan of garibi hatao (1971) failed to translate into improvement: the Bangladesh refugee influx of about 8 million, the 1971 war, U.S. aid cut-off, oil-price spikes after the 1973 Arab–Israel war, and inflation of 23% (1973) and 30% (1974) created mass hardship. Industrial growth was low; unemployment high; salaries of government employees were frozen as an austerity measure; the 1972–73 monsoon failure cut foodgrain output by 8% (NCERT §"Economic context", p. 93). The combined effect was widespread distress that fuelled mass protest.
- Naxalite challenge. Marxist-Leninist (later Maoist) Naxalite groups, especially strong in West Bengal, took up arms against the "capitalist order"; the State government took stringent measures to suppress them — NCERT records both the genuine grievance underlying Naxalism and the harsh police response (NCERT §"Economic context", p. 94).
- Gujarat movement (January 1974). Student agitation against rising prices, cooking-oil scarcity and corruption; opposition parties joined; the agitation became state-wide and President's Rule was imposed. After Morarji Desai's indefinite-fast threat, fresh Assembly elections were held in June 1975; Congress was defeated (NCERT §"Gujarat and Bihar movements", p. 94).
- Bihar movement (March 1974). Students invited Jayaprakash Narayan (JP) to lead a non-violent, nation-wide protest; JP gave the call for Sampoorna Kranti (Total Revolution) — social, economic and political — and demanded the dismissal of the Bihar Congress government. JP accepted leadership on the condition that the movement remain non-violent and not be limited to Bihar (NCERT §"Gujarat and Bihar movements", pp. 94–95).
- JP's 1975 march & opposition unity. In 1975 JP led one of the largest political rallies in the capital, backed by the Bharatiya Jana Sangh, Congress (O), Bharatiya Lok Dal, Socialist Party and others. He was projected as the alternative to Indira Gandhi — for the first time, an opposition platform was capable of attracting national support (NCERT §"Gujarat and Bihar movements", pp. 95–96).
- Railway Strike, May 1974. The National Coordination Committee for Railwaymen's Struggle led by George Fernandes struck nationwide over bonus and service conditions. The government declared the strike illegal, deployed the territorial army to protect tracks, arrested leaders, and the strike was called off after 20 days without settlement (NCERT §"Railway Strike of 1974", p. 96). The strike crystallised the regime's perception that opposition mobilisation was reaching dangerous proportions.
- Conflict with judiciary. Three constitutional issues — Parliament's power to abridge Fundamental Rights, to curtail the right to property, and to abridge FRs to give effect to Directive Principles — were rejected by the Supreme Court. The crisis culminated in Kesavananda Bharati (1973), which established the basic structure doctrine — Parliament can amend the Constitution but cannot alter its basic structure (NCERT §"Conflict with Judiciary", pp. 96–97).
- Supersession of judges. In April 1973, the day after the Kesavananda verdict, the government set aside the seniority of three judges and appointed Justice A.N. Ray as Chief Justice. The three superseded judges had ruled against the government. Talk of a "committed judiciary" and "committed bureaucracy" began — the idea that judges and officials should align with the executive's vision (NCERT §"Conflict with Judiciary", p. 97).
- Allahabad HC judgment. On 12 June 1975, Justice Jagmohan Lal Sinha declared Indira Gandhi's 1971 Lok Sabha election from Rae Bareli invalid on the petition of socialist leader Raj Narain, on the ground that she had used government servants in her election campaign. She was disqualified for six years. The Supreme Court on 24 June granted a partial stay: she could remain MP but could not participate in Lok Sabha proceedings or vote in the House (NCERT §"Declaration of Emergency", p. 97).
- 25 June 1975 build-up. JP led a Ramlila Maidan rally announcing a nationwide satyagraha for the PM's resignation, and asking the army, police and government employees not to obey "illegal and immoral orders." The government read this as a call for revolt (NCERT §"Crisis and response", p. 97).
- Proclamation of Emergency. On the night of 25 June 1975, the PM recommended Emergency to President Fakhruddin Ali Ahmed, who issued the proclamation immediately under Article 352 on the ground of "internal disturbance". Electricity to newspaper offices in Bahadur Shah Zafar Marg (Delhi) was cut after midnight; opposition leaders and dissenters were arrested in the early hours of 26 June; the Cabinet was only informed at a special meeting at 6 a.m. on 26 June, after the proclamation had been signed — a procedural irregularity that has been widely criticised (NCERT §"Declaration of Emergency", pp. 98, 101).
- Effects of Emergency. Federal distribution of powers was practically suspended; all powers concentrated in the Union; Fundamental Rights were suspended including the right to move the court for their restoration; press censorship was imposed (papers needed prior approval before publication); the RSS and Jamait-e-Islami were banned; strikes and public agitations were disallowed; many political workers who were not even members of the RSS or banned groups were arrested (NCERT §"Consequences", p. 101).
- Preventive detention & habeas corpus. The government made extensive use of preventive detention (arrest on apprehension of an offence rather than for one committed). Arrested workers could not challenge detention through habeas corpus. Several High Courts initially allowed habeas corpus petitions, ruling that even though FRs were suspended, the State could not deprive a person of life and liberty without authority of law. But in April 1976 the Supreme Court's constitution bench overruled them and accepted the government's plea — effectively allowing the State to take away the right to life and liberty during Emergency. NCERT calls this "one of the most controversial judgments" of the Supreme Court (NCERT §"Consequences", p. 101).
- Resistance. The Indian Express and the Statesman protested censorship by leaving editorial spaces blank; Seminar and Mainstream chose to close down rather than submit. Kannada writer Shivarama Karanth (Padma Bhushan) and Hindi writer Phanishwarnath Renu (Padma Shri) returned their awards in protest. Many journalists were arrested for writing against the Emergency, as were underground newsletter distributors. Open defiance, however, was rare; most people accepted what was happening with a mix of fear, indifference and (in some sections) approval (NCERT §"Consequences", pp. 101–102).
- 42nd Amendment & constitutional changes. Elections of the PM, President and Vice-President were placed beyond court challenge; the 42nd Amendment extended the legislatures' tenure from five to six years — a permanent change, not just for the Emergency period. During an Emergency, elections could be postponed by one year — effectively, the post-1971 Lok Sabha would need elections only by 1978 instead of 1976. The 42nd Amendment also placed restrictions on judicial review and inserted into the Preamble the words "Socialist," "Secular," and "Integrity" (NCERT §"Consequences", p. 102).
- Lessons of Emergency. Democracy was restored quickly — "it is extremely difficult to do away with democracy in India". Three lessons: (i) by the 44th Amendment, 'internal' Emergency can now be proclaimed only on the ground of 'armed rebellion', and the Cabinet's written advice to the President is now necessary; (ii) awareness of civil liberties grew, and civil-liberties organisations sprang up; (iii) the judiciary became more active in protecting civil liberties (NCERT §"Lessons of the Emergency", pp. 102–103).
- Shah Commission. NCERT highlights that the police and the administration became political instruments of the ruling party during the Emergency — vulnerable to political pressures — and that this remains a vulnerability of the system that the Shah Commission of Inquiry (1977), appointed by the Janata government, brought out (NCERT §"Lessons of the Emergency", p. 103; also Exercise Q5, p. 111).
- 1977 elections. Held in March 1977 after 18 months of Emergency; opposition parties formed the Janata Party under JP's leadership; Jagjivan Ram floated the Congress for Democracy, later merged with Janata. Result: Janata + allies won 330 of 542 seats (Janata itself 295); Congress fell to 154 seats and under 35% votes. Indira Gandhi was defeated from Rae Bareli, and Sanjay Gandhi from Amethi. The wave was massive in the north; Congress retained Maharashtra, Gujarat, Orissa and swept the south, where the Emergency had not been experienced as oppressively (NCERT §"Lok Sabha Elections, 1977", pp. 103–105). The election was effectively a referendum on the Emergency; the verdict was a clear "no".
- Janata Government. Three-way contest for PM among Morarji Desai, Charan Singh and Jagjivan Ram; JP and J.B. Kripalani's intervention finally produced Morarji Desai as PM. The party lacked direction, leadership and a common programme. The Janata Party split when factions could not be held together; Morarji Desai lost majority within 28 months; Charan Singh then formed a government with Congress's outside support and lasted about four months before Congress withdrew support. In the January 1980 elections, Congress under Indira Gandhi won 353 seats and returned to power (NCERT §"Janata Government", pp. 105–108).
- Legacy. Congress shed its umbrella character and identified with one ideology and one leader. Opposition learned the lesson of unity and adopted the strategy of 'non-Congressism', which became central to coalition politics in subsequent decades. The welfare of backward castes began entering politics — the Mandal Commission was appointed by the Janata government, an issue that would dominate later politics (NCERT §"Legacy", pp. 108–109).
- Final assessment. The Emergency was both a constitutional crisis (over Parliament–Judiciary jurisdiction) and a deeper political crisis — the ruling party with absolute majority chose to suspend democratic norms, exposing the tension between institution-based democracy and democracy of mass protest. NCERT leaves the assessment of the relative responsibility of the government and the opposition to the reader, presenting both positions: the government's claim that there was a serious law-and-order breakdown, and the opposition's claim that this was an ordinary protest movement that could have been handled politically (NCERT §"Legacy", pp. 109–110).
2.2 Definitions to memorise
| Term | Definition | Page |
|---|---|---|
| Emergency (Article 352) | A constitutional state declared by the President on grounds of external threat or — pre-44th-Amendment — "internal disturbance"; concentrates powers in the Union and permits curtailment of Fundamental Rights | 98 |
| Sampoorna Kranti (Total Revolution) | JP's 1974 call for transformation in social, economic and political spheres to establish "true democracy" | 94 |
| Garibi hatao | Indira Gandhi's 1971 election slogan to remove poverty | 93 |
| Bihar Movement | Student-led 1974 movement that invited JP and demanded dismissal of the Bihar Congress government | 94 |
| Gujarat Movement | January 1974 anti-price-rise student movement that triggered President's Rule in Gujarat | 94 |
| Committed judiciary / bureaucracy | Idea that judges and officials should be loyal to the executive/legislature's vision — invoked by Indira-era loyalists | 96–97 |
| Kesavananda Bharati (1973) | Supreme Court judgment that established the basic structure doctrine | 97 |
| Basic structure doctrine | Parliament can amend the Constitution but cannot alter its basic structure | 97 |
| Supersession of judges (1973) | Appointment of Justice A.N. Ray as CJI by superseding three senior judges who had ruled against the government | 97 |
| Preventive detention | Arrest and detention not for any offence committed, but on apprehension that one may commit an offence | 101 |
| Habeas corpus | Writ ordering production of an arrested person before a court; challenge to detention | 101 |
| Press censorship | Requirement that newspapers obtain prior government approval for material to be published | 101 |
| 42nd Amendment (1976) | Wide-ranging amendment passed during Emergency; extended legislatures' tenure from 5 to 6 years and curtailed judicial review | 102 |
| 44th Amendment | Post-Emergency amendment that replaced "internal disturbance" with "armed rebellion" as a ground for Emergency, and made Cabinet's written advice mandatory | 102–103 |
| Internal disturbance | Pre-44th-Amendment ground used to proclaim Emergency on 25 June 1975 | 98 |
| Armed rebellion | Post-44th-Amendment ground for proclaiming internal Emergency | 102 |
| Janata Party | 1977 merger of Bharatiya Lok Dal, Congress (O), Jana Sangh, Socialist Party under JP's leadership | 103 |
| Congress for Democracy | Group floated by Jagjivan Ram in 1977; merged with Janata | 103 |
| Non-Congressism | Strategy of opposition parties to avoid splitting non-Congress votes by uniting against Congress | 108 |
| Mandal Commission | Backward-classes commission appointed by the Janata government | 109 |
| Shah Commission | Commission of inquiry appointed by the Janata government in 1977 to inquire into Emergency excesses | 111 (Exercise Q5) |
| Civil liberties organisations | Rights groups (PUCL, PUDR) that emerged in the aftermath of the Emergency to monitor State action | 103 |
| Rae Bareli | Indira Gandhi's Lok Sabha constituency, lost to Raj Narain in 1977 | 97, 104 |
| Amethi | Sanjay Gandhi's Lok Sabha constituency, lost in 1977 | 104 |
2.3 Diagrams / processes to remember
- **Editorial of Nai Dunia, 27 June 1975** — blank editorial column as protest against censorship (NCERT p. 92).
- Abu cartoon "PM says…" — economic distress, p. 93.
- **R.K. Laxman cartoon, Times of India 16 April 1974** — JP and the Bihar movement, p. 95.
- **R.K. Laxman cartoon, Times of India 26 June 1975** — D.K. Barooah behind the chair, captures impending crisis (pp. 98–99).
- **R.K. Laxman cartoon, Times of India 29 March 1977** — common man with Jagjivan Ram, Morarji Desai, Charan Singh and Atal Behari Vajpayee after the 1977 verdict (p. 104).
- Map of 1977 election results — Congress wiped out in north, retained Maharashtra/Gujarat/Orissa/south (p. 106).
- Cartoon "Emergency was like a vaccination against dictatorship" — Janata Party faction cartoons (p. 107).
- Profiles to recognise — Jayaprakash Narayan (1902–1979), Morarji Desai (1896–1995), Charan Singh (1902–1987), Jagjivan Ram (1908–1986).
- Sequence chain: 12 June 1975 Allahabad HC verdict → 24 June 1975 SC partial stay → 25 June 1975 Ramlila Maidan rally → 25–26 June 1975 Emergency proclaimed → April 1976 SC habeas corpus ruling → March 1977 elections → 1980 Indira returns.
2.5 Key Articles / Treaties / Events
| Reference | Source / Subject | NCERT cite |
|---|---|---|
| Article 352 | Constitutional basis for proclamation of Emergency | p. 98 |
| Article 226 / 32 | Writs suspended during the Emergency | p. 101 |
| Kesavananda Bharati v Kerala, 1973 | Basic-structure doctrine | p. 97 |
| Supersession of judges, April 1973 | A. N. Ray made CJI over three senior judges | p. 97 |
| Gujarat Movement, January 1974 | Anti-price-rise student agitation | p. 94 |
| Bihar Movement, March 1974 | JP-led; Sampoorna Kranti call | p. 94 |
| Railway Strike, May 1974 | Led by George Fernandes; called off after 20 days | p. 96 |
| Pokhran-I nuclear test, May 1974 | Indira's strategic boost | (referenced cross-chapter) |
| Allahabad HC verdict, 12 June 1975 | Justice J. M. L. Sinha invalidates Indira's Rae Bareli election | p. 97 |
| Supreme Court partial stay, 24 June 1975 | Indira allowed to remain MP but not vote | p. 97 |
| Emergency proclaimed, 25 June 1975 | Fakhruddin Ali Ahmed signs late at night | p. 98 |
| April 1976 habeas corpus ruling | SC overruled HCs; deprivation of life/liberty held permissible | p. 101 |
| 42nd Amendment, 1976 | Lok Sabha term 5→6; "Socialist/Secular/Integrity" inserted in Preamble | p. 102 |
| March 1977 General Election | Janata sweep (330/542); Congress reduced to 154 | p. 104 |
| Janata Party formed | Merger of BLD, Cong (O), Jana Sangh, Socialist Party | p. 103 |
| Morarji Desai PM, 24 March 1977 | First non-Congress PM | p. 105 |
| Shah Commission, 1977 | Inquiry into Emergency excesses | p. 111 |
| 44th Amendment, 1978 | "Internal disturbance" replaced by "armed rebellion"; Cabinet's written advice mandatory | pp. 102–103 |
| Mandal Commission appointed (1979 — by Janata) | Backward-classes commission | p. 109 |
| Charan Singh PM | 4-month government with Congress's outside support | p. 105 |
| January 1980 Election | Congress wins 353 seats; Indira returns | p. 105 |
2.4 Common confusions / NTA trap points
- The Allahabad HC verdict was delivered by Justice J.M.L. Sinha (Jagmohan Lal Sinha) on 12 June 1975, on a petition by Raj Narain — not by the Supreme Court. NTA loves swapping these.
- The Emergency was declared under Article 352 on the ground of "internal disturbance" — not "armed rebellion". The ground was changed to "armed rebellion" only by the 44th Amendment after the Emergency, and NCERT signals this rectification (p. 102).
- The Railway Strike of 1974 was led by George Fernandes (National Coordination Committee for Railwaymen's Struggle) — not by JP, though JP led the broader Bihar movement.
- The 42nd Amendment extended the legislature's tenure from 5 to 6 years — and this was a permanent change, not limited to the Emergency (NCERT is explicit).
- The Supreme Court's controversial habeas corpus ruling came in April 1976, by a constitution bench that overruled the High Courts — not the High Courts ruling against citizens.
- Congress retained the southern states, Maharashtra, Gujarat, Orissa in 1977 — the "anti-Emergency wave" was a north-Indian phenomenon.
- The Janata government appointed the Mandal Commission — backward-class reservations enter politics from this moment, not from 1990 alone.
- Sanjay Gandhi lost from Amethi in 1977 (not Rae Bareli — that was Indira's seat).
- Cabinet informed only at 6 a.m. on 26 June — after the proclamation had already been signed by President Fakhruddin Ali Ahmed.
- Janata won 295 seats; with allies it crossed to 330; Congress fell to 154 with under 35% votes — three different numbers, often mixed up.
- Charan Singh's government lasted about 4 months (with Congress's outside support); Morarji's government lasted 28 months before losing majority.
🎯 Practice MCQs
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Q1. Under which Article of the Constitution was the Emergency proclaimed on 25 June 1975?
▸ Show answer & explanation
Answer: C
The government invoked Article 352, which permits a state of emergency on grounds of external threat or — at that time — internal disturbance. Article 356 concerns President's Rule in States; Article 360 deals with financial emergency.
Q2. Justice Jagmohan Lal Sinha of the Allahabad High Court declared Indira Gandhi's election invalid on which date?
▸ Show answer & explanation
Answer: D
The HC judgment came on 12 June 1975 on Raj Narain's petition. 24 June is when the Supreme Court granted a partial stay; 25 June is when Emergency was proclaimed.
Q3. Match the following: | List I | List II | |---|---| | (a) Total Revolution | (i) Indira Gandhi | | (b) Garibi hatao | (ii) Jayaprakash Narayan | | (c) Bihar Movement | (iii) Bihar students invited JP | | (d) Railway Strike 1974 | (iv) George Fernandes |
▸ Show answer & explanation
Answer: A
JP gave the call for *Sampoorna Kranti*; *garibi hatao* was Indira Gandhi's 1971 slogan; the Bihar movement was led by JP after the students invited him; the Railway Strike was led by George Fernandes through the National Coordination Committee for Railwaymen's Struggle.
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Q4. Which of the following statements about the 1977 Lok Sabha elections is/are correct? 1. The Janata Party itself won 295 seats. 2. The Congress was reduced to 154 seats with less than 35% of votes. 3. Indira Gandhi lost from Rae Bareli and Sanjay Gandhi from Amethi. 4. The Congress swept the southern states despite losing the north.
▸ Show answer & explanation
Answer: D
Every statement is explicit: Janata Party won 295 of 542 (with allies 330); Congress fell to 154 seats and under 35% vote-share; Indira lost Rae Bareli and Sanjay lost Amethi; Congress "virtually swept through the southern States" and held Maharashtra, Gujarat and Orissa.
Q5. The 42nd Constitutional Amendment, passed during the Emergency, extended the duration of legislatures from:
▸ Show answer & explanation
Answer: B
The 42nd Amendment extended the legislatures' tenure from five to six years, and that this change was intended to be permanent, not only for the Emergency period.
Q6. **Assertion (A):** In April 1976, the Supreme Court accepted the government's plea that during the Emergency the citizen's right to life and liberty could be taken away. **Reason (R):** The Supreme Court overruled the High Courts which had earlier entertained habeas corpus petitions by detained persons.
▸ Show answer & explanation
Answer: A
Both statements are factually correct as per NCERT, and the second directly supplies the mechanism for the first — the constitution bench overruled the High Courts and accepted the government's plea, thereby closing the doors of the judiciary for citizens.
Q7. Which of the following was NOT a feature of the Emergency declared in June 1975?
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Answer: D
Fundamental Rights were suspended, the press was censored, and RSS and Jamait-e-Islami were banned. Elections were not immediately held — they were in fact postponed; the Lok Sabha elections came only in March 1977 after 18 months of Emergency.
Q8. Who, among the following, recommended the proclamation of Emergency to President Fakhruddin Ali Ahmed on the night of 25 June 1975, with the Cabinet being informed only the next morning?
▸ Show answer & explanation
Answer: C
The Prime Minister recommended Emergency to the President, who issued the proclamation immediately; the Cabinet was informed at a 6 a.m. meeting on 26 June, after all this had happened.
Q9. Consider the following statements about events leading to the Emergency: 1. The Gujarat student agitation of January 1974 led to the imposition of President's Rule in the state. 2. Jayaprakash Narayan led the Bihar movement only after the students invited him, on the condition that it remain non-violent and not be limited to Bihar. 3. The Railway Strike of 1974 was called by the National Coordination Committee for Railwaymen's Struggle and lasted twenty days. 4. The supersession of three Supreme Court judges and the appointment of Justice A.N. Ray as Chief Justice happened in 1973, after the Kesavananda Bharati judgment. Which of the statements are correct?
▸ Show answer & explanation
Answer: D
All four statements correspond verbatim to NCERT — President's Rule in Gujarat, JP's conditional acceptance, the 20-day Railway Strike led by the National Coordination Committee, and the 1973 supersession that followed Kesavananda Bharati.
Q10. Which of the following is the odd one out in the context of the proclamation of Emergency in 1975?
▸ Show answer & explanation
Answer: D
Total Revolution, the Railway Strike and the Allahabad HC verdict were all *causes* of the Emergency. The Shah Commission Report came *after* the Emergency, having been set up by the Janata government in 1977 to inquire into Emergency excesses — so it cannot have led to the proclamation.
Q11. After the 44th Constitutional Amendment, "internal Emergency" can be proclaimed only on which ground?
▸ Show answer & explanation
Answer: B
As a lesson of the Emergency, the ground was changed from "internal disturbance" (which had been used in 1975) to "armed rebellion," and the Cabinet's written advice to the President was made mandatory.
Q12. The Janata Government formed after the 1977 elections appointed which of the following commissions?
▸ Show answer & explanation
Answer: A
The Janata government set up the Shah Commission to inquire into Emergency excesses and the Mandal Commission (Second Backward Classes Commission) to investigate the conditions of socially and educationally backward classes — both became politically consequential later.
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