Introduction

Justice A. N. Ray, or Ajit Nath Ray, was a distinguished Indian jurist and legal luminary who made significant contributions to the Indian legal system. He was born on 29^th January 1912.

Justice A. N. Ray had a remarkable career in the judiciary, leaving an indelible mark through his service as the Chief Justice of India (CJI). His tenure witnessed several landmark judgments that shaped the legal landscape of the country.

What is the Career Journey of Justice A N Ray?

• Justice A N Ray undertook M.A. Modern History studies at Presidency College in Calcutta and pursued a B.A. in Honours School of Modern History at Oriel College, part of Oxford University.
• After being called to the Bar by the Society of Gray’s Inn in 1939, he practiced law at the Calcutta High Court.
• He became the Supreme Court Judge on 1^st August 1969, and he was ascended the role of 14^th CJI on 26^th April 1973.

What are the Notable Judgments of Judgments of Justice A N Ray?

• Kesavananda Bharati v. State of Kerala (1973):
  • Justice A N Ray was among the judges who did not sign the judgment in this historic case, which dealt with the basic structure doctrine of the Indian Constitution.
  • The court held that while Parliament has the power to amend the Constitution, it cannot alter its basic structure.
  • This judgment had far-reaching implications for constitutional law in India.
    • However, Justice A N Ray dissented with the majority and stated that parliament has unlimited power to amend the Constitution.
• Indira Nehru Gandhi v. Raj Narain (1975):
  • Justice A N Ray was the CJI during the hearing of this case, which had significant political ramifications.
    • The judgment declared the election of then Prime Minister Indira Gandhi as void on grounds of electoral malpractice.
  • This decision led to a political crisis and the imposition of the Emergency in India.
  • The bench held the case in favor of Raj Narain.
• ADM Jabalpur v. Shiv Kant Shukla (1976):
  • Justice A N Ray was one of the four judges who delivered the majority judgment in this infamous case, also known as the Habeas Corpus case during the Emergency in India (1975-1977).
  • The judgment held that during the Emergency, individuals could not approach the courts for writs of habeas corpus.
  • This decision was widely criticized and later overruled by the SC.

What is the Controversy Related to Justice A N Ray?

• The controversy surrounding him is primarily associated with the events leading up to and following the imposition of the state of emergency in India in 1975 by then Prime Minister.
  • During this period, there were concerns about the independence of the judiciary and allegations of judicial activism in favor of the government.
• Justice A. N. Ray's appointment as the CJI and his decisions during the emergency era fueled suspicions of his proximity to the government and a lack of judicial independence.
• The controversy stemmed as he broke the practice of appointing CJI based on seniority, as Justice A N Ray superseded Justice J.M. Shelat, Justice K.S. Hegde, and Justice A.N. Grover.
  • Notably, these three Judges had been part of the majority in the Kesavananda Bharati v. State of Kerala (1973).