It overruled A. K. Gopalan v. State of Madras, which had implied the exclusiveness of fundamental rights, and established a relationship between Articles 14, 19, and 21 of the Constitution (known as the 'golden triangle' or 'trinity'),[1]: 222  holding that a law depriving a person of 'personal liberty' must not violate any of them.

[1]: 220  Once again overruling A. K. Gopalan, the Court in this case held that a 'procedure' under Article 21 of the Constitution cannot be arbitrary, unfair, oppressive, or unreasonable.

[1]: 220 The decision had a significant influence on Indian constitutional law and has been described as the moment when the Supreme Court of India rejected "three decades of formalist interpretation, and inaugurated a new path where Courts would expand the rights of individuals against the State, instead of limiting or contracting them.

[3]: 273  When reasons for impounding her passport was sought, the Government of India declined to provide any "in the interests of the general public.

The Union responded in their written submissions that her passport was impounded because her presence was likely to be required in connection with legal proceedings before a 'Commission of Inquiry'.