Introduction
Justice V. R. Krishna Iyer, one of India’s most revered and influential judges, played an instrumental role in shaping the country’s judicial landscape during his tenure on the Supreme Court of India from 1973 to 1980. His career is marked by a tireless commitment to human rights, social justice, and judicial activism. Justice Iyer was not just a judge who interpreted the law; he was a pioneer who sought to reform the judicial process by making it more inclusive, compassionate, and responsive to the needs of the poor, the marginalized, and the oppressed. His landmark judgments, rooted in his deep sense of social responsibility, changed the course of Indian jurisprudence and set important precedents for future generations of judges, lawyers, and activists. Known for his fearless and progressive stance, Justice Krishna Iyer became a symbol of judicial activism, advocating for rights that extended beyond mere legal formalities to embrace the broader idea of social justice.
Early Life and Education
Born on November 15, 1915, in Palakkad, Kerala, Vaidyanathapuram Raghavan Krishna Iyer came from a family that valued education and social service, which profoundly influenced his worldview. Growing up in a family that upheld the ideals of social justice and equality, Krishna Iyer was exposed to progressive thought at an early age. His educational journey began in Kerala, where he completed his schooling and laid the foundation for a lifelong pursuit of knowledge.
Justice Iyer’s academic interests were wide-ranging, but his passion for law and political philosophy steered him towards the legal field. He went on to pursue his higher studies at Madras University, where he was deeply influenced by the works of great philosophers and thinkers. The academic environment helped him shape his ideas about law being a powerful tool for social transformation, a belief that would later define his judicial career.
After completing his studies, Justice Iyer began his legal practice in Kerala, where he quickly earned a reputation as a passionate advocate with a strong commitment to social reform. His work was focused on civil rights, social justice, and equality, especially for the underprivileged sections of society. This early exposure to the legal struggles of marginalized communities provided him with the understanding and compassion that would later guide his judgments on the bench.
Judicial Career and Major Contributions
Justice V. R. Krishna Iyer was appointed to the Kerala High Court in 1968, and later elevated to the Supreme Court of India in 1973. His judicial philosophy was rooted in the belief that the law should serve as a tool for social transformation rather than merely being a mechanism for maintaining the status quo. His tenure in the Supreme Court is marked by several landmark judgments that reflect his commitment to human rights, equality, and justice for the marginalized.
1. Human Rights and Social Justice
Justice Krishna Iyer’s contribution to human rights law is one of the defining aspects of his judicial career. He was a strong advocate for social justice, with a particular focus on the rights of Dalits, women, and the poor. In his judgment in the PUDR vs. Union of India (1982) case, he famously stated that the right to life under Article 21 of the Indian Constitution not only protects the right to live but also mandates the right to a life of dignity. He argued that the state has an obligation to ensure that its citizens are not deprived of a life of dignity, a concept that went far beyond mere physical existence.
Justice Iyer’s emphasis on social justice is also evident in his judgments regarding the rights of the underprivileged. He recognized that justice could not be achieved simply by legal formalities; it had to be rooted in a broader understanding of social realities. This belief led him to expand the scope of fundamental rights under the Constitution, especially in cases related to the rights of the disadvantaged.
2. Judicial Activism and Public Interest Litigation (PIL)
Justice Krishna Iyer is often credited with pioneering judicial activism in India. He championed the use of Public Interest Litigation (PIL), a mechanism that allows individuals or organizations to approach the courts on matters of public concern without having to demonstrate a personal injury or direct interest. PIL became a powerful tool for addressing issues that affected large sections of society, particularly those who lacked access to justice.
One of his most significant judgments in this regard was in the Hussainara Khatoon (1979) case, which highlighted the plight of undertrial prisoners in Indian jails. The case focused on prisoners who had been languishing in jails for years without trial, often due to a lack of legal representation or resources. Justice Iyer’s ruling led to the release of thousands of undertrials, marking a pivotal moment in the evolution of PIL as a tool for social justice.
Justice Iyer also played an instrumental role in advocating for the rights of prisoners, emphasizing that even those in custody deserved to live with dignity and enjoy their fundamental rights. His decisions extended beyond traditional judicial boundaries, and his progressive approach helped shape the modern landscape of judicial activism in India.
3. Landmark Judgments in Environmental Law
Justice Krishna Iyer was a visionary in the field of environmental law, recognizing the interconnection between human rights and the environment long before it became a widespread global concern. In a 1974 case, he upheld the significance of public participation in decisions that could impact the environment. He ruled that when people's fundamental rights, including the right to a healthy environment, are at risk, the judiciary must step in to safeguard these rights.
One of his landmark judgments in this domain was in the M.C. Mehta vs. Union of India (1987) case, often referred to as the Ganga Pollution Case. Justice Iyer’s ruling in this case laid the foundation for environmental jurisprudence in India, calling for immediate action to clean the Ganga River, which had become a source of pollution. His proactive stance in matters of environmental protection became a hallmark of his judicial philosophy.
4. Contributions to Labour Law and Women’s Rights
Justice Krishna Iyer was deeply concerned with the welfare of the working class and women's rights. He believed that the law should act as a shield for the vulnerable, particularly workers and women who often found themselves at the mercy of exploitative systems. His judgments expanded the scope of labour rights, ensuring that workers were entitled to fair treatment and protection under the law.
He was particularly vocal in advocating for gender justice. In cases related to dowry harassment, domestic violence, and gender equality, his judgments laid down important precedents that advanced women’s rights in India. He consistently emphasized that the law must treat women with equality and dignity, ensuring that gender discrimination was not allowed to persist.
Retirement and Post-Retirement Work
Justice Iyer retired from the Supreme Court of India in 1980, but his work and influence continued well beyond his retirement. After retiring from the bench, he remained deeply involved in social activism and human rights work. He became a vocal advocate for poverty alleviation, legal reforms, and the rights of the downtrodden. His retirement years were spent championing causes that he had always been passionate about, including education, social justice, and democracy.
Justice Iyer also played a significant role in legal education, delivering lectures and seminars on human rights, judicial activism, and the role of the judiciary in shaping a just society. His books, including "Judicial Reforms: A Path to Social Justice" and "The Law and Social Justice", remain crucial texts for legal scholars and activists. Through his writing and advocacy, he continued to inspire a generation of lawyers and judges committed to upholding the principles of justice.
Legacy
Justice V. R. Krishna Iyer’s legacy is one of profound influence, both within the Indian judiciary and the broader society. His progressive and compassionate approach to law has left an indelible mark on India’s judicial system. He is widely regarded as one of the greatest judicial minds India has ever produced, particularly for his focus on human rights, social justice, and judicial activism.
In recognition of his lifelong service, he was awarded the Padma Vibhushan, India’s second-highest civilian honor, in 2009. His passing on December 4, 2014, at the age of 99, marked the end of an era in Indian jurisprudence, but his work continues to guide judges, lawyers, and activists to this day.
Justice Krishna Iyer’s enduring legacy serves as a reminder of the power of the judiciary to drive social change and advocate for the rights of the marginalized. His contributions to human rights, environmental law, and public interest litigation continue to inspire generations of lawyers and citizens committed to creating a just society.
Conclusion
Justice V. R. Krishna Iyer’s life and career embody the very essence of justice, compassion, and activism. His landmark rulings and commitment to human rights have left an indelible mark on India’s legal system. A staunch advocate for social justice, judicial activism, and human dignity, his work continues to shape the legal landscape of India, and his influence is felt by every individual who believes in the transformative power of the law. Justice Iyer will always be remembered as a visionary who worked tirelessly to bring justice to those who needed it the most.