Article 194 of Indian Constitution, History, Significance

Article 194 comes under Part VI of the Indian Constitution. The article outlines the powers, privileges and immunities of the State Legislature and its members. This is done to make sure that the legislative processes are carried out in a smooth manner at state level. Article 194 helps maintain the autonomy and authority of state legislative bodies, allowing legislators to perform their duties without any interference. In this article, we are going to cover all about Article 194 of the Constitution of India and its important provisions. 

Article 194 of the Constitution of India History

In order to keep the parliamentary functions in order, the framers of the Indian Constitution provided certain powers and the privileges to the State Legislature. The idea of establishing a state legislature was derived from the British Parliamentary system and hence Article 194 was constituted to set privileges for state legislators and maintain legislative functions under protective measures. 

Article 194 of Indian Constitution Interpretation

Article 194 of the Constitution of India is sub-divided into four clauses: 

1. Freedom of Speech in the Legislature: Clause 1 ensures that the legislators are provided with freedom of speech without any restrictions in their state legislative chambers. 
2. Immunity from Legal Proceedings: Clause 2 makes sure that members of state legislature are not legally prosecuted for anything that they say or cast their vote on within the house or its committees. 
3. Definition of Powers and Privileges: Clause 3 says that, until the state legislatures establish their own rules, their powers and privileges remain as they were before the 44th Amendment of 1978.
   
4. Extended Application to Non-Members: Clause 4 provides the same privileges to non-members who are allowed to speak or participate in House proceedings or committee meetings.

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Article 194 Landwark Judgements

The following two judgements were passed with Article 194 being a factor of consideration: 

• P. V. Narasimha Rao v. State (1998): The Supreme Court held that legislators enjoy protection under Article 105(2) for speeches and votes in Parliament—even if influenced by bribery—but this immunity does not cover actions outside the House.
  
• Sita Soren v. Union of India (2024): The Court clarified that Article 194(2) cannot shield legislators from legal consequences of corrupt actions. It limited immunity and reaffirmed that accountability is paramount.

Article 194 Significance

Article 194 is important due to the following reasons: 

• Protects Legislative Independence: By providing protection to legislators from any external pressure and legal retaliation, Article 194 allows free and frank deliberations.
  
• Gives Power to Legislatures: It gives state legislatures the authority to make their own privileges and preserve institutional autonomy.
  
• Balances Privilege with Accountability: Judicial rulings make sure that the immunity is not misused to protect corrupt behavior.