- “public order” vague and subjective
- confiscation of passport violates Article 21
- denial of right violates Article 14
- Overrules previous decision saying Article 14, 19 and 21 are mutually exclusive (AK. Gopalan v State of Madras 1950)
- 14, 19 and 21 must be seen interrelated
- PEBL must be just, fair and reasonable
- court will examine even legis actions