In SR Bommai v. Union of India (1994), the Supreme Court emphasized that Governor's report recommending President's Rule must comply with constitutional safeguards like objective material, floor test, and ______ review, ensuring Article 356 used for genuine constitutional breakdown.

Answer: judicial

Constitutional safeguards under SR Bommai: (a) Context: Challenge to President's Rule imposition without constitutional safeguards in multiple States, (b) Supreme Court holding: (i) Governor's report must comply with constitutional safeguards: Objective material, floor test, judicial review, (ii) Constitutional safeguards ensure: Democratic verification, objective material, constitutional principles compliance, not political considerations, (iii) Judicial review: Courts examine whether safeguards complied with, not just substantive outcome, (c) Applications: (i) Post-1994: Courts more willing to strike down Article 356 proclamations without constitutional safeguards, (ii) Federal balance: Protects State autonomy against arbitrary Centre overreach via constitutional safeguards, (d) Rationale: (i) Democratic legitimacy: Constitutional safeguards ensure Article 356 reflects genuine constitutional breakdown, not political convenience, (ii) Constitutional morality: Governor as constitutional functionary, not political agent, (iii) Judicial oversight: Courts ensure Article 356 used for genuine constitutional breakdown, not political ends, (e) Illustrates constitutional federalism: Constitutional safeguards requirement protects State autonomy; judicial review ensures Article 356 used for genuine crises, not political convenience.