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In Rameshwar Prasad case (2006), the Supreme Court struck down Bihar Assembly dissolution under Article 356, holding that the Governor's report recommending President's Rule was based on unverified media reports and political considerations, not objective assessment of constitutional breakdown. This judgment reinforced which SR Bommai principle?
- Governor's report is final and cannot be questioned
- Floor test is primary method to test majority; Governor cannot dismiss Ministry without testing majority
- President's Rule can be imposed without Parliamentary approval
- Secularism is not part of basic structure
Answer: Floor test is primary method to test majority; Governor cannot dismiss Ministry without testing majority
Rameshwar Prasad v. Union of India (2006) and SR Bommai principles: (a) Facts: Bihar Assembly elections 2005 resulted in hung Assembly; Governor recommended President's Rule citing horse-trading based on media reports, without floor test, (b) SC holding: (i) Governor's satisfaction must be based on objective material, not unverified media reports or political considerations, (ii) Floor test is primary method to test majority; Governor cannot pre-empt Assembly's right to test majority, (iii) Dissolution of Assembly is extreme step; revival possible if proclamation invalidated, (c) SR Bommai reinforcement: (i) Presidential satisfaction subject to judicial review, (ii) Floor test as democratic standard for majority verification, (iii) Secularism part of basic structure; State action against secularism can justify Article 356, (iv) Assembly dissolution not automatic; can be revived if proclamation struck down, (d) Impact: Curbed arbitrary use of Article 356 for political ends; strengthened federal balance by protecting State autonomy against Centre overreach via gubernatorial discretion, (e) Illustrates judicial protection of federal balance: Objective standards, floor test principle ensure Governor acts as constitutional functionary, not political agent; State autonomy protected within unified framework.