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In SR Bommai v. Union of India (1994), the Supreme Court emphasized that Governor's report recommending President's Rule should be based on material verified through ______ sources, not just unverified media reports or political considerations.
- subjective
- independent
- partisan
- confidential
Answer: independent
Independent verification of Governor's report: (a) Context: Challenge to President's Rule imposition based on unverified reports, political considerations, (b) Supreme Court holding: (i) Governor's report must be based on objective material verified through independent sources (e.g., Assembly proceedings, independent inquiries, not just media reports), (ii) Cannot be based on: Unverified media reports, political considerations, subjective assessments, party affiliations, (iii) Judicial review: Courts can examine whether report based on independently verified material, not political considerations, (c) Applications: (i) Rameshwar Prasad (2006): Struck down Bihar Assembly dissolution based on unverified media reports, political considerations, (ii) Recent Governor cases (2022-2024): Reiterated objective standards, independent verification requirement, (d) Rationale: (i) Democratic legitimacy: Elected State governments represent people's will; Article 356 exceptional measure, not routine political tool, (ii) Constitutional morality: Governor as constitutional functionary, not political agent, (iii) Federal balance: Protects State autonomy against arbitrary Centre overreach via gubernatorial discretion, (e) Illustrates constitutional federalism: Independent verification requirement protects State autonomy; judicial review ensures Article 356 used for genuine constitutional breakdown, not political convenience.