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In SR Bommai v. Union of India (1994), the Supreme Court emphasized that Governor's report recommending President's Rule must respect federal autonomy by:
- Prioritizing Union control over State governance
- Protecting State autonomy unless genuine constitutional breakdown occurs
- Abolishing State legislative powers permanently
- Transferring State executive powers to Union permanently
Answer: Protecting State autonomy unless genuine constitutional breakdown occurs
Federal autonomy under SR Bommai: (a) Context: Challenge to President's Rule imposition violating federal autonomy, (b) Supreme Court holding: (i) Governor's report must respect federal autonomy: State autonomy protected unless genuine constitutional breakdown occurs, (ii) Constitutional breakdown narrowly defined: Genuine inability to function in accordance with Constitution, not mere political instability, (iii) Judicial review: Courts examine whether report respects federal autonomy, not just procedural compliance, (c) Applications: (i) Post-1994: Courts more willing to strike down Article 356 proclamations violating federal autonomy, (ii) Federal balance: Protects State autonomy against arbitrary Centre overreach via gubernatorial discretion, (d) Rationale: (i) Democratic legitimacy: Elected State governments represent people's will; Article 356 exceptional measure, not routine tool, (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: Federal autonomy requirement protects State autonomy; judicial review ensures Article 356 used for genuine crises, not political convenience.