Court cannot impose additional restrictions by using tools of interpretation.
9. That the Executive cannot transgress its limits by imposing an additional restriction in the form of Executive or Departmental instruction was emphasised by this Court in Bijoe Emmanuel vs. State of Kerala50 . The Court made it clear that the reasonable restrictions sought to be imposed must be through “a law” having statutory force and not a mere Executive or Departmental instruction. The restraint upon the Executive not to have a backdoor intrusion applies equally to Courts. While Courts may be entitled to interpret the law in such a manner that the rights existing in blue print have expansive connotations, the Court cannot impose additional restrictions by using tools of interpretation. What this Court can do and how far it can afford to go, was articulated by B. Sudharshan Reddy, J., in Ram Jethmalani (supra) as follows: “85. An argument can be made that this Court can make exceptions under the peculiar circumstances of this case, wherein the State has acknowledged that it has not acted with the requisite speed and vigour in the case of large volumes of suspected unaccounted for monies of certain individuals. There is an inherent danger in making exceptions to fundamental principles and rights on the fly. Those exceptions, bit by bit, would then eviscerate the content of the main right itself. 50(1986) 3 SCC 615 46 Undesirable lapses in upholding of fundamental rights by the legislature, or the executive, can be rectified by assertion of constitutional principles by this Court. However, a decision by this Court that an exception could be carved out remains permanently as a part of judicial canon, and becomes a part of the constitutional interpretation itself. It can be used in the future in a manner and form that may far exceed what this Court intended or what the constitutional text and values can bear. We are not proposing that Constitutions cannot be interpreted in a manner that allows the nationState to tackle the problems it faces. The principle is that exceptions cannot be carved out willynilly, and without forethought as to the damage they may cause.
86.One of the chief dangers of making exceptions to principles that have become a part of constitutional law, through aeons of human experience, is that the logic, and ease of seeing exceptions, would become entrenched as a part of the constitutional order. Such logic would then lead to seeking exceptions, from protective walls of all fundamental rights, on grounds of expediency and claims that there are no solutions to problems that the society is confronting without the evisceration of fundamental rights. That same logic could then be used by the State in demanding exceptions to a slew of other fundamental rights, leading to violation of human rights of citizens on a massive scale.
” 30. Again, in Secretary, Ministry of Information & Broadcasting, Govt. of India vs. Cricket Association of Bengal51, this Court cautioned that the restrictions on free speech can be imposed only on the basis of Article 19(2). In Ramlila Maidan Incident, in re.52 , this Court developed a threepronged 51(1995) 2 SCC 161 52 (2012) 5 SCC 1 47 test namely, (i) that the restriction can be imposed only by or under the authority of law and not by exercise of the executive power; (ii) that such restriction must be reasonable; and (iii) that the restriction must be related to the purposes mentioned in clause (2) of Article 19.