In Maneka Gandhi V/s Union of India case (1978), in this case the passport of Maneka Gandhi was impounded by Government, the Supreme Court took a wider interpretation of Article 21. The Supreme Court's judgement in the Maneka Gandhi case effectively meant that 'procedure established by law' under Article 21 would have the same effect as the expression 'due process of law'. In a subsequent decision, the Supreme Court stated that Article 21 would read as: 'No person shall be deprived of his life or personal liberty except according to fair, just and reasonable procedure established by valid law.