The present case raised the issue of whether the High Court, in accordance with Article 226 of the Indian Constitution, has the authority to protect an individual's right to life during a National Emergency. The aforementioned judgement was widely seen as a lamentable event in the annals of the Court's chronicles. The primary focus of the case was to the interpretation of Article 226, which has a wider scope compared to Article 32, since it serves to enforce rights that extend beyond those deemed basic. The case raised the inquiry of whether Article 226 has the capacity to protect an individual's fundamental right to life in times of emergency, even if such protection is not explicitly provided for by Article 21. The Court's ruling established that the inherent right to life, which beyond the scope of the Constitution, might be upheld via the application of Article 226. The ADM Jabalpur case stands as a significant event in the annals of the Court's history, underscoring the crucial role of adopting constitutionalism as a means to protect individual rights and defend the principles of justice.