The requirement of reasonableness runs like a golden thread through the entire fabric of fundamental rights.

The part III of the constitution enshrines the backbone of our democratic system which is the fundamental rights. Article 13 establishes the supremacy of fundamental rights by declaring that all laws which are inconsistent with or against fundamental rights shall be void to the extent of the inconsistency.  A law must incorporate the principles of natural justice and if a law deprives a person of his fundamental rights without complying with the rules of natural Justice could not be held as valid and it lacks reasonableness which is the core of the fundamental rights.  

Article 21 of the constitution says that: “No person shall be deprived of his life or personal liberty except according to the procedure establish by law”.

Also, personal liberty is one of the most important of all fundamental rights. The restriction upon freedoms can be only imposed if they are reasonable. Hence a restriction to be constitutionally valid must be satisfying the following 2 tests:

1.   The restriction must be for the purpose mentioned in clauses 2 to  6 of Article 19

2.   The restriction must be reasonable restriction

In Francis Coralie Mullin v. Administrator, Union territory of Delhi, (1981)1 SCC 608, the supreme court held that Article 21 requires that no one shall be deprived of his life or personal liberty except by procedure established by law and this procedure must be reasonable, fair and just not arbitrary, whimsical or fanciful.

In Ajay Hasia v. Khalid Mujib Sehravardi (1981)1SCC 722, the supreme court says that the doctrine of classification which is evolved by the courts is not a paraphrase of article 14 nor is it the objective and end of that article. It is merely a judicial formula for determining whether the legislative or executive action in question is arbitrary and therefore constitutes a denial of equality.  If the classification is not reasonable and does not satisfy the requirements of Articles 14 and 19, the action of the authority can be held as a breach of fundamental rights.

Justice Bhagwati held in the Maneka Gandhi case held that the procedure contemplated in Article 21 could not be unfair or unreasonable. The principle of reasonableness which is an essential element of equality or non-arbitrariness pervaded Article 14 like a brooding omnipresence and the procedure contemplated in Article 21 must answer the test of reasonableness in order to be in conformity with Article 14.

Also in Kasturi Lal lakshmi reddy v. state of Jammu and Kashmir observed that in the Maneka Gandhi case, the court elaborately demonstrated the requirement of reasonableness runs like a golden thread through the entire fabric of fundamental rights and the concept of reasonableness finds its positive manifestation and expression in the loftly ideal of social and economic justice. 

 In Sunil Batra V. Delhi administration (AIR 1980 SC 1579) held that the practice of keeping under trials with convicts in jails offended the test of reasonableness in Article 19 and fairness in Article 21.

Recently while looking through the various mitigating circumstances of the convict before implementing the death penalty the court is upholding the fairness and reasonableness of administering the death penalty.

In the Bacchan Singh case, the constitutional bench suggested a humane and reformist framework in the matter of the death penalty. It said that the gallows could be resorted to only in the rarest of the rare cases that too when the alternative option is unquestionably foreclosed

But the case did not in concrete terms elaborate on the mitigating factors and the method to gather them to avert the death penalty.     

Thereby In a recent case on April 2022, a bench of the supreme court led by Justice UU Lalit, in Irfan Vs state of Madhya Pradesh, identify the mitigating circumstances and ensured a convict-centric approach so that the imposition of capital punishment becomes rarer, fairer, and principled.

Also In Rajendra Pralhadrao Wasnik v. State of Maharashtra (2018), the court was open to bringing the recording material pertaining to the convict “about his conduct in jail, his conduct outside jail if he has on bail sometimes, medical evidence about his mental makeup, conduct with his family and so on. ”

Hence thereby for decades, sentencing hearings have covered only basic details like the convict's immediate family structure, educational qualifications, work before the arrest, etc. No effort was made to consider information pivotal for mitigation such as adverse childhood experiences, multi–generational history of physical and mental issues, exposure to traumatic events, and other familial, cultural, and social factors crucial to understanding an individualized sentencing inquiry.    

Thereby the requirement of reasonableness as envisaged throughout the part III of the constitution has been upheld by the courts of our country. The life of an individual is a dignified one it is not an animal life. Hence reasonableness must be proved before punishing him and without reasonable excuses his fundamental rights should not be deprived.