Article 21 lays down that, no person shall be deprived of his life or personal liberty except according to procedure established by law. This Article guarantees freedom of life to every Indian citizen against arbitrary interface by the state. It was during the internal emergency (1975-77) that the state had acquired unprecedented powers to limit the freedom of the people. Therefore, 44th Amendment was passed to avoid the recurrence of such a situation. According to this Act, the Fundamental Right to life and personal liberty must continue without any interference even if the emergency is imposed.