- Statement (A) is correct. In the A.K. Gopalan vs. State of Madras case (1950), the Supreme Court adopted a narrow interpretation of Article 21. It held that the protection under Article 21 is available only against arbitrary executive action and not against arbitrary legislative action. It also held that 'procedure established by law' meant procedure enacted by a law made by the legislature, regardless of its fairness. - Statement (B) is incorrect. In the Maneka Gandhi vs. Union of India case (1978), the Supreme Court explicitly overruled the interpretation given in the Gopalan case. It held that Article 21 protects an individual against arbitrary legislative action as well as executive action. It also ruled that the 'procedure established by law' must be fair, just, and reasonable, thus introducing the concept of 'due process of law' indirectly.