The pattern of partisan use of President's Rule under Article 356, and the judicial limits the Supreme Court placed on it through the S. R. Bommai judgment (1994).
- Article 356 lets the Centre take over a State on failure of constitutional machinery; its repeated use against opposition-ruled States made it the most criticised provision.
- The Sarkaria Commission (1988) recommended it be used only as a last resort, with a warning to the State and a floor test first.
- S. R. Bommai v. Union of India (1994) held that the proclamation is subject to concept judicial review, that the majority must be tested on the floor of the House and not in the Governor's subjective view, and that secularism is part of the concept basic structure.
- The court can restore a dismissed government if it finds the proclamation mala fide.
- The 44th Amendment, 1978, had already required parliamentary approval within two months and capped continuance.
Article 356, the Bommai principles, and the Sarkaria recommendations are a high-frequency Centre-State and federalism theme.
Bommai did not abolish Article 356; it made the floor test and judicial review mandatory, leaving the power intact.
Bommai (1994): Article 356 is judicially reviewable, the majority is decided by a floor test, and secularism is basic structure.