Which one of the following statements with regard to Maneka Gandhi vs. Union of India case, 1978 is not correct?

In the landmark Maneka Gandhi vs. Union of India (1978) case, the Supreme Court overturned the restrictive 'Gopalan' view, ruling that Articles 14, 19, and 21 are not watertight compartments but form a 'golden triangle' [1]. The Court held that any law depriving a person of personal liberty under Article 21 must also satisfy the requirements of Article 19 and Article 14. Therefore, statement 2 is incorrect as it suggests a law under Article 21 might not need to satisfy Article 19. The judgment established that the 'procedure established by law' must be just, fair, and reasonable, not arbitrary. While the case expanded Article 21 to include the right to a fair trial and travel abroad [2], the specific exclusion of the 'right to die' from the right to life was later affirmed in the Gian Kaur case (1996), maintaining the principle that Article 21 protects the right to live with dignity.

Sources

1. [1] https://www.lkouniv.ac.in/site/writereaddata/siteContent/202003281533580196varun_Right_to_Life.pdf
2. [2] Indian Polity, M. Laxmikanth(7th ed.) > Chapter 8: Fundamental Rights > D I Right to Education > p. 91