Which one of the following statements about 'personal liberty' is not correct?

Statement 4 is incorrect because in the A.K. Gopalan vs. State of Madras (1950) case, the Supreme Court took a narrow interpretation of Article 21 [1]. The majority held that 'procedure established by law' was distinct from the American 'due process of law' and that Article 21 offered protection only against arbitrary executive action, not legislative action [1]. It was only later, in the Maneka Gandhi vs. Union of India (1978) case, that the Court overruled Gopalan and introduced the requirement that procedures must be fair, just, and reasonable, effectively incorporating 'due process'. Statements 1 and 2 correctly reflect Article 21's mandate that deprivation of liberty requires a valid law and procedure [4]. Statement 3 is correct as the writ of Habeas Corpus is the primary judicial remedy to secure personal liberty against unlawful detention [2].

Sources

1. [1] Indian Polity, M. Laxmikanth(7th ed.) > Chapter 8: Fundamental Rights > G Protection of Life and Personal Liberty > p. 89
2. [3] Indian Polity, M. Laxmikanth(7th ed.) > Chapter 5: Preamble of the Constitution > III Liberty > p. 45
3. [4] Democratic Politics-I. Political Science-Class IX . NCERT(Revised ed 2025) > Chapter 5: DEMOCRATIC RIGHTS > Right to Freedom > p. 82
4. [2] Indian Polity, M. Laxmikanth(7th ed.) > Chapter 90: Landmark Judgements and Their Impact > A.D.M. JABALPUR CASE (1976) > p. 627