Explanation:

 In A K Gopalan vs State of Madras case Apex court took narrow view of article 21 and held that Article 21 has no relationship with Article 14 and 19 and said that personal liberty has nothing to do with rights given in article 19, which talks about different type of liberty and also held that article 14 which talks about reasonableness has also no relationship with Article 21. Apex court made literal interpretation of procedure establish by law.

In Maneka Gandhi vs Union of India case supreme court took broad view and held that there is the formation of golden triangle amongst article 14 19, and 21. Apex court held that procedure must be fair just and reasonable.