Consider the passage given below and answer the following question.
Prior to Maneka Gandhi v. Union of India judgment, Article 21 ensured the right to life and personal liberty to citizens just against the arbitrary action of executive and not from legislative action. The state could obstruct the freedom of citizens in the event that it could uphold its activity by a substantial regulation. Justice Bhagwati observed that the expression ‘personal liberty’ in Article 21 is of widest amplitude and it covers a variety of rights which go to constitute the personal liberty of man and some of them have raised to the status of distinct fundamental rights and given additional safeguard under Article 19.

The words ‘procedure established by law’ in Article 21 means:

A procedure laid down or enacted by a competent authority

The correct answer is Option 2: A procedure laid down or enacted by a competent authority.

Article 21 of the Indian Constitution uses the term “Procedure Established by Law,” which means that no person shall be deprived of their life or personal liberty except according to a procedure established by law. This implies that if the government follows the prescribed legal procedures while depriving a person of their life or liberty, it is constitutionally valid, irrespective of whether the procedure is fair, just, or reasonable. The government has the authority to set the procedures and processes for implementing and enforcing these laws. Under this principle, as long as the government follows the procedures it has established, its actions are considered valid, even if they may appear unfair or unjust to individuals.

Due Process of Law has much wider significance, but it is not explicitly mentioned in the Indian Constitution. Due process of law doctrine not only checks if there is a law to deprive the life and personal liberty of a person but also sees if the law made is fair, just, and not arbitrary. Under due process, it is the legal requirement that the state must respect all of the legal rights that are owed to a person, and laws that the state enacts must conform to the laws of the land like – fairness, fundamental rights, liberty, etc.