The Madras High Court ruled that under Article 161, the Governor must act on the aid and advice of the Council of Ministers in granting clemency, reinforcing democratic accountability.

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• Court held that Article 161 powers are not personal discretionary powers of the Governor.
• Governor is constitutionally bound by aid and advice of the Council of Ministers.
• Clemency powers include pardon, reprieve, respite, remission and commutation of sentences.
• Any deviation from ministerial advice is constitutionally invalid and against parliamentary democracy.
• Judgment reinforces principle of responsible government and elected executive supremacy.
• Court declared contrary earlier rulings as per incuriam for ignoring binding precedents.
• Governor acts as a nominal head, not an independent or parallel executive authority.
• Real executive power lies with the elected government representing people’s will.
• Article 161 applies to offences under the executive power of the State.
• Clemency powers serve humanitarian purpose and correct judicial errors or excessive punishment.
• These powers are subject to judicial review on grounds like arbitrariness or mala fide intent.
• Ensures balance between justice and mercy within constitutional framework.