In Menaka case (1978), the Supreme Court overruled its judgment in the Gopalan case by taking a wider interpretation of the Article 21.  

• Therefore, it ruled that the right to life and personal liberty of a person can be deprived by a law provided the procedure prescribed by that law is reasonable, fair and just.  
• In other words, it has introduced the American expression ‘due process of law’.  
• In effect, the protection under Article 21 should be available not only against arbitrary executive action but also against arbitrary legislative action. 

Source: Laxmikanth.