basis of Article 51 of the Government of Union Territories Act, 1963. Which thus reads Criticism Article 356 gives wide powers to the Union government to assert its authority over a state if civil unrest occurs and the state government does not have the means to end it. Though the purpose of this article is to give more powers to the Union government to preserve the unity and integrity of the nation, it has often been misused by the ruling parties at the Centre, who used it as a pretext to dissolve state governments ruled by political opponents. Thus, it is seen by many as a threat to the federal state system. Since the adoption of the Indian constitution in 1950, the Union government has used this article several times to dissolve elected state governments by imposing President's rule. The article was used for the first time in Punjab on 20 June 1951. It was also used in the state of Patiala and East Punjab States Union (PEPSU) and during the Vimochana Samaram to dismiss the democratically elected Communist state government of Kerala on 31 July 1959. In the 1970s and 1980s, it was common for the Union government to dismiss state governments led by opposition parties. The Indira Gandhi regime and post-emergency Janata Party were noted for this practice. Indira Gandhi's government between 1966 and 1977 is known to have imposed President's rule 39 times in different states. Similarly, the Janata Party which came to power after the emergency issued President's rule in 9 states which were ruled by Congress. The practice was limited only after the Supreme Court established strict guidelines for imposing President's rule in its ruling on the S. R. Bommai v. Union of India case in 1994. This landmark judgement has helped curtail the widespread abuse of Article 356. The judgement established strict guidelines for imposing President's rule. Subsequent pronouncements by the Supreme Court in Jharkhand and other states have further limited the scope for misuse of Article 356. Only since the early 2000s has the number of cases of imposition of President's rule has been drastically reduced. Article 356 has always been the focal point of a wider debate of the federal structure of government in Indian polity. The Sarkaria Commission Report on Centre-State Relations 1983 has recommended that Article 356 must be used "very sparingly, in extreme cases, as a measure of last