Constitutional Amendments in India
Learning Objectives
By the end of this page, you should be able to:
- Explain the procedure for amending the Constitution under Article 368 and identify which provisions fall into each of the three amendment categories.
- Trace the evolution of the basic structure doctrine from Shankari Prasad through Kesavananda Bharati to Minerva Mills.
- Identify the components courts have recognised as part of the Constitution's "basic structure."
- Explain why the 42nd Amendment is called the "mini-constitution" and what the 44th Amendment undid.
- Distinguish the holdings of Golaknath and Kesavananda Bharati on whether Fundamental Rights can be amended.
- Apply the basic structure doctrine to evaluate whether a hypothetical constitutional amendment would survive judicial review.
Quick Answer
Article 368 of the Constitution lays down the procedure for amending it, recognising three routes depending on what is being changed: a simple parliamentary majority, a special majority (two-thirds of members present and voting, plus a majority of the total membership of each House), and a special majority combined with ratification by at least half the state legislatures for federal provisions. Parliament's amending power is vast but not unlimited — since Kesavananda Bharati v. State of Kerala (1973), the Supreme Court has held that Parliament cannot amend the Constitution's "basic structure," even though it can amend Fundamental Rights and virtually any other provision. This doctrine protects core features like democracy, secularism, federalism, judicial review, and the rule of law from being destroyed through the amendment process itself.
Overview
A constitution that could never change would eventually become irrelevant — but a constitution that could be changed too easily would offer no real protection against a government intent on dismantling it. Article 368 tries to strike that balance. It gives Parliament the power to amend the Constitution, but it graduates the difficulty of amendment based on how significant the provision is: routine matters need only an ordinary law, ordinary provisions need a special majority, and provisions touching the federal structure need the states' consent too.
For the first two decades after independence, the big constitutional question was simple: can Parliament amend anything, including Fundamental Rights, using Article 368? The Supreme Court's answer swung from "yes" (Shankari Prasad, Sajjan Singh) to "no, not Fundamental Rights" (Golaknath) to, finally, a middle path in Kesavananda Bharati: Parliament can amend any part of the Constitution, including Fundamental Rights, but it cannot destroy the Constitution's "basic structure" — its identity as a document. This basic structure doctrine is now the single most important judge-made limitation on legislative power in Indian constitutional law, and it is why India's Constitution has survived 100+ amendments without losing its essential character.
Core Concepts
1. Article 368 — The Amendment Procedure
Definition: Article 368 empowers Parliament to amend any provision of the Constitution by way of addition, variation, or repeal, following the procedure laid down in that article, subject to the basic structure limitation.
Explanation: Article 368 does not treat all amendments alike. Depending on the subject matter, a bill has to go through one of three tracks:
- Simple majority (outside Article 368 procedure, but still "amendments" in substance): Certain provisions listed elsewhere in the Constitution — like the creation of new states, alteration of state boundaries and names (Article 3), or changes to salaries and allowances of judges and other officials — can be changed by ordinary legislation passed by a simple majority, the same way any regular law is passed. Article 368(1) itself excludes these from its scope.
- Special majority under Article 368(2): Most of the Constitution — including Fundamental Rights, Directive Principles, and the vast majority of articles — can only be amended by a bill passed in each House by (a) a majority of the total membership of that House, and (b) a majority of not less than two-thirds of the members present and voting. This is deliberately harder than an ordinary majority.
- Special majority + ratification by states (Article 368(2) proviso): A specific list of federally sensitive provisions — election of the President (Articles 54, 55), extent of executive power of the Union and states, the Supreme Court and High Courts, distribution of legislative powers between Union and states (the Seventh Schedule lists), representation of states in Parliament, and Article 368 itself — require the special majority in Parliament and ratification by the legislatures of not less than one-half of the states before presentation to the President.
Once passed, the bill goes to the President, who under the 24th Amendment (1971) is bound to give assent — the President cannot withhold or return the bill (unlike ordinary legislation).
Example: Suppose Parliament wants to change the retirement age of Supreme Court judges. That is a matter within Article 368(2)'s special-majority track, but because it doesn't touch the "distribution of powers between Union and states" listed in the proviso, it would not need state ratification — just a two-thirds majority in each House.
Real-World Example: The 101st Amendment (2016), which introduced the Goods and Services Tax, altered the distribution of taxing powers between the Union and the states — a proviso subject — so it required not just a two-thirds parliamentary majority but ratification by at least half the state legislatures before it could take effect.
Why It Matters: The graded procedure is what makes India's Constitution "partly rigid, partly flexible." Federal features get an extra layer of protection (state ratification) precisely because changing them unilaterally from the Centre would threaten the federal bargain the states signed up to.
Common Misunderstanding: Students often assume every constitutional amendment needs state ratification. In fact, ratification is required only for the narrow list of federally sensitive provisions under the Article 368(2) proviso — the great majority of amendments (including most Fundamental Rights amendments) need only a special majority in Parliament, no state involvement at all.
2. The Basic Structure Doctrine — Origins and Evolution
Definition: The basic structure doctrine holds that while Parliament's amending power under Article 368 is wide, it cannot be used to alter or destroy the Constitution's fundamental identity — its "basic structure" — even by following the correct amendment procedure.
Explanation: This doctrine developed through a sequence of Supreme Court decisions, each responding to a real political conflict between Parliament (which wanted to push through land reform and social welfare legislation) and the judiciary (which was striking down such laws as violating Fundamental Rights, especially the right to property under Article 31).
- Shankari Prasad v. Union of India (1951): The first case to test whether Article 368 allows amendment of Fundamental Rights. The Court held that the word "law" in Article 13(2) — which says the state shall not make any law abridging Fundamental Rights, and any such law is void — means ordinary legislative law, not a constitutional amendment. So Parliament could amend Fundamental Rights under Article 368.
- Sajjan Singh v. State of Rajasthan (1965): The Court, by majority, reaffirmed Shankari Prasad, upholding Parliament's power to amend Fundamental Rights.
- I.C. Golaknath v. State of Punjab (1967): An 11-judge bench reversed course. It held that a constitutional amendment under Article 368 is "law" within the meaning of Article 13(2), and therefore Parliament cannot amend Part III (Fundamental Rights) at all — Fundamental Rights were given a "transcendental" position beyond the reach of amendment. The Court applied this ruling only prospectively (using the doctrine of prospective overruling), so past amendments remained valid.
- The 24th Amendment (1971): Parliament's direct response to Golaknath. It amended Article 368 itself to expressly state that Parliament has the power to amend any provision of the Constitution, including Part III, and it amended Article 13 to clarify that Article 13 does not apply to amendments made under Article 368. It also made presidential assent to constitutional amendment bills mandatory.
- Kesavananda Bharati v. State of Kerala (1973): The pivotal case, decided by a 13-judge bench (the largest ever in Indian constitutional history) by a wafer-thin 7-6 majority. The Court upheld the validity of the 24th Amendment — confirming that Parliament can amend Fundamental Rights — but carved out a crucial limitation: Parliament's amending power under Article 368 does not extend to altering the "basic structure" or "basic framework" of the Constitution. The Constitution gave Parliament power to amend it, not to destroy or rewrite its identity.
Example: If Parliament passed a constitutional amendment abolishing judicial review of legislation entirely, it would follow the correct Article 368 procedure (special majority, maybe even ratification) but would still be struck down — not because the procedure was wrong, but because it destroys a basic structure feature (judicial review).
Real-World Example: In Kesavananda Bharati itself, the petitioner, the head (Swami) of a religious institution in Kerala, challenged Kerala land reform legislation and the 24th, 25th, and 29th Amendments that protected such legislation from being challenged on Fundamental Rights grounds. The case became the vehicle for the Court to finally settle the running battle between Parliament and judiciary over the scope of the amending power.
Why It Matters: Without this doctrine, a Parliament with the requisite majority could, in theory, use Article 368 to convert India into a one-party state, abolish free elections, or eliminate the judiciary — all through a "valid" amendment. The basic structure doctrine ensures that amendment power is a tool to improve and adapt the Constitution, not a tool to abolish it.
Common Misunderstanding: Many students think Kesavananda Bharati means Fundamental Rights cannot be amended. It's the opposite — Kesavananda Bharati overruled Golaknath and confirmed Fundamental Rights can be amended. What it cannot be done is destroy the basic structure, and not every amendment to a Fundamental Right destroys the basic structure.
3. What Constitutes the "Basic Structure"
Definition: The basic structure is not a fixed, exhaustively enumerated list in the Constitution's text — it is a set of core features that courts have identified, case by case, as being so fundamental to the Constitution's identity that no amendment can destroy them.
Explanation: Because Kesavananda Bharati did not produce a closed list, subsequent cases have added to it. Features judicially recognised as part of the basic structure include: supremacy of the Constitution, the republican and democratic form of government, secularism, separation of powers between the legislature, executive, and judiciary, federalism, the sovereignty and unity of India, judicial review, free and fair elections, the rule of law, and the dignity of the individual guaranteed by Fundamental Rights (particularly the harmony between Fundamental Rights and Directive Principles). The Court decides on a case-by-case basis whether a challenged amendment damages one of these features so severely that it changes the Constitution's identity — it isn't enough that the amendment merely touches or modifies one of them.
Example: A hypothetical amendment removing the power of judicial review of ordinary legislation (not just constitutional amendments) would very likely be struck down, because judicial review has been repeatedly held to be part of the basic structure (Indira Nehru Gandhi v. Raj Narain; Minerva Mills).
Real-World Example: In Indira Nehru Gandhi v. Raj Narain (1975), the Supreme Court struck down clause 4 of the 39th Amendment, which sought to place the election dispute of the Prime Minister beyond the scrutiny of any court — the Court held this violated free and fair elections and the rule of law, both part of the basic structure, even though the amendment followed the correct Article 368 procedure.
Why It Matters: This open-ended, evolving list means the doctrine is flexible enough to respond to new threats to constitutional democracy that the original framers of Kesavananda Bharati could not have anticipated, while still being grounded in judicially articulated principles rather than the personal preference of individual judges.
Common Misunderstanding: Students often think the "basic structure" is written down somewhere in the Constitution as a formal list. It is not — it is entirely a judicial construct, built up through case law since 1973, and courts continue to identify new basic structure elements when a genuine constitutional crisis calls for it.
4. The 42nd Amendment and Its Reversal by the 44th Amendment
Definition: The Constitution (42nd Amendment) Act, 1976 — passed during the Emergency (1975-77) — made sweeping changes to the Constitution and is often called the "mini-constitution" because of the sheer scale of the changes it introduced.
Explanation: The 42nd Amendment did many things at once: it added the words "Socialist" and "Secular" to the Preamble; it gave Directive Principles primacy over Fundamental Rights under Articles 14, 19, and 31 by inserting Article 31C in broad terms; it curtailed the power of judicial review of constitutional amendments by inserting clauses into Article 368 declaring that no amendment could be questioned in any court on any ground; it extended the term of the Lok Sabha and state assemblies; and it added Fundamental Duties (Article 51A) among many other changes. Two of its most aggressive moves — ousting judicial review of amendments, and giving Directive Principles unconditional primacy over Articles 14 and 19 — were struck down by the Supreme Court in Minerva Mills v. Union of India (1980) as violating the basic structure: judicial review, and the balance between Fundamental Rights and Directive Principles, were both held to be basic features. The 44th Amendment (1978), passed after the Emergency ended, then reversed several other overreaching changes — for example, it removed the right to property as a Fundamental Right (making it a mere legal right under Article 300A) but, more importantly for the amendment debate, it restored safeguards against misuse of Emergency powers and undid procedural excesses introduced by the 42nd Amendment.
Example: Under the 42nd Amendment's version of Article 368, if a citizen tried to challenge a constitutional amendment in court as unconstitutional, the amended Article 368(5) said no such challenge could even be entertained — effectively immunising the amending power from judicial review altogether.
Real-World Example: In Minerva Mills, the petitioners (owners of a textile company nationalised under the Sick Textile Undertakings Act) challenged section 55 of the 42nd Amendment, which had inserted clauses (4) and (5) into Article 368 to place amendments beyond judicial review. The Supreme Court struck these clauses down, reasoning that a limited amending power is itself part of the basic structure — Parliament cannot use its amending power to give itself unlimited amending power.
Why It Matters: Minerva Mills is the clearest illustration of the basic structure doctrine working exactly as intended — stopping Parliament from using an amendment to escape all future judicial scrutiny of its amendments. It confirmed that judicial review is not just a feature of ordinary governance but a permanent, unamendable guarantee.
Common Misunderstanding: Some students think the 42nd Amendment was entirely undone by the 44th Amendment. In fact, several of its provisions remain in force today — the words "Socialist" and "Secular" in the Preamble, and Fundamental Duties under Article 51A, are still part of the Constitution. Only the overreaching parts (ousting judicial review, unconditional Directive Principle primacy, and some Emergency-related excesses) were reversed or struck down.
5. Limits on the Amending Power After Kesavananda Bharati
Definition: Post-1973, every constitutional amendment is potentially subject to judicial review on the ground that it damages the basic structure, even though the amendment may have followed the correct Article 368 procedure in every technical respect.
Explanation: This means an amendment can fail for two entirely different reasons: (1) procedural — it wasn't passed with the correct majority, or without required state ratification where needed; or (2) substantive — it followed the procedure correctly, but its content destroys a basic structure feature. The basic structure doctrine only polices the second kind of defect. The Court in Waman Rao v. Union of India (1981) applied a practical, forward-looking approach to this doctrine: it held that the basic structure test would apply to constitutional amendments made after the Kesavananda Bharati judgment (24 April 1973), while amendments and laws placed in the Ninth Schedule before that date would not be reopened on this ground, to preserve legal certainty. It also confirmed that laws placed in the Ninth Schedule after that date are not automatically immune from judicial review and can still be tested against the basic structure doctrine.
Example: If Parliament amends Article 21 to add a new due-process safeguard, that generally does not threaten the basic structure and would be upheld easily. But if an amendment tried to abolish Article 21 (right to life and personal liberty) altogether, that would very likely fail, since the dignity of the individual and rule of law are recognised basic structure elements.
Real-World Example: In I.R. Coelho v. State of Tamil Nadu (2007), a nine-judge bench extended this logic further, holding that laws placed in the Ninth Schedule (which the Constitution says "shall not be called in question in any court" — Article 31B) after 24 April 1973 are still open to being tested against the basic structure doctrine if they damage Fundamental Rights that form part of the basic structure.
Why It Matters: These later cases show the basic structure doctrine is not a one-time historical event confined to Kesavananda Bharati — it is a living, continuously applied standard of constitutional review that Indian courts use to this day whenever an amendment is challenged.
Common Misunderstanding: Students sometimes think placing a law in the Ninth Schedule makes it permanently unchallengeable. Since Waman Rao and especially I.R. Coelho, that immunity is not absolute — Ninth Schedule laws enacted after 24 April 1973 can still be struck down if they violate the basic structure.
Visual Learning
Key Terms
| Term | Definition | Context |
|---|---|---|
| Article 368 | The constitutional provision granting Parliament power to amend the Constitution and prescribing the procedure for doing so. | Source of the amending power and the three-tier procedure. |
| Basic structure doctrine | Judicial doctrine holding that Parliament cannot use its amending power to alter the Constitution's fundamental identity. | Established in Kesavananda Bharati (1973); still applied today. |
| Special majority | A majority of the total membership of a House, and a two-thirds majority of members present and voting. | Required for most amendments under Article 368(2). |
| Ratification by states | Approval by the legislatures of at least half the states, required in addition to Parliament's special majority for certain federal provisions. | Required under the proviso to Article 368(2). |
| Prospective overruling | A technique where a court's new ruling applies only from the date of the judgment onward, leaving past actions taken under the old rule undisturbed. | Used in Golaknath to avoid invalidating past constitutional amendments. |
| Ninth Schedule | A schedule of the Constitution originally meant to place certain land reform laws beyond judicial review under Article 31B. | Its scope was limited by I.R. Coelho (2007) using the basic structure doctrine. |
| Mini-constitution | Popular name for the 42nd Amendment Act, 1976, because of the scale and breadth of changes it made. | Several of its provisions were later struck down or reversed. |
| Directive Principles of State Policy (DPSP) | Non-justiciable guidelines in Part IV directing the state toward social and economic policy goals. | Central to the Article 31C dispute in Minerva Mills. |
Common Mistakes
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Misconception: The Constitution can never be amended in a way that affects Fundamental Rights. Why it's wrong: This confuses the outcome of Golaknath (which held Fundamental Rights could not be amended) with the later and controlling decision in Kesavananda Bharati, which explicitly overruled Golaknath on this point. Correct: Fundamental Rights can be amended under Article 368 using the special majority procedure — the only constraint is that the amendment must not destroy the basic structure of the Constitution.
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Misconception: Every constitutional amendment requires ratification by the state legislatures. Why it's wrong: Students often generalise the requirement from high-profile amendments (like the GST amendment) to all amendments. Correct: State ratification is required only for the specific list of federally sensitive provisions in the proviso to Article 368(2) — the President's election, the judiciary, Union-state legislative distribution, and Article 368 itself, among a few others. Most amendments need only a special majority in Parliament.
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Misconception: The basic structure doctrine is written into the text of the Constitution as an explicit limitation. Why it's wrong: There is no article that lists "basic structure" or defines it — students sometimes look for it in the bare text and get confused when they can't find it. Correct: The doctrine is entirely judge-made, first articulated in Kesavananda Bharati (1973) and developed through subsequent case law like Indira Nehru Gandhi v. Raj Narain, Minerva Mills, and Waman Rao. Courts identify basic structure elements case by case.
Comparison and Connections
| Aspect | Golaknath v. State of Punjab (1967) | Kesavananda Bharati v. State of Kerala (1973) |
|---|---|---|
| Bench size | 11 judges | 13 judges |
| Can Parliament amend Fundamental Rights? | No — Article 368 "law" is caught by Article 13(2) | Yes — Article 13(2) does not apply to constitutional amendments |
| Basis of limitation | Fundamental Rights treated as beyond the reach of any amendment | Amending power is limited only by the "basic structure," which may or may not include a specific Fundamental Right |
| Effect on prior amendments | Applied prospectively only (past amendments preserved) | Upheld the 24th Amendment; established the basic structure test going forward |
| Long-term significance | Overruled by Kesavananda Bharati | Still the controlling precedent on the scope of Article 368 |
| Amendment procedure | Majority required | State ratification? | Example subject matter |
|---|---|---|---|
| Simple majority (outside Art. 368) | Ordinary majority, like a regular bill | No | Formation of new states, changes to Union Territory boundaries |
| Special majority (Art. 368(2)) | 2/3 present & voting + majority of total membership, each House | No | Most Fundamental Rights, most of the Constitution |
| Special majority + ratification (Art. 368(2) proviso) | Same special majority | Yes — at least half the states | President's election, Supreme Court/High Courts, Union-state legislative powers, Article 368 itself |
Practice Questions
Recall
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What are the three categories of subject matter under the Article 368 amendment procedure? Answer guidance: (1) provisions amendable by simple majority outside Article 368 (e.g., Article 3 matters); (2) provisions requiring special majority under Article 368(2); (3) federal provisions requiring special majority plus ratification by at least half the state legislatures.
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Which case first established the basic structure doctrine, and in what year? Answer guidance: Kesavananda Bharati v. State of Kerala, decided in 1973 by a 13-judge bench, 7-6 majority.
Understanding
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Explain why Kesavananda Bharati is described as overruling Golaknath while also upholding the 24th Amendment. Answer guidance: The Court agreed with the 24th Amendment's position that Parliament can amend any part of the Constitution including Fundamental Rights (contrary to Golaknath), but simultaneously held that this amending power is bounded by the basic structure — a limitation the 24th Amendment did not itself impose but which the Court read into Article 368.
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Why does Article 368 require a stricter procedure (special majority plus state ratification) for federal provisions than for other parts of the Constitution? Answer guidance: Because federal provisions affect the balance of power between the Union and the states — a bargain the states are party to — so the Constitution requires the states' own legislatures to consent before that bargain can be changed, protecting India's federal structure from unilateral alteration by the Centre.
Application
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Parliament passes a constitutional amendment, with the correct special majority, stating that no court may review the validity of any constitutional amendment ever passed. Will this amendment survive judicial scrutiny? Why or why not? Answer guidance: No. This mirrors clause (4)/(5) inserted into Article 368 by the 42nd Amendment, struck down in Minerva Mills v. Union of India (1980) for destroying judicial review and the limited nature of the amending power, both held to be part of the basic structure.
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A state government challenges a constitutional amendment that reduces the powers of state legislatures over a Seventh Schedule subject, arguing it was passed without state ratification. What should the court examine first? Answer guidance: Whether the amendment falls within the Article 368(2) proviso's list of federal provisions (distribution of legislative powers between Union and states is on that list) — if so, ratification by at least half the state legislatures was mandatory, and its absence would make the amendment procedurally invalid regardless of the basic structure question.
Analysis
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Compare the reasoning in Golaknath and Kesavananda Bharati regarding the meaning of "law" in Article 13(2). What changed? Answer guidance: Golaknath held a constitutional amendment is "law" under Article 13(2), so it cannot abridge Fundamental Rights. Kesavananda Bharati effectively endorsed the 24th Amendment's clarification that Article 13 does not apply to Article 368 amendments, freeing Parliament to amend Fundamental Rights — while substituting a different, judicially-created check (the basic structure doctrine) in place of the blanket Article 13(2) bar.
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Evaluate whether the Waman Rao "prospective from 24 April 1973" rule for applying the basic structure test creates a fair or arbitrary distinction between pre- and post-Kesavananda Bharati amendments. Answer guidance: A strong answer would note the practical rationale — legal certainty and avoiding reopening decades of settled land reform legislation — while also acknowledging the arbitrariness of using a single judgment date as a bright line, and how I.R. Coelho (2007) later softened this by subjecting even post-1973 Ninth Schedule laws to the basic structure test regardless of when the underlying Ninth Schedule entry was made effective, refining fairness at the cost of some certainty.
FAQ
1. Can Parliament amend the Preamble? Yes. In Kesavananda Bharati, the Supreme Court held the Preamble is part of the Constitution and can be amended under Article 368, as it was in 1976 by the 42nd Amendment (adding "Socialist," "Secular," and "Integrity") — but any such amendment still cannot alter the basic structure the Preamble reflects, such as the republican, democratic character of the state.
2. Is the basic structure doctrine unique to India? The specific doctrine as developed in Kesavananda Bharati is an Indian judicial innovation, though it has since influenced constitutional courts in other countries (such as Bangladesh and Pakistan) grappling with similar tensions between legislative amending power and constitutional identity.
3. What is the difference between amending the Constitution and passing an ordinary law? An ordinary law is made under the legislative powers distributed by the Constitution and must conform to it, including Fundamental Rights; a constitutional amendment changes the Constitution itself and follows the special Article 368 procedure, not ordinary lawmaking procedure.
4. Did the 24th Amendment succeed in giving Parliament unlimited amending power? Only partially. It succeeded in overturning Golaknath's bar on amending Fundamental Rights (upheld in Kesavananda Bharati), but it did not succeed in giving Parliament truly unlimited power, because the Court read in the basic structure limitation as an independent, judge-made check.
5. Why is Kesavananda Bharati considered one of the most important judgments in Indian constitutional history? Because it resolved a decade of conflict between Parliament and the judiciary over the scope of Article 368, and because the basic structure doctrine it created has since been the primary tool for striking down amendments that threaten democracy, secularism, federalism, and judicial review — effectively acting as an unwritten, permanent core of the Constitution.
Quick Revision
- Article 368 lays down the amendment procedure; some provisions (like Article 3 matters) are amended by simple majority outside Article 368.
- Three tracks: simple majority / special majority (2/3 present+voting, plus majority of total membership) / special majority + ratification by half the states (for federal provisions).
- President must give assent to a constitutional amendment bill — no discretion, since the 24th Amendment (1971).
- Shankari Prasad (1951) and Sajjan Singh (1965): Parliament can amend Fundamental Rights.
- Golaknath (1967): reversed course — Fundamental Rights cannot be amended (prospective overruling only).
- 24th Amendment (1971): asserted Parliament's power to amend any part of the Constitution, including Part III.
- Kesavananda Bharati (1973): 13-judge bench, 7-6 — Fundamental Rights CAN be amended, but the "basic structure" cannot be destroyed. Landmark limiting doctrine.
- Basic structure elements include: democracy, secularism, federalism, separation of powers, judicial review, rule of law, free elections — an open, evolving list, not a fixed text.
- 42nd Amendment (1976), the "mini-constitution," tried to oust judicial review of amendments and give DPSPs unconditional priority over Articles 14/19 — both struck down in Minerva Mills (1980).
- 44th Amendment (1978) reversed several Emergency-era excesses (though not everything the 42nd Amendment did).
- Waman Rao (1981): basic structure test applies to amendments after 24 April 1973 (the date of the Kesavananda Bharati judgment).
- I.R. Coelho (2007): even Ninth Schedule laws enacted after 1973 remain open to the basic structure test.
Related Topics
Prerequisites
Related
- 8. Judicial Review
- 9. Sovereignty
- 6. Center and State Relations
- 4. Directive Principles of State Policy
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