In the case of I. C. Golaknath and Others v. State of Punjab and Another (1967), the Supreme Court of India delivered a landmark judgment that had significant implications for constitutional law and fundamental rights in India. Here’s a brief overview of the case:
Background:
The case involved a constitutional challenge to the Constitution (Seventeenth Amendment) Act, 1964, which sought to place limitations on the fundamental right to property guaranteed under Articles 19(1)(f) and 31 of the Indian Constitution. The Amendment Act aimed to curtail judicial review of laws relating to agrarian reform and the acquisition of estates.
Key Legal Issues:
- Fundamental Right to Property: The primary issue before the Supreme Court was whether Parliament had the authority to amend the Constitution to restrict or abrogate fundamental rights, particularly the right to property, without any limits.
- Constitutional Amendment: The case raised questions about the amending power of Parliament under Article 368 of the Constitution and the extent to which fundamental rights could be amended or abridged through constitutional amendments.
Court’s Decision:
The Supreme Court, in a historic judgment:
- Affirmed Fundamental Rights: Upheld the view that fundamental rights, including the right to property under Articles 19(1)(f) and 31, are fundamental and cannot be taken away or abridged by Parliament through constitutional amendments.
- Judicial Review: Asserted the supremacy of the Constitution and the role of the judiciary in reviewing constitutional amendments to ensure they do not violate the basic structure of the Constitution.
- Overturned Previous Decisions: Reversed earlier decisions that had upheld the validity of constitutional amendments curtailing fundamental rights.
Significance:
- Doctrine of Basic Structure: The Golaknath case established the doctrine that certain core principles and features of the Constitution, known as the “basic structure,” are inviolable and cannot be amended by Parliament.
- Impact on Constitutional Amendments: It laid the groundwork for subsequent judgments, including the Kesavananda Bharati case, which further defined and elaborated on the basic structure doctrine.
Legacy:
- The Golaknath case marked a watershed moment in Indian constitutional history, asserting judicial supremacy in interpreting the Constitution and protecting fundamental rights from legislative encroachment.
This case is pivotal in understanding the evolution of constitutional law in India, particularly the balance between parliamentary sovereignty and the protection of fundamental rights.