In the case of Keshavananda Bharati Sripadagalvaru v. State of Kerala (1973), the Supreme Court of India delivered a historic judgment that profoundly impacted constitutional law in India, particularly regarding the scope of parliamentary power to amend the Constitution and the concept of the “basic structure.” Here’s a brief overview of this landmark case:
Background:
Keshavananda Bharati, the petitioner, was the head seer of the Edneer Mutt in Kerala. The case challenged the constitutional validity of the 24th Amendment Act, 1971, which aimed to nullify the Supreme Court’s earlier decision in the Golaknath case and restore Parliament’s authority to amend any part of the Constitution, including fundamental rights.
Key Legal Issues:
- Constitutional Amendment: The primary issue before the Supreme Court was whether there are any implied limitations on Parliament’s power to amend the Constitution, especially concerning fundamental rights and other essential features.
- Basic Structure Doctrine: The case explored whether the Constitution contains a “basic structure” that forms its core and cannot be altered even by constitutional amendment.
Court’s Decision:
The Supreme Court, in a landmark and lengthy judgment spanning over 7,000 pages:
- Doctrine of Basic Structure: Unanimously held that while Parliament has the power to amend the Constitution under Article 368, this power is not unlimited. The Court introduced and affirmed the “basic structure” doctrine, which identifies certain fundamental features of the Constitution that cannot be altered by Parliament.
- 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.
- Validity of Amendments: While upholding the validity of the 24th Amendment Act, the Court ruled that amendments that infringe upon the basic structure of the Constitution are invalid.
Significance:
- Basic Structure Doctrine: The Keshavananda Bharati case established the doctrine that the Constitution’s basic structure, including principles of democracy, secularism, federalism, and fundamental rights, is inviolable and beyond the reach of Parliament’s amending power.
- Impact on Indian Jurisprudence: The case laid the foundation for subsequent judgments that further elaborated on the scope and application of the basic structure doctrine in protecting constitutional principles from arbitrary changes.
Legacy:
- The Keshavananda Bharati case is considered one of the most consequential decisions in Indian constitutional history, ensuring the stability and endurance of the Constitution’s foundational principles amidst changing political landscapes.
This case continues to shape constitutional law in India and remains a cornerstone in discussions about the balance of power between the legislature, judiciary, and executive, as well as the protection of fundamental rights and democratic values.