ValkyaEditorial

Tagged “basic-structure”

10 articles on basic-structure.

Landmark JudgmentSupreme Court of India

Aligarh Muslim University v. Naresh Agarwal: the seven-judge overruling of Azeez Basha and the re-architecture of minority-institution status under Article 30(1)

On 8 November 2024 a seven-judge Constitution Bench of the Supreme Court, by a 4:3 majority, overruled the 1968 ruling in S. Azeez Basha v. Union of India that an institution incorporated by statute could never be a minority institution under Article 30(1). The majority, authored by Chandrachud CJ on behalf of himself and Justices Sanjiv Khanna, Pardiwala and Manoj Misra, held that statutory incorporation does not extinguish minority status — what matters is whether the minority community established the institution in substance, traced through ideation, purpose and implementation; and that the conjunctive 'establish and administer' formula in Article 30(1) permits proportionate, not exclusive, minority administration. Three separate dissents — by Surya Kant J, Datta J and S.C. Sharma J — would have preserved Azeez Basha. The question of whether AMU as it exists today satisfies the new establishment test was remitted to a regular bench.

Valkya Editorial··16 min
Landmark JudgmentSupreme Court of India

Indira Nehru Gandhi v. Raj Narain: how the five-judge Bench struck down a constitutional amendment that tried to immunise a single election

On 7 November 1975, a five-judge Constitution Bench unanimously struck down Clause (4) of Article 329A — the Thirty-ninth Amendment's attempt to retroactively withdraw the Prime Minister's election from judicial scrutiny — as a violation of the basic structure. On the merits, the Court reversed the Allahabad High Court and upheld Mrs Gandhi's Rae Bareli election, but on statutory grounds: the retroactive amendments to the Representation of the People Act had taken the very corrupt-practice findings out from under Sinha J's judgment. The judgment installed free and fair elections, judicial review of election disputes and the rule of law as basic-structure components.

Valkya Editorial··16 min
Landmark JudgmentSupreme Court of India

I.R. Coelho v. State of Tamil Nadu: how the Ninth Schedule was brought within the basic structure

On 11 January 2007, a nine-judge Constitution Bench unanimously held that any law inserted into the Ninth Schedule of the Constitution after 24 April 1973 — the date of the Kesavananda Bharati judgment — is open to judicial scrutiny on the ground that it violates the basic structure or the Fundamental Rights forming part of the basic structure. The judgment closes the doctrinal loop that Kesavananda had opened: the Ninth Schedule cannot operate as a constitutional refuge from the basic structure doctrine.

Valkya Editorial··9 min
Landmark JudgmentSupreme Court of India

Janhit Abhiyan v. Union of India: how a five-judge Bench upheld the 10 per cent EWS reservation

On 7 November 2022, a five-judge Constitution Bench held by 3:2 that the Constitution (One Hundred and Third Amendment) Act, 2019 — which had inserted clauses authorising the State to provide reservation of up to 10 per cent for economically weaker sections, additional to the existing reservation under Articles 15(4), 15(5) and 16(4) — did not breach the basic structure of the Constitution. Justices Maheshwari, Trivedi and Pardiwala wrote separate concurring opinions for the majority; Justice Ravindra Bhat wrote a dissent on behalf of himself and Chief Justice U.U. Lalit. A digest of the bench, the holdings, the dissent, and the doctrinal arc of reservation jurisprudence after the EWS judgment.

Valkya Editorial··10 min
Landmark JudgmentSupreme Court of India

Kesavananda Bharati v. State of Kerala: the basic structure doctrine and the limits of Parliament's amending power

On 24 April 1973, a 13-judge Constitution Bench of the Supreme Court — the largest ever assembled in Indian constitutional adjudication — held by a 7:6 majority that Parliament's amending power under Article 368 does not extend to altering the basic structure of the Constitution. The petition had begun as a religious-property challenge by the head of the Edneer Mutt; it ended as the most consequential constitutional ruling in the Republic's history. A digest of the bench, the line-up of opinions, the doctrinal contribution that has since governed every constitutional amendment, and the cases that have applied it.

Valkya Editorial··10 min
Landmark JudgmentSupreme Court of India

L. Chandra Kumar v. Union of India: judicial review as basic structure and the limits of administrative tribunals

On 18 March 1997 a seven-judge Constitution Bench of the Supreme Court, in a unanimous judgment authored by Chief Justice A.M. Ahmadi, struck down clause 2(d) of Article 323A and clause 3(d) of Article 323B to the extent they excluded the writ jurisdiction of the High Courts and of the Supreme Court over decisions of administrative tribunals. Judicial review under Articles 32, 226 and 227 was held to be part of the basic structure of the Constitution, tribunals were repositioned as courts of first instance rather than substitutes for High Courts, and the 'alternative institutional mechanism' theory of S.P. Sampath Kumar (1987) was partly overruled.

Valkya Editorial··15 min
Landmark JudgmentSupreme Court of India

Madras Bar Association v. Union of India: the tribunal-reforms arc from the July 2021 striking-down to the November 2025 full invalidation

Across two engagements separated by four years, the Supreme Court has held the Tribunals Reforms architecture introduced by the Union to be inconsistent with the constitutional protection of judicial independence. In July 2021, a three-judge bench struck down provisions of the Tribunals Reforms (Rationalisation and Conditions of Service) Ordinance, 2021 by 2:1. In November 2025, a two-judge bench led by Chief Justice B.R. Gavai held that the Tribunals Reform Act, 2021 was unconstitutional and inconsistent with the basic structure. A digest of both engagements, the doctrinal frame, and the tribunal-independence architecture they leave.

Valkya Editorial··9 min
Landmark JudgmentSupreme Court of India

Minerva Mills v. Union of India: how the Supreme Court rolled back the Forty-second Amendment's attack on judicial review

On 31 July 1980, a five-judge Constitution Bench held by 4:1 that Sections 4 and 55 of the Constitution (Forty-second Amendment) Act, 1976 — the provisions that had purported to give the Directive Principles overriding priority over the Fundamental Rights and to immunise Article 368 amendments from judicial review — were unconstitutional. The judgment is the operative authority on the harmony between Fundamental Rights and Directive Principles, on the limits of Parliament's amending power, and on judicial review as part of the basic structure. A digest of the bench, the doctrine, and the constitutional arc.

Valkya Editorial··9 min
Landmark JudgmentSupreme Court of India

SC Advocates-on-Record Association v. Union of India: how the NJAC was struck down and the collegium restored

On 16 October 2015, a five-judge Constitution Bench held by 4:1 that the Constitution (Ninety-ninth Amendment) Act, 2014 and the National Judicial Appointments Commission Act, 2014 were unconstitutional — and restored the collegium system for the appointment of judges to the Supreme Court and the High Courts. The majority held that judicial primacy in the appointment process is part of the independence of the judiciary, which is part of the basic structure of the Constitution. Justice Chelameswar dissented entirely. A digest of the bench, the doctrinal architecture, and the Memorandum of Procedure question that remains.

Valkya Editorial··11 min
Landmark JudgmentSupreme Court of India

S.R. Bommai v. Union of India: the nine-judge Bench on Article 356, judicial review, and secularism as basic structure

On 11 March 1994, a nine-judge Constitution Bench delivered the most consequential federalism ruling of the post-Kesavananda generation. The judgment held that the President's proclamation under Article 356 imposing President's Rule in a State is subject to judicial review; that secularism is part of the basic structure of the Constitution; that the dissolution of a State Legislative Assembly cannot precede Parliament's approval of the proclamation; and that a State Government that fails to act in accordance with the secular character of the Constitution can, on appropriate facts, be dismissed. A digest of the bench, the doctrinal holdings, and the architecture they leave.

Valkya Editorial··9 min