On 10 February 1970, an eleven-judge Constitution Bench of the Supreme Court struck down the Banking Companies (Acquisition and Transfer of Undertakings) Act, 1969 by a ten-to-one majority. Justice J.C. Shah's majority judgment did three doctrinally distinct things: it read Article 31(2) compensation as a 'just equivalent', it replaced the object/subject test with an effect test, and it overruled A.K. Gopalan's silo theory of fundamental rights — the analytical move that, eight years later, made the golden triangle of Maneka Gandhi possible.