UPSC MainsGeneral Studies Paper IConstitutionPractice question

Constitutional Evolution Amending Power and State Reorganization

"Did the Government of India Act, 1935 lay down a federal constitution? Discuss." "Parliament's power to amend the Constitution is a limited power and it cannot be enlarged into absolute power." In light of this statement, explain whether Parliament under Article 368 of the Constitution can destroy the Basic Structure of the Constitution by expanding its amending power. "Discuss the role of Article 3 of the Indian Constitution in the reorganization of states. How does it reflect the concept of 'an indestructible Union of destructible States'?"

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How to approach

Structure the answer across three thematic sections corresponding to each constitutional dimension. First, evaluate the federal character and structural limitations of the Government of India Act, 1935. Second, examine the constitutional limits of Article 368 using the Basic Structure doctrine and pivotal case law, and conclude by analyzing Parliament's unilateral authority under Article 3 in state reorganization.

Model answer

501 words

Introduction

India's constitutional architecture reflects a blend of historical evolution, robust judicial safeguards, and dynamic territorial flexibility. From the federal blueprints envisioned under colonial statutes to post-independence doctrines preserving democratic supremacy and national integrity, the Constitution carefully balances centralized cohesion with decentralized governance.

Federal Character of the Government of India Act, 1935

The Government of India Act, 1935 proposed a formal federal framework for the subcontinent, though it fell short of establishing a true federation in practice.

  • Proposed All-India Federation: The Act provided for a federation comprising British Indian provinces and princely states. However, accession was voluntary for princely states, and because the requisite number of rulers refused to execute Instruments of Accession, the federal structure never became operational.
  • Threefold Distribution of Legislative Powers: It introduced three distinct legislative lists—Federal, Provincial, and Concurrent—delineating domains between the central authority and provinces.
  • Establishment of a Federal Court: Set up in 1937, the Federal Court was mandated to resolve inter-provincial disputes and interpret constitutional provisions.
  • Colonial Centralization: Dyarchy was retained at the Centre, while overriding veto, discretionary, and residuary powers remained vested in the colonial Governor-General, fundamentally undermining genuine federal autonomy.

Limits on Amending Power under Article 368

Parliament's constituent power under Article 368 is inherently derived from the Constitution and remains subordinate to its fundamental framework.

  • Basic Structure Inviolability: The Supreme Court ruled in the Kesavananda Bharati case (1973) that constituent power under Article 368 cannot be exercised to alter, emasculate, or abrogate the Basic Structure of the Constitution.
  • Limited Power Cannot Become Absolute: In Minerva Mills v. Union of India (1980), the apex court struck down clauses (4) and (5) of Article 368 inserted by the 42nd Amendment. The Court held that a limited amending power is itself a basic feature, and the donee of a limited power cannot expand it into absolute, unreviewable constituent power.
  • Judicial Review as a Bulwark: Any amendment attempting to extinguish judicial review or dismantle fundamental constitutional values remains void ab initio.

Article 3 and State Reorganization

Article 3 confers expansive authority upon Parliament to reshape the internal boundaries of the Indian Union without requiring state concurrence.

  • Unilateral Territorial Reorganization: Parliament can by ordinary law (simple majority under Article 4) form new states, alter areas, boundaries, or names of existing states.
  • Non-Binding State Reference: Under the proviso to Article 3, the President refers the reorganization proposal to the concerned state legislature for its opinion. However, as reaffirmed in Babulal Parate v. State of Bombay (1959), this opinion is purely advisory and does not bind Parliament.
  • Indestructible Union of Destructible States: Unlike the United States model of an 'indestructible Union composed of indestructible States', the Indian Constitution guarantees the territorial integrity of the Union, not of individual states, safeguarding national sovereignty over territorial permanence.

Conclusion

The Indian constitutional system synthesizes historical federal experiments with strong centripetal safeguards and judicial limits on legislative excess. By protecting the Basic Structure from legislative overreach and maintaining flexible internal boundaries under Article 3, the Constitution preserves national unity while adapting to emerging democratic imperatives.

Key facts to remember

case study
Minerva Mills v. Union of India (1980)

The Supreme Court invalidated clauses (4) and (5) of Article 368, ruling that Parliament's limited amending power is itself a basic feature of the Constitution that cannot be enlarged into an unlimited power.

case study
Babulal Parate v. State of Bombay (1959)

The Supreme Court established that the views of state legislatures referred under the proviso to Article 3 are consultative and not binding upon the Union Parliament.

definition
Indestructible Union of Destructible States

A constitutional formulation signifying that while the territorial identity and borders of states can be reorganized or extinguished by Parliament, the Indian Union itself is perpetual and indissoluble.

Frequently asked questions

Why did the federal scheme under the Government of India Act 1935 fail to materialize?

The federation required rulers representing at least half of the princely states' total population to sign Instruments of Accession, which the princes refused to do, leaving the federal tier unimplemented.