UPSC MainsLAW-PAPER-I202220 Marks
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Q6.

“Amending power does not extend to damaging or destroying the basic structure or framework of our Constitution." Discuss.

How to Approach

This question probes the limits of parliamentary sovereignty within a constitutional framework. The approach should begin by defining the 'basic structure' doctrine and its genesis. Subsequently, analyze the rationale behind this limitation on amending power, citing relevant judgments. Discuss the potential consequences of eroding the basic structure and contrast with the principle of parliamentary supremacy. Finally, consider the practical implications and ongoing debates surrounding the doctrine. A structured answer with clear headings and subheadings is essential.

Model Answer

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Introduction

The Indian Constitution, while granting extensive powers to the Parliament to amend laws, is not absolute. The landmark Kesavananda Bharati v. State of Kerala (1973) case introduced the ‘basic structure’ doctrine, which acts as a constitutional restraint on the power of Parliament. This doctrine essentially states that while the Constitution can be amended, the amending power does not extend to destroying or damaging its fundamental features. The genesis of this doctrine arose from concerns regarding excessive legislative power potentially undermining the very principles upon which the Constitution was founded. This answer will explore the scope and implications of this crucial constitutional principle.

Understanding the Basic Structure Doctrine

The basic structure doctrine isn't explicitly codified in the Constitution. It’s a judicial creation, born out of the need to balance the power of the legislature with the preservation of constitutional values. The Kesavananda Bharati case was triggered by a series of challenges to the 24th, 25th, and 29th Constitutional Amendments, which sought to curtail the power of judicial review and nationalize property. The Supreme Court, while upholding the validity of some amendments, established the basic structure doctrine as a limiting principle.

Core Components of the Basic Structure

Identifying the precise contours of the basic structure remains a complex and evolving task. While no exhaustive list exists, the following elements are widely considered to be integral:

  • Secularism: The commitment to religious neutrality and equal treatment of all religions.
  • Democracy: The principles of free and fair elections, representative government, and citizen participation.
  • Rule of Law: The supremacy of law and the equality of all citizens before the law.
  • Federalism: The division of powers between the Union and the States.
  • Judicial Independence: The freedom of the judiciary from executive and legislative interference.
  • Fundamental Rights: The enshrined rights guaranteeing individual liberties and protections.
  • Unity and Integrity of the Nation: Preservation of national cohesion and territorial integrity.

Rationale Behind the Doctrine

The basic structure doctrine is rooted in several justifications:

  • Constitutional Supremacy: The Constitution is not merely a document but a living embodiment of the will of the people. Amending it to the point of destroying its core principles would violate this supremacy.
  • Limited Government: The doctrine prevents the Parliament from exercising unfettered power, ensuring a balance between legislative authority and constitutional safeguards.
  • Protection of Fundamental Rights: It safeguards fundamental rights from potential erosion through legislative action.
  • Preservation of Democratic Values: It upholds the essence of democracy by preventing actions that would undermine the principles of free and fair elections and citizen participation.

Case Laws and Evolution

Following Kesavananda Bharati, the doctrine has been reaffirmed and refined in subsequent judgments:

  • Minerva Mills v. Union of India (1980): Reinforced the importance of judicial review as a component of the basic structure.
  • S.R. Bommai v. Union of India (1994): Affirmed the doctrine’s applicability to matters of secularism and federalism, establishing a guideline for judicial intervention in situations involving constitutional breakdown.
  • Golaknath v. State of Punjab (1969): Though overruled by the 24th Amendment, this case initially argued for a strict interpretation of Article 368, highlighting the potential for legislative overreach.

Parliamentary Supremacy vs. Basic Structure Doctrine

The basic structure doctrine represents a significant departure from the traditional Westminster model of parliamentary supremacy, where Parliament is considered sovereign and its actions are generally beyond judicial review. The Indian Constitution, however, adopts a hybrid model. While Parliament possesses considerable amending power (Article 368), this power is constrained by the basic structure doctrine. This creates a tension between legislative authority and constitutional principles.

Criticisms and Challenges

The doctrine has faced criticism:

  • Judicial Activism: Critics argue that the doctrine allows the judiciary to encroach upon the legislative domain, effectively creating a "shadow constitution."
  • Vagueness: The lack of a definitive list of basic structure elements makes it susceptible to subjective interpretation and potential abuse.
  • Hindrance to Reform: Some argue it can impede necessary constitutional reforms by creating an insurmountable legal barrier.

Recent Developments and Debates

The debate surrounding the basic structure doctrine continues. Recent challenges to laws like the Aadhaar Act have invoked the doctrine, demonstrating its ongoing relevance. There is ongoing discussion about the need for greater clarity and consistency in its application. The doctrine remains a crucial element in the Indian constitutional framework, balancing the power of the legislature with the preservation of core constitutional values.

Case Name Year Key Holding Regarding Basic Structure
Kesavananda Bharati v. State of Kerala 1973 Established the basic structure doctrine.
Minerva Mills v. Union of India 1980 Reaffirmed judicial review as part of the basic structure.
S.R. Bommai v. Union of India 1994 Applied the doctrine to secularism and federalism.

Conclusion

The basic structure doctrine remains a cornerstone of the Indian Constitution, acting as a vital safeguard against the potential abuse of amending power. While criticisms regarding judicial overreach and ambiguity persist, the doctrine's primary function – protecting the fundamental principles of the Constitution – remains essential for preserving India’s democratic fabric. Moving forward, a more nuanced and consistent application of the doctrine, along with continued public discourse, is crucial to ensure its legitimacy and effectiveness in the face of evolving constitutional challenges.

Answer Length

This is a comprehensive model answer for learning purposes and may exceed the word limit. In the exam, always adhere to the prescribed word count.

Additional Resources

Key Definitions

Basic Structure Doctrine
A judicial principle that limits the power of the Indian Parliament to amend the Constitution, preventing amendments that would fundamentally alter its core features and values.
Parliamentary Supremacy
The principle that the Parliament is the supreme law-making body and its actions are beyond the reach of judicial review.

Key Statistics

Between 1950 and 1973, the Indian Parliament enacted over 80 amendments, prompting concerns about potential legislative overreach and necessitating the establishment of the basic structure doctrine.

Source: PRS Legislative Research

The 24th Amendment Act of 1972, which was challenged in the Kesavananda Bharati case, sought to remove the right to property from the list of fundamental rights.

Source: Ministry of Law and Justice

Examples

Aadhaar Act Challenge

In 2019, the Supreme Court upheld the constitutional validity of the Aadhaar Act but acknowledged concerns about privacy and data protection, demonstrating the ongoing relevance of the basic structure doctrine in safeguarding fundamental rights.

Potential Amendment of Secularism

An attempt to amend the Constitution to declare India a Hindu Rashtra would likely be struck down as a violation of the basic structure principle of secularism.

Frequently Asked Questions

Can the basic structure doctrine itself be amended?

This is a highly debated question. The Supreme Court has generally avoided directly addressing whether the basic structure doctrine can be amended, implying that any attempt to do so would likely be subject to intense judicial scrutiny.

What is the difference between the basic structure doctrine and judicial review?

Judicial review is the power of the judiciary to examine legislation and declare it unconstitutional. The basic structure doctrine provides the *basis* for judicial review, limiting Parliament’s amending power to protect the fundamental principles of the Constitution.

Topics Covered

PolityConstitutional LawConstitutional AmendmentJudicial ReviewFundamental Rights