Previous Year Question

Among the given options, the correct answer is S. R. Bommai v. Union of India (1994). In this judgment, the Supreme Court recognised the constitutional significance of the Preamble and treated its principles as relevant to the basic structure of the Constitution. Later Supreme Court judgments have also referred to S. R. Bommai while noting the relationship between the Preamble and the basic structure of the Constitution.

However, an important historical distinction must be understood. The proposition was not established for the first time in S. R. Bommai. In Kesavananda Bharati v. State of Kerala (1973), the 13-Judge Bench changed the earlier position and accepted that the Preamble is a part of the Constitution. Later official Supreme Court judgments continue to cite Kesavananda Bharati for this proposition.

Before this, in In Re: Berubari Union (1960), the Supreme Court had taken the view that the Preamble was not a part of the Constitution. Kesavananda Bharati changed that position. Hence, the useful chronology is—

Berubari Union (1960) → Preamble not treated as part of the Constitution
Kesavananda Bharati (1973) → Preamble held to be part of the Constitution
S. R. Bommai (1994) → position reaffirmed; secularism linked with the basic structure

Why, then, is Bommai the answer here? Because Kesavananda Bharati is not among the four options, while S. R. Bommai v. Union of India is the option in which the Supreme Court clearly recognised and reaffirmed the constitutional importance of the Preamble.

The Bommai judgment is particularly important for secularism. The Court connected the secular character reflected in the Preamble with the basic structure of the Indian Constitution. Thus, this case is relevant for examinations in the context of Article 356, federalism, secularism and the Preamble.

Therefore, among the given options, the correct answer is (c) Bommai Vs. Union of India.