Previous Year Question
Which one of the following cases outlined the basic structure doctrine of the Indian Constitution?
Gopalan vs Madras State
Golaknath vs Punjab State
Keshava Nand Bharti vs Kerala State
None of these
Correct Answer: C
Detailed Solution
The Basic Structure Doctrine of the Indian Constitution was evolved in Kesavananda Bharati v. State of Kerala (1973). A 13-Judge Bench of the Supreme Court delivered this landmark judgment on 24 April 1973.
The central principle was that Parliament possesses wide power to amend the Constitution under Article 368, but it cannot destroy or alter the basic structure or identity of the Constitution. This became known as the Basic Structure Doctrine.
Chief Justice S. M. Sikri identified illustrations of the basic structure including supremacy of the Constitution, republican and democratic government, secular character, separation of powers and the federal character of the Constitution. The list was not treated as exhaustive, and later judgments further developed the doctrine.
Golak Nath v. State of Punjab (1967) was an important earlier case concerning Parliament's power to amend Fundamental Rights, but it did not formulate the Basic Structure Doctrine.
A. K. Gopalan v. State of Madras principally concerned personal liberty and preventive detention; it was not the source of the Basic Structure Doctrine.
Thus, the chronology is: Golak Nath (1967) → major dispute over amendment power; Kesavananda Bharati (1973) → Basic Structure Doctrine.