The Indian Constitution is not just a written document—it has grown, adapted, and matured through judicial interpretation. Over the decades, the Supreme Court has delivered transformative judgments that shaped the meaning of rights, federal principles, separation of powers, and the balance between citizen freedoms and State authority. Here is an easy, professional, and factually accurate overview of how landmark cases helped the Constitution evolve.
1. Early Years: Parliament’s Power Clarified
Shankari Prasad (1951) and Sajjan Singh (1965)
In the early years, the Supreme Court upheld Parliament’s power to amend any part of the Constitution, including Fundamental Rights.
- Shankari Prasad v. Union of India (1951) – Court held that constitutional amendments were valid even if they affected fundamental rights.
- Sajjan Singh v. State of Rajasthan (1965) – Reaffirmed this position.
During this phase, Parliament’s supremacy in constitutional amendments went largely unquestioned.
2. Turning Point: Rights Cannot Be Taken Away Easily
Golak Nath v. State of Punjab (1967)
This case changed course dramatically.
- The Supreme Court ruled that Parliament cannot amend Fundamental Rights, calling them “transcendental and immutable.”
- It marked the first high-point in judicial protection of individual rights.
Although Parliament disagreed and later amended the Constitution, this case triggered a deeper debate on constitutional limits.
3. The Basic Structure Emerges
Kesavananda Bharati v. State of Kerala (1973)
This is the most influential constitutional decision in Indian history.
Key outcomes:
- Parliament can amend the Constitution, but
- Cannot alter its “Basic Structure.”
The Court did not provide a fixed list but included:
- Rule of law
- Judicial review
- Separation of powers
- Federalism
- Supremacy of the Constitution
- Fundamental Rights
The “Basic Structure Doctrine” remains the cornerstone of Indian constitutional law.
4. Executive Power Put on Trial
ADM Jabalpur v. Shivkant Shukla (1976)
During the Emergency (1975–77), this case tested the limits of State power.
- The Court upheld that Fundamental Rights could be suspended during Emergency.
- It is widely regarded as one of the Court’s darkest moments, later admitted as a mistake.
In 2017, the Supreme Court expressly overruled the logic in this case, affirming that right to life cannot disappear even in an emergency.
5. PROTECTING THE RULE OF LAW
Indira Gandhi v. Raj Narain (1975)
Parliament passed laws to save the Prime Minister’s position after her election was challenged.
- The Supreme Court struck them down, saying even the highest executive office is not above judicial review.
- The Basic Structure Doctrine was applied directly to protect democratic accountability.
6. Strengthening the Judiciary’s Independence
The Judges’ Cases (1981–1998)
These cases redefined the process of judicial appointments:
- S.P. Gupta (1981) – Executive primacy
- Second Judges Case (1993) – Judicial primacy; creation of the Collegium system
- Third Judges Case (1998) – Detailed the functioning of the Collegium
This ensured independence of the judiciary from political influence, which the Court treated as part of the Basic Structure.
7. Rights Expanded through Interpretation
Maneka Gandhi v. Union of India (1978)
This case transformed Article 21.
- The Court held that “procedure established by law” must be fair, just, and reasonable, not merely legal.
- This broadened the scope of several rights, including due process, personal liberty, and procedural safeguards.
Other rights-inspired developments:
- Right to privacy declared a Fundamental Right in Puttaswamy (2017)
- LGBTQ+ rights recognized in Navtej Johar (2018)
- Right to dignity and autonomy strengthened in multiple judgments
These decisions show the Constitution’s ability to grow with changing society.
8. Federalism Reinforced and Clarified
S.R. Bommai v. Union of India (1994)
- The Court restricted misuse of President’s Rule, holding that federalism is part of the Basic Structure.
- Political disputes could not be settled by the Centre arbitrarily.
This judgment preserved the balance between the Union and the States.
For a deeper legal-historical perspective, Landmarks in Indian Legal and Constitutional History by V. D. Kulshreshtha provides an insightful survey of major developments and turning points. You can find it on EBC Webstore. (EBC Webstore)
