Sajjan Singh v. State of Rajasthan
Context: The Sajjan Singh v. State of Rajasthan (1964) case upheld Parliament's authority to amend the Constitution, including fundamental rights, reinforcing land ceiling laws, and laying the groundwork for the basic structure doctrine.
Important Pointers:
► Year of Judgment: 1965 ► Bench Strength: 5 judges (majority 3:2) ► Issue: Whether constitutional amendments (like the 17th Amendment) can be challenged for violating Fundamental Rights ► Petitioner’s Argument: The 17th Constitutional Amendment infringed upon the right to property under Article 31 ► Key Legal Provision in Question: Article 368 – Power to amend the Constitution ► Majority View: Parliament can amend Fundamental Rights under Article 368; Amendments are not “law” under Article 13(2)
► Dissenting Opinion: Warned against unlimited parliamentary power; Justice Mudholkar hinted at the “Basic Structure” doctrine, which was later upheld in Kesavananda Bharati (1973) ► Significance: Precursor to the landmark Kesavananda Bharati case (1973); First judicial doubt cast on Parliament’s unlimited amending power
► Outcome: Petition dismissed; 17th Amendment upheld.