1. What is the I.C. Golaknath vs. State of Punjab Case all about?
The I.C. Golaknath vs. State of Punjab case in 1967 is a landmark judgement that addressed the power of the Parliament to amend the Constitution, particularly in relation to Fundamental Rights. The case arose when the Golaknath family challenged the validity of the Punjab Security of Land Tenures Act, 1953, which restricted their rights to hold and acquire property. The primary issue was whether Parliament could amend any part of the Constitution, including Fundamental Rights.
2. Facts of the I.C. Golaknath vs. State of Punjab Case Relevant for UPSC
- Parties Involved: I.C. Golaknath and others (petitioners) vs. State of Punjab (respondent).
- Legal Questions:
- Whether Parliament has the power to amend Fundamental Rights under Part III of the Constitution.
- The extent of the amending power conferred by Article 368 of the Indian Constitution.
- Noteworthy Events:
- The Golaknath family owned substantial agricultural land, which was affected by the Punjab Security of Land Tenures Act.
- They challenged the Act, arguing that it violated their Fundamental Rights to property guaranteed under Article 19(1)(f) and Article 31.
- The case escalated to the Supreme Court, questioning the extent of Parliament’s power to amend the Constitution.
3. What are the Major Judgements/Changes Brought by I.C. Golaknath vs. State of Punjab Case?
The Supreme Court delivered a historic judgement with profound implications:
- The Court ruled that Parliament does not have the power to amend Fundamental Rights. Any amendment that abridges or takes away a Fundamental Right is unconstitutional.
- The Court held that the amending power under Article 368 is subject to judicial review and cannot be used to alter Fundamental Rights.
- This judgement imposed a significant limitation on Parliament’s power to amend the Constitution, ensuring the protection of Fundamental Rights.
4. What was the Impact of I.C. Golaknath vs. State of Punjab Case on Indian Constitution?
- Protection of Fundamental Rights: The judgement ensured that Fundamental Rights are inviolable and cannot be amended or abrogated by Parliament, reinforcing the sanctity of these rights.
- Judicial Review of Constitutional Amendments: It established the principle that constitutional amendments are subject to judicial review, providing a check on Parliament’s amending power.
- Constitutional Stability: The ruling emphasized the stability and supremacy of the Constitution, ensuring that its core principles, especially Fundamental Rights, are preserved.
5. Was this I.C. Golaknath vs. State of Punjab Case Challenged/Reversed in Future?
The principles established in the Golaknath case were later revisited in the landmark Kesavananda Bharati vs. State of Kerala (1973) case. The Kesavananda Bharati case introduced the Basic Structure Doctrine, allowing Parliament to amend the Constitution but not alter its basic structure, thus modifying the rigid stance of the Golaknath judgement.
6. Doctrines/Theories/New Concepts
- Doctrine of Prospective Overruling: The Golaknath case introduced the concept of prospective overruling, where the judgement would apply to future cases and not invalidate past amendments. This doctrine aimed to prevent legal chaos and maintain continuity in the application of laws.
- Inviolability of Fundamental Rights: The case underscored the principle that Fundamental Rights cannot be amended or abrogated by Parliament, ensuring their protection and stability within the constitutional framework.