Thursday, 29 February 2024

KESAVANANDA BHARATHI CASE & LATER DEVELOPMENTS LEADING TO COLLEGIUM

 

The power to change the constitution lies in article 368.

The Constitution establishes the legislative authority of the central government and the state legislatures within their respective spheres of influence.

However, this authority is not unchecked and may be challenged in a court. The judiciary has the authority to determine whether a law is constitutionally valid and it can even abolish any statute that violates it. However, the courts have no power to tell the Government to pass any law, but they can advise the Government to do so.  

To prove its power, the Parliament has passed a number of constitutional modifications. The 24th constitutional amendment passed in 1971 modified article 368 & article 13 of the constitution allowing the Parliament to unilaterally amend fundamental rights without any check.

This amendment overturns the ruling of the SC in the Golaknath & Ors Vs the State of Punjab case in 1967 that Parliament cannot in any way limit fundamental rights. In the Golaknath case a bench of 11 justices of the SC heard the case.

The Golaknath family owned 500 acres of land in Punjab. The government brought in land ceiling and of the 500 acres, it was said that only 30 acres each can be held by the two Golaknath brothers, and some would go to the tenants and the rest of the land would be declared surplus, and would go to the state. The Land Ceiling Act was placed in schedule number 9 of the Constitution, making it unchallengeable in a court of law. The Golaknath family contested the matter on abrogation of fundamental rights in court and it finally reached the Supreme Court. A constitutional bench of 11 judges heard this case and ruled that the act was invalid by a thin majority of 6 to 5. The then Chief Justice was Koka Subbarao who headed the Bench.

To get around this judgment and assert its powers, the Constitution's 24th amendment was brought in by Indira Gandhi.  

The decision of the Golaknath case was reiterated in the Kesavananda Bharati Vs the state of Kerala case in 1970 where a 13-judge constitutional bench again by a thin majority of 7 to 6 ruled that Parliament cannot amend the basic character of the constitution. The then Chief Justice S.M.Sikri headed the bench.

However, in this judgment, the SC upheld the constitutionality of Article 31C, which implied that amendments seeking to implement the Directive principles that do not affect the basic structure of the constitution shall not be subjected to judicial review.

The very next day of this judgment by the SC, 3 of the senior most justices who favored the judgment Justices A N Grover, H.R.Khanna & J M Shelat have been bypassed by Indira Gandhi and Justice AN Ray the 4th senior most after them who opposed the majority judgment was appointed as the Chief Justice of India. After this was done, all the 3 bypassed justices as well as the CJ Justice S.M. Sikri who headed the bench resigned.   

Perhaps looking to the attempts of the state to gain absolute and unquestionable powers over the judiciary, the judiciary slowly brought in the collegium system. Such a system was not enshrined anywhere in the constitution; nevertheless perhaps giving unbridled power to the center can end in a disaster for the country. The Parliament certainly has the power to legislate, but if that power is made absolute and unquestionable then one day, a one-sided dictatorship may come in and snuff out Democracy in the country. If the judiciary is in the hands of the Government then one cannot even oppose it on anything.

The Constitution certainly does not give such unbridled power to anyone. Considering this aspect perhaps a Collegium system is not bad for the country. But that system has to be refined to purge it of its current defects. Otherwise, it is worse than political leaders appointing it.  

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