I.C. Golaknath and Ors. v. State of Punjab and Anrs.
Overview
A landmark 1967 case decided by the Supreme Court of India.
Full case name: I.C. Golaknath and Ors. vs State of Punjab and Anrs.
Decided on February 27, 1967.
The case addressed the issue of whether the Parliament could amend the Constitution to curtail Fundamental Rights.
Facts of the Case
The Golaknath family owned over 500 acres of farmland in Jalandhar, Punjab.
The 1953 Punjab Security and Land Tenures Act limited land holdings, declaring surplus land to be redistributed.
The family challenged the Act, claiming it violated their constitutional rights under Articles 19(1)(f), 19(1)(g), and 14.
The Seventeenth Amendment, placing the Punjab Act in the Ninth Schedule, was also challenged.
Key Issues
Whether a constitutional amendment is "law" under Article 13(3)(a) of the Constitution.
Whether Fundamental Rights can be amended.
Judgment
The Supreme Court overturned its previous decisions, ruling Parliament cannot amend Fundamental Rights.
A narrow majority (6:5) held that Article 368 amendments are "law" under Article 13(3).
Constitutional amendments cannot contravene Fundamental Rights in Part III of the Constitution.
Doctrine of Prospective Overruling
Introduced by Chief Justice Koka Subba Rao in this case.
Originates from American jurisprudence, allowing new rules for future cases while applying old rules to existing cases.
Used to uphold the Seventeenth Amendment, despite its abridgement of Fundamental Rights.
Minority View
Opposed the doctrine of prospective overruling.
Argued that judicial declarations should apply from the law's effective date, not prospectively.
Significance
Prompted the 24th Amendment in 1971, asserting Parliament's power to amend any part of the Constitution, including Fundamental Rights.
The doctrine of basic structure established in Kesavananda Bharati v. State of Kerala (1973) later overruled Golaknath.
Kesavananda ruled that amendments affecting the Constitution's basic structure are void.
Related Cases
Kesavananda Bharati v. State of Kerala (1973): Established the basic structure doctrine.
Conclusion
The Golaknath case was pivotal in shaping the constitutional law in India, reinforcing the protection of Fundamental Rights against parliamentary amendments.