MPPSC 2026 Prelims Paper-I · Question 18 of 100

Correct — D, the Shankari Prasad case (Shankari Prasad Singh Deo v. Union of India, 1951). It was the first time the constitutional validity of an amendment — the First Constitutional Amendment Act, 1951, which had curtailed the right to property — was challenged before the Supreme Court. The Court upheld Parliament's power: it held that the word 'law' in Article 13 means ordinary law made under legislative powers, not a constitutional amendment made under Article 368, so Parliament could amend even the Fundamental Rights. That ruling opened the amendment-power line of cases which runs through Sajjan Singh (1965), Golaknath (1967) and Kesavananda Bharati (1973).

• (a)The Kesavananda Bharati Case — 1973 — the culmination of this line, not its beginning. It overruled Golaknath, allowed Parliament to amend any part of the Constitution, but laid down the 'basic structure' doctrine as an outer limit.
• (b)The Golaknath Case — 1967 — the reversal, not the first challenge. The Supreme Court here held that Parliament could NOT abridge or take away Fundamental Rights, treating an amendment as 'law' under Article 13. Parliament responded with the 24th Amendment Act, 1971.
• (c)The Champakam Dorairajan Case — 1951, and it does predate Shankari Prasad in the same year — but it was not a challenge to the amending power at all. State of Madras v. Champakam Dorairajan struck down a caste-based communal order in college admissions and held that Fundamental Rights prevail over Directive Principles; it was the case that prompted the First Amendment, which Shankari Prasad then challenged.

Article 368 gives Parliament the power to amend the Constitution, but says nothing about whether Fundamental Rights are off-limits. Four decades of litigation settled that question. Shankari Prasad (1951) and Sajjan Singh (1965) said Parliament may amend Fundamental Rights; Golaknath (1967) said it may not; Kesavananda Bharati (1973) struck the balance still in force — Parliament may amend any provision, including a Fundamental Right, provided it does not damage or destroy the basic structure of the Constitution.

The question rewards ordering, not just recognition. Champakam Dorairajan is the deliberate bait because it is also a 1951 case — but it was a challenge to a State's communal G.O., not to an amendment. Anchor the chain by its trigger: Champakam (1951) → First Amendment, 1951 → challenged in Shankari Prasad (1951) → Sajjan Singh (1965) → Golaknath (1967) → 24th Amendment (1971) → Kesavananda Bharati (1973).

• Shankari Prasad Singh Deo v. Union of India (1951) — the first challenge to a constitutional amendment (the First Amendment Act, 1951)
• The Court held 'law' in Article 13 does not include a constitutional amendment under Article 368
• Sajjan Singh v. State of Rajasthan (1965) reaffirmed that position while considering the 17th Amendment
• Golaknath v. State of Punjab (1967) reversed it, holding Fundamental Rights beyond the amending power; Parliament replied with the 24th Amendment Act, 1971
• Kesavananda Bharati v. State of Kerala (1973) overruled Golaknath and propounded the basic structure doctrine
• The First Amendment Act, 1951 also inserted the Ninth Schedule and Article 15(4)

• Picking Kesavananda Bharati because it is the most famous case — the question asks for the FIRST challenge, not the decisive one
• Picking Champakam Dorairajan because it is also from 1951 — it challenged a State order on college admissions, not an amendment
• Confusing Golaknath (limits the amending power) with Kesavananda Bharati (restores it, subject to the basic structure)

MPPSC and UPSC both ask this as case-to-doctrine matching or as an ordering question. Lock four pairs: Shankari Prasad = first challenge; Golaknath = FRs unamendable; Kesavananda = basic structure; Minerva Mills = limited amending power is itself basic structure.

• practice — not a real PYQ

  The doctrine of the 'basic structure' of the Constitution was propounded by the Supreme Court in:

  • (a)Shankari Prasad v. Union of India (1951)
  • (b)Golaknath v. State of Punjab (1967)
  • (c)Kesavananda Bharati v. State of Kerala (1973)
  • (d)Minerva Mills v. Union of India (1980)

  Answer(c) Kesavananda Bharati v. State of Kerala (1973) — Minerva Mills later applied and strengthened the doctrine, but did not originate it.

• practice — not a real PYQ

  Which Constitutional Amendment Act was enacted primarily to nullify the Supreme Court's ruling in the Golaknath case?

  • (a)17th Amendment Act, 1964
  • (b)24th Amendment Act, 1971
  • (c)42nd Amendment Act, 1976
  • (d)44th Amendment Act, 1978

  Answer(b) 24th Amendment Act, 1971 — it declared that Parliament may amend any part of the Constitution, including Fundamental Rights, and that Article 13 does not apply to amendments made under Article 368.