Match List-A with List-B and identify the correct answer from the codes given below : List-A (Case) – List-B (Amendment challenged) A. Indira Gandhi V. Raj Narain – i. 42nd Amendment B. Minerva Mills V. Union of India – ii. 52nd Amendment C. Kihoto Hollohan V. Zachillu – iii. 39th Amendment D. P. Sambamurthy V. State of A.P. – iv. 32nd Amendment Codes :

Correct — option (4), A-iii, B-i, C-ii, D-iv.

A. Indira Gandhi v. Raj Narain — 39th Amendment. The Thirty-ninth Amendment Act, 1975 inserted Article 329A, a special provision on election disputes of the Prime Minister and the Speaker. The Supreme Court decided the case on 7 November 1975 and struck down clause (4) of that article.

B. Minerva Mills v. Union of India (1980) — 42nd Amendment. The Court declared invalid section 4 (which widened Article 31C) and section 55 (which added clauses (4) and (5) to Article 368, barring courts from questioning amendments).

C. Kihoto Hollohan (1992) — 52nd Amendment. That Act of 1985 added the Tenth Schedule on defection. Paragraph 7 was held invalid for want of ratification by the States.

D. P. Sambamurthy v. State of A.P. — 32nd Amendment. That Act of 1973 inserted Article 371D; the Court declared clause (5), with its proviso letting the State Government modify or annul tribunal orders, unconstitutional.

Dates alone narrow it down: a 1975 case cannot challenge an amendment of 1976 or 1985.

Why the others are wrong

• (1)
  A-i, B-iii, C-iv, D-ii — Every pair here is wrong. Pairing Indira Gandhi v. Raj Narain with the 42nd Amendment fails on dates alone: the case was decided in 1975, and the Forty-second Amendment Act is of 1976.

  Minerva Mills is paired with the 39th instead of the 42nd, and the anti-defection case with the 32nd instead of the 52nd, which added the Tenth Schedule.

• (2)
  A-ii, B-iii, C-i, D-iv — Only D-iv, Sambamurthy with the 32nd Amendment, is right. Raj Narain (1975) cannot concern the 52nd Amendment, which came in 1985.

  Minerva Mills challenged the 42nd, not the 39th, and Kihoto Hollohan is the anti-defection case on the 52nd Amendment's Tenth Schedule, not a challenge to the 42nd.

• (3)
  A-iv, B-ii, C-iii, D-i — All four pairs are wrong. Raj Narain concerned the 39th Amendment, not the 32nd, and Minerva Mills (1980) cannot concern the 52nd Amendment of 1985.

  Kihoto Hollohan is not about the 39th, and Sambamurthy is not about the 42nd; it struck down clause (5) of Article 371D, inserted by the 32nd Amendment.

Since Kesavananda Bharati (1973), the Supreme Court has held that Parliament's power to amend the Constitution under Article 368 does not extend to destroying its basic structure. Each case in this question applied that limit to a particular amendment.

Raj Narain tested an amendment that shielded the Prime Minister's election from the courts. Minerva Mills tested an amendment that tried to make the amending power itself unlimited and beyond review.

Kihoto Hollohan upheld the anti-defection law but held one paragraph invalid for a procedural defect — it needed ratification by the States. Sambamurthy struck down the State Government's power to modify or annul an administrative tribunal's orders.

Key facts

• Indira Gandhi v. Raj Narain was decided on 7 November 1975; it concerned the Thirty-ninth Amendment Act, 1975, which inserted Article 329A.
• Minerva Mills (1980) declared invalid sections 4 and 55 of the Forty-second Amendment Act, 1976.
• The Tenth Schedule (anti-defection) was added by the Fifty-second Amendment Act, 1985, with effect from 1 March 1985.
• In Kihoto Hollohan, paragraph 7 of the Tenth Schedule was declared invalid for want of ratification under the proviso to Article 368(2).
• In P. Sambamurthy, the Supreme Court declared clause (5) of Article 371D, inserted by the Thirty-second Amendment Act, 1973, unconstitutional.

Common traps

• A case cannot challenge an amendment made after it. Check years before memory: 1975 rules out the 42nd (1976) and 52nd (1985) for Raj Narain.
• Kihoto Hollohan did not strike down the anti-defection law; it upheld the Tenth Schedule and held only paragraph 7 invalid.
• Minerva Mills and Kesavananda Bharati are both basic-structure cases, but only Minerva Mills tested the Forty-second Amendment, which came three years after Kesavananda.

UnlockIAS will link similar questions from RAS Pre 2021, 2018 and 2013 here once those papers are published on this site.

• practice — not a real PYQ

  In which case did the Supreme Court declare invalid clauses (4) and (5) of Article 368, which had been inserted by the Forty-second Amendment Act, 1976?

  • (a)Kesavananda Bharati v. State of Kerala
  • (b)Minerva Mills v. Union of India
  • (c)Golaknath v. State of Punjab
  • (d)S. R. Bommai v. Union of India
  Answer(2) — Minerva Mills (1980) declared section 55 of the Forty-second Amendment, which added those clauses, invalid. Option (1), Kesavananda Bharati (1973), came before the 1976 Act. Option (3), Golaknath (1967), also predates it. Option (4), S. R. Bommai (1994), concerned President's Rule under Article 356.
• practice — not a real PYQ

  The Tenth Schedule, containing provisions on disqualification on the ground of defection, was added to the Constitution by the:

  • (a)Forty-second Amendment Act, 1976
  • (b)Forty-fourth Amendment Act, 1978
  • (c)Fifty-second Amendment Act, 1985
  • (d)Sixty-first Amendment Act, 1988
  Answer(3) — The Fifty-second Amendment Act, 1985 added the Tenth Schedule. Option (1) is the Emergency-era amendment tested in Minerva Mills. Option (2) reversed several Emergency-era changes. Option (4) lowered the voting age from 21 to 18.