The case of Golaknath v. State of Punjab, decided in 1967, is a landmark judgment of the Supreme Court of India that had a profound impact on the Constitution of India, particularly on the power of Parliament to amend the Constitution.
The Golaknath family owned over 500 acres of farmland in Punjab. However, the Punjab Security and Land Tenures Act restricted the amount of land a family could own to 30 standard acres. Excess land was to be declared 'surplus' and redistributed. The Golaknath family challenged the constitutionality of this Act.
The key legal issue revolved around whether Parliament had the power to amend the Constitution so as to abridge any of the Fundamental Rights enshrined in Part III of the Constitution. This issue arose in the context of the First, Fourth, and Seventeenth Amendments to the Constitution, which had been enacted to implement land reform laws and were challenged by the petitioners.
Supreme Court Judgment:
- The Supreme Court, in a narrow 6-5 decision, ruled that Parliament does not have the power to amend the Constitution in a way that takes away or abridges the Fundamental Rights outlined in Part III.
- The Court overruled its earlier decisions in the Sankari Prasad and Sajjan Singh cases, where it had held that Parliament had wide powers to amend any part of the Constitution, including Fundamental Rights.
- The judgment was based on the premise that the Constitution had given a transcendental position to Fundamental Rights, and they were immutable to the extent of being immune to the amending power of Parliament.
Significance of the Judgment:
1. Constitutional Amendment as a 'Law': The Court held that an amendment under Article 368 is a 'law' within the meaning of Article 13(2) and therefore, if it violates any Fundamental Right, it may be declared void.
2. Inviolability of Fundamental Rights: This judgment established the doctrine that Fundamental Rights cannot be abridged, taken away, or abrogated by Parliament through constitutional amendments.
3. Trigger for the Basic Structure Doctrine: Although the Golaknath case did not explicitly mention the 'Basic Structure' doctrine, it set the stage for its development in the subsequent Kesavananda Bharati case.
- The ruling in the Golaknath case prompted a significant constitutional response. In 1971, the 24th Amendment to the Constitution was passed, which amended Article 13 and Article 368 to expressly exclude constitutional amendments from being "law" within the meaning of Article 13, thereby aiming to remove the restriction that the Golaknath case had placed on Parliament's amending power.
- The 25th Amendment, enacted in the same year, was another response to this judgment, aiming to immunise land reform laws from judicial review.
The Golaknath v. State of Punjab case is a seminal judgment in the annals of Indian constitutional law, representing a critical moment in the evolving relationship between the judiciary and the legislature in India. Its implications continue to influence the constitutional discourse around the power of parliamentary amendments and the sanctity of Fundamental Rights.
For more detailed information, you can refer to the sources like [Wikipedia](https://en.wikipedia.org/wiki/Golaknath_v._State_of_Punjab) and [Indian Kanoon](https://indiankanoon.org/doc/1306515/).