Golaknath Case, Background, Judgement, Impact

The Golaknath case (1967) centred on the Golaknath family, who challenged the Punjab Security and Land Tenures Act, which imposed limits on land ownership to facilitate redistribution. They contended that the Act violated their Fundamental Rights to property, asserting that such rights should be immune from legislative alteration and subject to judicial review under Article 13.

The Supreme Court ruled that Parliament lacks the authority to amend Fundamental Rights, introducing the doctrine of prospective overruling, reinforcing the inviolability of these rights, and establishing a foundation for the Basic Structure Doctrine in future jurisprudence.

Golaknath Case Background 

The case of I.C. Golaknath v. State of Punjab (1967) is a landmark Supreme Court decision concerning post-independence land reforms. It involved the Golaknath family, owners of over 500 acres in Jalandhar, Punjab. In 1953, the Punjab government passed the Punjab Security and Land Tenures Act, which limited individual land ownership to 30 standard acres (60 ordinary acres), with surplus land subject to state acquisition.

• This legislation formed part of a comprehensive governmental strategy aimed at redistributing land and enhancing agricultural productivity in a nation.
• The Golaknath family challenged the Act, contending that it infringed upon their constitutional rights to acquire and hold property, as guaranteed by Article 19(1)(f) (right to property) and Article 31 (protection against deprivation of property). 
• They sought judicial relief to declare the Act unconstitutional and contested the 17th Amendment, which had placed the Punjab Act in the Ninth Schedule of the Constitution, thereby rendering it immune to judicial scrutiny.

Golaknath Case Summary

The I.C. Golaknath and Ors. v. State of Punjab case reached the Supreme Court in 1965, prompting significant legal debate on the scope of Parliament's authority to amend Fundamental Rights. 

• The case primarily centred on whether constitutional amendments made under Article 368 could be classified as "law" under Article 13(3)(a), which declares that any law contravening Fundamental Rights is void. 
• This raised the crucial question of whether Parliament had the power to amend the Fundamental Rights enshrined in Part III of the Constitution. 
• The Court had to determine if such amendments could be restricted by Article 13, thereby examining the relationship between the amending power under Article 368 and the protective scope of Article 13.

Arguments of Petitioner

The Golaknath asserted that Fundamental Rights (FRs) are crucial for individual freedom and democracy, should be immune to legislative changes, require judicial review under Article 13, and were intended by the framers to be protected from arbitrary government action. 

• Inviolability of FRs: The Golaknaths argued that Fundamental Rights are essential to individual freedom and should be beyond legislative modification, as they underpin democracy and require protection from government overreach.
• Interpretation of Article 13: The petitioners claimed that any amendment affecting FRs should be seen as "law" under Article 13, making it subject to judicial review to prevent erosion of constitutional guarantees.
• Historical Context: The Golaknath noted that the framers of the constitution intended Fundamental Rights to be protected from arbitrary government action, citing Constituent Assembly debates that underscored the need to preserve individual rights.

Arguments of Respondent 

The respondents argued that Parliament has the sovereign authority to amend the Constitution, including Fundamental Rights, emphasizing the need for flexibility and citing past judgments to assert that such amendments are beyond judicial review.

• Parliamentary Sovereignty: The respondents asserted that Parliament has the sovereign power to amend any part of the Constitution, including Fundamental Rights, as flexibility is essential for governance and adapting to societal needs.
• Flexibility of Constitution: They maintained that amendments are crucial for addressing contemporary challenges and that a rigid Constitution would impede progress. They emphasized that Parliament's amendment power embodies democratic principles and reflects the public will.
• Judicial Limitations: The respondents argued that previous rulings had established constitutional amendments beyond judicial review, strengthening Parliament’s authority.
  • They cited Sankari Prasad Singh Deo v. Union of India (1952) and Gopalan v. State of Madras (1950) as supporting precedents.

Golaknath Case SC Judgement 

The Supreme Court's judgment in the Golaknath case limited Parliament's power to amend Fundamental Rights (FRs), subjected amendments under Article 368 to judicial review under Article 13(2), and introduced prospective overruling. The 6:5 judgment, led by Chief Justice K. Subba Rao, laid the foundation for the Kesavananda Bharati case and reinforced civil liberties in India.

• Parliamentary Power Limitation: The Supreme Court ruled that Parliament lacks the authority to amend FRs in Part III of the Constitution, establishing their inviolability and protection from amendments.
• Judicial Review Affirmation: The Court held that amendments under Article 368 are subject to Article 13(2), meaning any amendment violating FRs is void, reinforcing judicial protection of liberties.
• Majority Opinion: The Supreme Court bench delivered the decision with a 6:5 majority. Dissenting judges supported a more flexible view of parliamentary power.
• Prospective Overruling: The judgment introduced prospective overruling, applying the ruling to future cases without affecting previous amendments, and maintaining legal stability while upholding constitutional principles.
• Impact on Future Jurisprudence: The case laid the foundation for later rulings, notably influencing the 1973 Kesavananda Bharati case, which established the Basic Structure Doctrine that certain constitutional features cannot be altered.

Golaknath Case Impact on Constitution 

The impact of the Golaknath case limited Parliament's power to amend Fundamental Rights, established the Basic Structure Doctrine, reinforced judicial oversight, introduced prospective overruling, influenced key rulings, and declared amendments violating these rights void under Article 13(2).

• Limitation on Parliamentary Power: The Supreme Court ruled that Parliament lacks authority to amend Fundamental Rights under Article 368, reinforcing their inviolability and setting a precedent for legislative limitations.
• Judicial Review and Assertiveness: The judgment marked a shift toward stronger judicial oversight, asserting the courts’ role in protecting constitutional principles and reviewing legislative actions.
• Introduction of Doctrine of Prospective Overruling: The concept of prospective overruling was introduced, meaning the ruling would apply to future cases but not affect prior amendments, maintaining stability while upholding constitutional values.
• Influence on Subsequent Jurisprudence: The case has influenced later decisions, such as Minerva Mills (1980) and the Indira Gandhi Election case (1975), where the Basic Structure Doctrine was invoked to protect fundamental rights.
• Reinforcement of Fundamental Rights: By affirming that Fundamental Rights are beyond legislative reach, the case solidified their status as core elements of India's democratic framework and civil liberties.
• Legal Precedent for Future Amendments: The ruling set a precedent that amendments infringing on Fundamental Rights are void under Article 13(2), guiding future judicial decisions.

Golaknath Case FAQs

Q1. What is the Golaknath case? 

Ans. The Golaknath case is a landmark 1967 Supreme Court ruling in India that declared Parliament cannot amend Fundamental Rights enshrined in the Constitution.

Q2. What is the difference between Golaknath case and Kesavananda Bharati case?

Ans. The Golaknath case ruled that Parliament cannot amend Fundamental Rights, while the Kesavananda Bharati case affirmed that Parliament can amend the Constitution but not its basic structure.

Q3. What impact did the Golaknath case have on the Indian Constitution?

Ans. The Golaknath case reinforced the inviolability of Fundamental Rights and established judicial review over constitutional amendments, shaping future legal interpretations.

Q4. What was the judicial activism of Golaknath case?

Ans. Judicial activism in the Golaknath case saw the Supreme Court asserting its authority to review and limit Parliament's power to amend Fundamental Rights, safeguarding individual liberties.

Q5. Was the Golaknath ruling ever challenged or reversed?

Ans. Yes, the Golaknath ruling was effectively reversed by the Kesavananda Bharati case in 1973.