👉 Judicial Review in India: Scope, Importance, Landmark Cases & Limitations

Judicial Review in India: Scope, Importance, Landmark Cases, and Limitations

Introduction

Judicial Review is a fundamental principle of constitutional governance that empowers the judiciary to examine the constitutionality of legislative enactments and executive orders. In India, it serves as a crucial mechanism to uphold the supremacy of the Constitution, protect the fundamental rights of citizens, and maintain the delicate balance of power among the three organs of the state: the Legislature, the Executive, and the Judiciary. Though the term "Judicial Review" is not explicitly mentioned in the Indian Constitution, its essence is embedded in various articles, making it an indispensable feature of India's democratic framework. This comprehensive note delves into the historical context, constitutional provisions, scope, significance, limitations, and landmark judgments associated with judicial review in India, also drawing comparisons with global models where relevant.

1. Historical and Constitutional Background

The concept of judicial review, as understood today, originated in the United States with the landmark case of Marbury v. Madison (1803), where Chief Justice John Marshall asserted the Supreme Court's power to declare an act of Congress unconstitutional. India, while drafting its Constitution, drew inspiration from various sources, including the American Constitution, and adapted the principle of judicial review to suit its unique constitutional and societal fabric.

1.1. Pre-Constitutional Influences

Even before the adoption of the Constitution, rudimentary forms of judicial oversight existed. The Government of India Act, 1935, for instance, established a Federal Court with limited powers of interpretation and review, laying some groundwork for judicial scrutiny. However, a robust system of judicial review truly began with the enforcement of the Indian Constitution.

1.2. Constituent Assembly Debates

The framers of the Indian Constitution, particularly Dr. B.R. Ambedkar, recognized the vital role of an independent judiciary with the power of judicial review. While discussing Article 32 (Right to Constitutional Remedies), Ambedkar famously described it as the "heart and soul of the Constitution," emphasizing its importance in enforcing fundamental rights. The consensus was to create a strong judiciary capable of safeguarding the Constitution against potential legislative and executive overreach.

2. Key Provisions & Articles

The power of judicial review in India is explicitly conferred upon the Supreme Court and High Courts through various constitutional articles. These provisions enable the judiciary to act as the guardian of the Constitution and the protector of fundamental rights.

3. Scope of Judicial Review in India

The scope of judicial review in India is broad and encompasses various actions of the legislative and executive branches. The courts can scrutinize laws, policies, and administrative decisions on specific grounds to ensure adherence to constitutional provisions.

3.1. What can be subjected to Judicial Review?

• Legislative Actions: Laws passed by the Parliament and State Legislatures, including ordinary laws, constitutional amendments, ordinances (Articles 123 & 213), and delegated legislation (rules, regulations, bye-laws).
• Executive Actions: Administrative decisions, orders, notifications, and policies of the Central and State governments, and other public authorities.
• Constitutional Amendments: Post-1973 (Kesavananda Bharati case), constitutional amendments can be reviewed if they violate the "Basic Structure" of the Constitution.
• 9th Schedule Laws: After the I.R. Coelho case (2007), laws placed in the Ninth Schedule post-April 24, 1973, are open to judicial scrutiny if they violate Fundamental Rights or the Basic Structure.
• Judicial Actions (limited): Higher courts can review the decisions of lower courts and tribunals, and the Supreme Court can review its own judgments (Article 137).

3.2. Grounds for Judicial Review

The constitutional validity of a legislative enactment or an executive order can be challenged in the Supreme Court or a High Court on the following grounds:

1. Violation of Fundamental Rights (Part III of the Constitution): If a law infringes upon any of the fundamental rights guaranteed to citizens, it can be declared unconstitutional.
2. Lack of Legislative Competence: If the enacting body (Parliament or State Legislature) has exceeded its constitutional powers by legislating on a subject outside its allocated list (Union List, State List, Concurrent List as per the Seventh Schedule).
3. Repugnancy to Constitutional Provisions: If the law or action is inconsistent with any other provisions of the Constitution, even if it doesn't directly violate fundamental rights.

3.3. "Procedure Established by Law" vs. "Due Process of Law"

A key distinction that impacts the scope of judicial review in India, compared to the USA, is the phrase "procedure established by law" in Article 21 (Protection of Life and Personal Liberty) versus the American "due process of law."

• "Procedure Established by Law" (India): This means that the judiciary can examine a law or executive order primarily on substantive grounds (i.e., whether it is within the legislative competence and does not violate other constitutional provisions like Fundamental Rights). It does not, in its original interpretation, allow courts to delve into the "fairness," "reasonableness," or "policy implications" of the law itself, only whether the established legal procedure for its enactment was followed. However, the interpretation has expanded significantly, especially after the Maneka Gandhi case (1978), where the Supreme Court read Articles 14 and 19 into Article 21, asserting that the "procedure" must be "just, fair, and reasonable," thereby moving closer to the "due process" standard in practice.
• "Due Process of Law" (USA): This provides a wider scope to the US Supreme Court. It allows the Court to declare laws void not only on substantive grounds but also on procedural grounds, examining the "reasonableness," "fairness," and "justness" of the law's content and its application.

Visual: Spectrum of Judicial Review (Conceptual)

|-----------------------------------------------------------------------|
|  Procedure Established by Law (Narrower Scope)   <----->   Due Process of Law (Wider Scope) |
|  Focus: Is the law validly made? Does it violate *explicit* provisions? | Focus: Is the law validly made? Is it *fair, just, and reasonable*? |
|  (Traditional Indian Approach, Evolving Post-Maneka Gandhi)             | (American Approach)                                                    |
|-----------------------------------------------------------------------|

4. Importance of Judicial Review

Judicial review is a cornerstone of Indian democracy, essential for its functioning and for maintaining the rule of law. Its significance can be understood through several key roles:

• Upholds Constitutional Supremacy: It reinforces the principle that the Constitution is the supreme law of the land, ensuring that all legislative and executive actions conform to its spirit and provisions.
• Protects Fundamental Rights: Judicial review acts as a safeguard against government actions that infringe upon the fundamental rights and liberties of individuals guaranteed by the Constitution, serving as the guardian of these rights.
• Maintains Federal Equilibrium: It helps resolve conflicts over the distribution of powers between the Union and the States, ensuring that both levels of government operate within their constitutional limits.
• Checks and Balances: By exercising judicial review, courts serve as a crucial check on the powers of the legislative and executive branches, preventing any single branch from becoming too dominant or abusing its authority.
• Prevents Misuse of Powers: It helps in curbing arbitrary or tyrannical rule by ensuring that the legislature and executive do not overstep their constitutional boundaries.
• Promotes Rule of Law: It ensures that governmental actions are based on law, not on arbitrary discretion, thereby strengthening the rule of law.
• Adapts the Constitution to Changing Needs: Through its interpretative function, the judiciary can adapt the Constitution to new social, economic, and political realities, ensuring its relevance over time.

5. Limitations of Judicial Review

Despite its wide scope and critical importance, judicial review in India is not without its limitations, which are necessary to maintain the balance of power and prevent judicial overreach.

• Separation of Functions (not strict Separation of Powers): India follows a system of 'separation of functions' rather than a strict 'separation of powers' as in the USA. While the judiciary acts as a check, it generally refrains from interfering in the day-to-day functioning of the other two branches, respecting their constitutional domains.
• Policy Decisions: Courts generally do not interfere with executive policy decisions unless they are found to be arbitrary, unreasonable, or in violation of the Constitution. They do not substitute their own judgment for that of the executive in matters of policy.
• Doctrine of "Strict Necessity": Courts often exercise self-restraint, employing the doctrine of "strict necessity," meaning they will only declare a law unconstitutional if there is no other remedy available or a substantial reason to do so, and only when absolutely essential to decide the case at hand.
• Immunities and Privileges: The Constitution grants certain immunities and privileges to the President, Governors, and judges of higher courts, which limit the scope of judicial review concerning their official acts, unless they have acted in their personal capacity or in specific constitutionally defined circumstances.
• Lack of Power to Make Laws: Unlike the US Supreme Court, which sometimes creates "judge-made laws," the Indian judiciary, when striking down a law, generally leaves the matter of creating a new law to the legislative branch, adhering to its interpretative role.
• Judicial Overreach/Activism Concerns: While judicial activism has expanded the scope of rights, it also faces criticism for sometimes encroaching upon the legislative or executive domains, leading to debates about judicial overreach. This is an inherent tension in the exercise of judicial review.
• Emergency Provisions: During a Proclamation of Emergency, some fundamental rights can be suspended, which historically impacted the scope of judicial review, though post-44th Amendment, Articles 20 and 21 cannot be suspended, and the proclamation itself can be judicially reviewed.

6. Judicial Interpretations and Landmark Cases

The journey of judicial review in India is largely defined by a series of landmark judgments that have progressively shaped its contours and firmly established its position as a basic feature of the Constitution.

6.1. Early Cases Defining Parliament's Amending Power

• Shankari Prasad v. Union of India (1951): This was the first major case challenging a constitutional amendment (the 1st Amendment, which added the Ninth Schedule). The Supreme Court held that the Parliament's power to amend the Constitution under Article 368 included the power to amend Fundamental Rights, and such amendments were not "laws" under Article 13, thus not subject to judicial review for violating Fundamental Rights.
• Sajjan Singh v. State of Rajasthan (1965): The Supreme Court reiterated its stance from Shankari Prasad, holding that constitutional amendments were outside the purview of Article 13.
• Golaknath v. State of Punjab (1967): In a significant shift, a larger bench of the Supreme Court, by a narrow majority, reversed the previous judgments. It held that Fundamental Rights were "transcendental and immutable" and could not be amended by Parliament, even through a constitutional amendment under Article 368. This decision created a deadlock, curtailing Parliament's power to amend Part III of the Constitution.

6.2. The Basic Structure Doctrine and its Evolution

The Golaknath judgment led Parliament to enact the 24th, 25th, and 29th Amendments to reassert its amending power and overcome the restrictions imposed by the Court. These amendments were challenged in the most significant constitutional case in India's history.

• Kesavananda Bharati v. State of Kerala (1973): This landmark case involved a 13-judge bench, the largest ever, which delivered a fragmented verdict. By a 7:6 majority, the Supreme Court overruled Golaknath, upholding the validity of the 24th Amendment and reaffirming Parliament's power to amend any part of the Constitution, including Fundamental Rights, under Article 368.

  • The Basic Structure Doctrine: Crucially, the Court introduced the "Basic Structure Doctrine," holding that while Parliament has the power to amend the Constitution, it cannot alter or destroy its "basic structure" or "essential features."
  • Judicial Review as a Basic Feature: The Court explicitly stated that judicial review itself is an integral part of the basic structure of the Constitution and cannot be taken away by Parliament through constitutional amendments.
  • Though the Court did not exhaustively define "basic structure," it listed certain principles as examples, including the supremacy of the Constitution, the republican and democratic form of government, the secular character of the Constitution, separation of powers, and the federal character of the Constitution.

• Indira Gandhi v. Raj Narain (1975) (Election Case): This case further solidified the Basic Structure Doctrine. The Supreme Court invoked the doctrine to strike down Clause (4) of Article 329A, inserted by the 39th Amendment, which placed the election disputes involving the Prime Minister and the Speaker outside the purview of all courts. The Court held that this provision was beyond Parliament's amending power as it affected the basic structure of the Constitution, including the principle of free and fair elections and judicial review.

• Minerva Mills v. Union of India (1980): This case involved a challenge to parts of the 42nd Amendment (1976), enacted during the Emergency, which attempted to drastically curtail judicial review.

  • The 42nd Amendment had inserted Clauses (4) and (5) into Article 368, declaring that no constitutional amendment could be questioned in any court and that there would be no limitation on Parliament's constituent power.
  • The Supreme Court, in Minerva Mills, struck down these clauses as unconstitutional, reaffirming that judicial review is a basic feature of the Constitution.
  • The Court also held that the harmony and balance between Fundamental Rights and Directive Principles of State Policy is an essential feature of the Constitution and cannot be disturbed.

6.3. Review of President's Rule

• S.R. Bommai v. Union of India (1994): This landmark judgment significantly impacted the judicial review of the President's power to impose President's Rule under Article 356. The Supreme Court held that the imposition of President's Rule is not beyond judicial review. It can be challenged on grounds of mala fide intent or extraneous considerations. The Court stipulated that the President's satisfaction must be based on relevant material, and if the proclamation is found to be unconstitutional, the dismissed state government can be reinstated. This case placed substantive limits on the executive's power under Article 356 and enhanced judicial oversight.

6.4. Judicial Review of the Ninth Schedule

• I.R. Coelho v. State of Tamil Nadu (2007): The Ninth Schedule was added by the 1st Amendment (1951) to protect certain laws (primarily related to land reforms) from judicial challenge, particularly on the ground of violating Fundamental Rights.
  • The I.R. Coelho case addressed whether laws placed in the Ninth Schedule could be judicially reviewed. A nine-judge bench unanimously held that laws placed in the Ninth Schedule after April 24, 1973 (the date of the Kesavananda Bharati judgment), are open to judicial scrutiny if they violate Fundamental Rights or the Basic Structure of the Constitution.
  • The Court established a two-fold test: whether the law violates fundamental rights and whether the violation impacts the basic structure. It reiterated that judicial review is an integral part of the basic structure and no law can be shielded from it.

6.5. Expanding Rights and Judicial Activism

• Maneka Gandhi v. Union of India (1978): This case significantly expanded the interpretation of Article 21 (Right to Life and Personal Liberty). The Supreme Court held that the "procedure established by law" must be "just, fair, and reasonable" and not arbitrary. It effectively read Articles 14 (Equality before Law) and 19 (Freedoms) into Article 21, establishing a nexus between these fundamental rights. This expanded interpretation provided broader grounds for judicial review of laws impacting personal liberty.
• Vishaka v. State of Rajasthan (1997): This case exemplified judicial activism. In the absence of specific legislation, the Supreme Court laid down guidelines for preventing sexual harassment of women at the workplace, recognizing it as a violation of fundamental rights (Articles 14, 15, 21). These guidelines had the force of law until Parliament enacted the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013.

7. Current Relevance, Debates, and Evolving Interpretations

Judicial review remains an active and dynamic feature of Indian polity. In recent times, its exercise has continued to evolve, leading to ongoing debates.

7.1. Judicial Activism vs. Judicial Restraint

• Judicial Activism: Refers to the judiciary's proactive role in protecting rights and promoting social justice, sometimes by stepping into policy-making or legislative domains when the executive or legislature fail to act. Cases like Vishaka and those related to environmental protection or prison reforms are often cited as examples.
• Judicial Restraint: Advocates for the judiciary to defer to the legislative and executive branches in policy matters, intervening only when there is a clear constitutional violation. It emphasizes respecting the separation of powers.

7.2. Judicial Overreach

Concerns about "judicial overreach" arise when critics argue that the judiciary is exceeding its legitimate authority and encroaching upon the functions of the other branches. This debate often surfaces in matters of environmental policy, economic reforms, or public appointments. The Supreme Court itself has, at times, acknowledged the need for self-correction and adherence to judicial discipline.

7.3. Evolving Interpretations

The judiciary continually interprets constitutional provisions in light of contemporary challenges. For instance:

• Digital Rights: The right to privacy (Puttaswamy case) and internet access are evolving areas where judicial review plays a role in balancing state power with individual liberties in the digital age.
• Environmental Jurisprudence: The courts have significantly expanded the scope of Article 21 to include the right to a clean environment, leading to judicial interventions in environmental protection and sustainable development.
• Social Justice: Judicial review continues to be instrumental in ensuring the implementation of affirmative action policies and addressing issues of discrimination and inequality.

8. Comparative Analysis: India vs. USA

While India borrowed the concept of judicial review from the USA, there are fundamental differences in their application and scope.

9. Conclusion & Summary

Judicial review is an indispensable and dynamic feature of the Indian Constitution, acting as the ultimate guardian of constitutional values, individual liberties, and the democratic framework. Rooted in explicit constitutional provisions and evolved through a series of transformative judgments, it has ensured that no organ of the state can claim absolute power. While its exercise necessitates a delicate balance between judicial activism and restraint, its fundamental role in upholding the rule of law and the supremacy of the Constitution remains unchallenged. The Basic Structure Doctrine, born from judicial review, stands as a unique Indian contribution, firmly limiting Parliament's amending power and ensuring the Constitution's core identity endures.

Key Takeaways:

• Judicial Review: Power of higher courts to test the legality of governmental actions against the Constitution.
• Constitutional Basis: Articles 13, 32, 226, etc., explicitly grant this power.
• Scope: Covers legislative, executive, and constitutional amendments (post-1973), including 9th Schedule laws (post-2007).
• Importance: Safeguards Fundamental Rights, upholds constitutional supremacy, ensures federal balance, and acts as checks and balances.
• Limitations: Respect for separation of powers, non-interference in policy matters, immunities, and the doctrine of "strict necessity."
• Basic Structure Doctrine: Established in Kesavananda Bharati (1973), it restricts Parliament's power to amend the Constitution's fundamental features; judicial review itself is part of this doctrine.
• Comparison with USA: India's scope is narrower (Procedure Established by Law vs. Due Process) and lacks judicial law-making, but has the unique Basic Structure Doctrine.

10. Practice Questions & Answers

✅ Multiple-Choice Questions (MCQs)

1. Which of the following articles explicitly confers the power of judicial review on High Courts for the enforcement of Fundamental Rights and for any other purpose? a) Article 13 b) Article 32 c) Article 131 d) Article 226

Answer: d) Article 226 Explanation: Article 226 empowers High Courts to issue writs for the enforcement of fundamental rights and "for any other purpose," giving them a broad scope of judicial review. Article 32 grants similar power to the Supreme Court specifically for Fundamental Rights.

2. The "Basic Structure Doctrine" was propounded in which of the following landmark Supreme Court cases? a) Golaknath v. State of Punjab b) Minerva Mills v. Union of India c) Kesavananda Bharati v. State of Kerala d) S.R. Bommai v. Union of India

Answer: c) Kesavananda Bharati v. State of Kerala Explanation: The Basic Structure Doctrine, which limits Parliament's power to amend the Constitution, was established in the Kesavananda Bharati case in 1973. Subsequent cases, like Minerva Mills, reaffirmed and applied this doctrine.

3. Judicial review of laws placed in the Ninth Schedule became possible post-April 24, 1973, due to which Supreme Court judgment? a) Shankari Prasad v. Union of India b) Indira Gandhi v. Raj Narain c) I.R. Coelho v. State of Tamil Nadu d) Waman Rao v. Union of India

Answer: c) I.R. Coelho v. State of Tamil Nadu Explanation: The I.R. Coelho case (2007) held that laws placed in the Ninth Schedule after April 24, 1973 (the date of the Kesavananda Bharati judgment) are open to judicial scrutiny if they violate Fundamental Rights or the Basic Structure of the Constitution.

4. The principle of "Procedure Established by Law" in India, particularly under Article 21, is traditionally narrower than the American "Due Process of Law" because: a) Indian courts cannot strike down any law. b) Indian courts primarily examine if the law was enacted according to laid down procedures and respects constitutional provisions, rather than its inherent fairness or reasonableness, though this interpretation has evolved. c) American courts have no power of judicial review. d) Indian fundamental rights are not justiciable.

Answer: b) Indian courts primarily examine if the law was enacted according to laid down procedures and respects constitutional provisions, rather than its inherent fairness or reasonableness, though this interpretation has evolved. Explanation: "Procedure Established by Law" historically meant judicial scrutiny was limited to the legality of the procedure, while "Due Process of Law" allows for scrutiny of the fairness and reasonableness of the law itself. However, the Maneka Gandhi case broadened India's interpretation to include just, fair, and reasonable procedures, blurring this distinction in practice.

🔍 Scenario-Based Questions

1. Scenario: A State Legislature passes a law that restricts the right to freedom of speech and expression (Article 19(1)(a)) for journalists, citing public order concerns. A group of journalists challenges this law in the High Court, arguing it is unconstitutional.

Question: On what grounds can the High Court exercise judicial review in this scenario, and what factors might influence its decision?

Answer: The High Court can exercise judicial review primarily on two grounds:

1. Violation of Fundamental Rights: The law directly infringes upon the fundamental right to freedom of speech and expression guaranteed under Article 19(1)(a).
2. Reasonableness of Restrictions: Article 19(2) allows for "reasonable restrictions" on this right in the interest of public order. The High Court will review whether the restrictions imposed by the State law are indeed "reasonable" and proportionate to the stated public order concerns. The judiciary will examine if the restriction is arbitrary, excessive, or goes beyond what is necessary to maintain public order. This involves a test of proportionality and whether a less restrictive alternative could achieve the same objective. Factors influencing its decision would include the severity of the restrictions, the actual threat to public order, comparative analysis with existing laws, and previous judicial precedents on Article 19(1)(a) and reasonable restrictions.

2. Scenario: Parliament passes a constitutional amendment that seeks to remove the power of the Supreme Court to review any law relating to environmental protection.

Question: Discuss the constitutional implications of such an amendment in light of the Basic Structure Doctrine and the Minerva Mills judgment.

Answer: This amendment would likely be struck down by the Supreme Court based on the Basic Structure Doctrine, as reinforced by the Minerva Mills case.

• Violation of Basic Structure: The Supreme Court in Kesavananda Bharati (1973) established that Parliament cannot alter or destroy the "basic structure" of the Constitution. In Minerva Mills (1980), judicial review was unequivocally declared to be a basic feature of the Constitution.
• Unconstitutional Amendment: An amendment aiming to remove the power of judicial review directly attacks a core component of the Basic Structure. The Supreme Court has consistently held that the limited amending power of Parliament is itself a basic feature, and this power cannot be used to grant itself unlimited authority by eliminating fundamental constitutional safeguards like judicial review. Therefore, such an amendment would be declared unconstitutional for violating the Basic Structure Doctrine.

🔄 Match-the-following / Chronology exercises

Match the following landmark cases with their key pronouncements/outcomes regarding Judicial Review:

Answer Key:

1. D
2. C
3. B
4. A

Chronological Order of Cases (Earliest to Latest):

1. Golaknath v. State of Punjab (1967)
2. Kesavananda Bharati v. State of Kerala (1973)
3. Minerva Mills v. Union of India (1980)
4. I.R. Coelho v. State of Tamil Nadu (2007)

🧠 Diagram-based/Case-based reasoning

Diagram: Evolution of Parliament's Amending Power & Judicial Review

Question: Based on the provided diagram, explain how the relationship between Parliament's power to amend the Constitution and the judiciary's power of judicial review evolved from Golaknath to I.R. Coelho.

Answer: The diagram illustrates a dynamic and often contentious evolution in the relationship between Parliament's amending power and judicial review:

1. Golaknath (1967): Initially, the Golaknath case established a strong judicial check, holding that Parliament could not amend Fundamental Rights (FRs), thus severely limiting Parliament's amending power.
2. Parliamentary Response (24th, 25th, 29th Amendments): In response, Parliament asserted its supremacy by enacting amendments to overcome the Golaknath ruling, explicitly stating its power to amend any part of the Constitution.
3. Kesavananda Bharati (1973): This case brought a critical equilibrium. It overturned Golaknath, reaffirming Parliament's power to amend FRs and other parts of the Constitution. However, it simultaneously introduced the Basic Structure Doctrine, creating an inviolable core of the Constitution that Parliament could not alter or destroy, even through an amendment. Crucially, the Court declared that Judicial Review itself is part of this Basic Structure.
4. Minerva Mills (1980): Following attempts (e.g., the 42nd Amendment) to curtail judicial review, the Minerva Mills case strongly reaffirmed the Kesavananda Bharati ruling. It struck down clauses that sought to make constitutional amendments non-justiciable, once again asserting that judicial review is a basic feature and cannot be removed.
5. I.R. Coelho (2007): The final stage in this particular evolution, as shown, pertains to the Ninth Schedule. The I.R. Coelho case extended the Basic Structure Doctrine and judicial review to laws placed in the Ninth Schedule after the Kesavananda Bharati judgment date (April 24, 1973), ensuring that even these seemingly immune laws could be reviewed for violating FRs or the Basic Structure.

In essence, the evolution moved from a temporary complete bar on amending FRs (Golaknath), to an acceptance of Parliament's amending power but with a fundamental limitation (Basic Structure Doctrine), with judicial review consistently emerging as an inherent and inalienable part of that basic structure, ultimately extending its reach even to the Ninth Schedule.

Recommended Books

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• Indian Polity (English) by M Laxmikanth for UPSC CSE 2025 | 7th edition (latest) | Civil Services Exam - Prelims, Mains and Interview | State PSCs exams/ PCS exams - by M Laxmikanth
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