Introduction
The Golaknath case, formally I.C. Golaknath and Ors. v. State of Punjab (1967), is a landmark Supreme Court decision that held Parliament could not amend or abridge Fundamental Rights under Part III by using its amending power, treating constitutional amendments as “law” subject to Article 13 and thus void if they curtailed those rights; delivered by a narrow 6–5 majority and applied prospectively, the ruling intensified the rights–amendment debate and set the stage for later constitutional developments like the 24th Amendment and the basic structure doctrine.
Statement of the Case
The statement of the case in I.C. Golaknath and Ors. v. State of Punjab (1967) concerns a constitutional challenge by the Golaknath family, owners of over 500 acres of agricultural land in Jalandhar, to the Punjab Security of Land Tenures Act, 1953, which capped holdings at 30 standard acres per person, declared the remainder surplus, and redistributed portions to tenants; proceeding under Article 32, the petitioners contended that the Act, shielded by its inclusion in the Ninth Schedule via the Constitution (Seventeenth Amendment) Act, 1964, violated their Fundamental Rights to property and occupation under Articles 19(1)(f) and 19(1)(g) and to equality under Article 14, and further urged that constitutional amendments under Article 368 are “law” within Article 13(3)(a), hence void insofar as they abridge Part III rights, thereby placing before a Constitution Bench the issues whether Parliament can amend or curtail Fundamental Rights and whether such amendments are subject to Article 13
Judgement
Judgment: In a 6–5 majority, the Supreme Court held that constitutional amendments made under Article 368 are “law” within the meaning of Article 13(3), and therefore Parliament cannot amend the Constitution to take away or abridge Fundamental Rights in Part III; applying the doctrine of prospective overruling, the Court preserved earlier amendments and the impugned land ceiling law but barred any future curtailment of Fundamental Rights through the amending process.
Key holdings
- Amendments under Article 368 are subject to Article 13, so any amendment infringing Part III is void to the extent of the infringement.
- Parliament’s power under Article 368 is procedural; it is not an unfettered constituent power to curtail Fundamental Rights.
- The ruling overruled earlier precedents in Shankari Prasad and Sajjan Singh to the extent they allowed curtailment of Part III via amendment.
Prospective overruling
- The Court introduced prospective overruling, declaring that its interpretation would operate for the future only, thereby not invalidating prior amendments or upsetting settled rights, and leaving the Punjab land reforms undisturbed.
Impact on Constitution and Politics
Here are five crisp impacts of the Golaknath judgment on India’s Constitution and politics:
- Clipped Parliament’s amending power over rights: By reading amendments as “law” under Article 13, the Court barred curtailment of Part III, immediately constraining the political majority’s capacity to dilute civil liberties through amendments.
- Triggered constitutional counter‑moves: The political response was swift—Parliament enacted the 24th Amendment to restore and clarify its amending power, explicitly insulating Article 368 amendments from Article 13.
- Set the stage for Basic Structure: Though not articulating the doctrine, Golaknath catalyzed Kesavananda Bharati, where the Court upheld wide amending power but forbade damage to the Constitution’s basic structure, reshaping amendment politics.
- Elevated judicial assertiveness: The ruling marked a more activist judiciary asserting guardianship of rights, influencing later cases like Indira Gandhi (1975) and Minerva Mills (1980) that policed amendment excesses.
- Reconfigured executive‑judiciary politics: The tug‑of‑war after Golaknath—24th/25th/39th/42nd Amendments and contentious appointments—deepened constitutional politics around separation of powers and court‑curbing efforts during the 1970s.
Conclusion
In sum, Golaknath stands as a pivotal inflection point that temporarily ring‑fenced Fundamental Rights from majoritarian amendment, compelled a political-constitutional reckoning through the 24th Amendment, and ultimately propelled the jurisprudential journey to Kesavananda’s basic structure limit on constituent power, thereby rebalancing India’s constitutional politics toward a rights‑conscious, court‑policed amendment process while preserving institutional stability through prospective overruling