Question

The validity of the First Amendment to the Indian Constitution was challenged in which case?

• A. Indra Sawhney v. Union of India
• B. MC Mehta v. Union of India
• C. K. M. Nanavati v. State of Maharashtra
• D. Shankari Prasad Singh Deo v. Union of India

Hint:

Important Constitutional Cases: \[ \text{Shankari Prasad (1951)} \rightarrow \text{Parliament Can Amend Fundamental Rights} \] \[ \text{Golaknath (1967)} \rightarrow \text{Parliament Cannot Amend Fundamental Rights} \] \[ \text{Kesavananda Bharati (1973)} \rightarrow \text{Basic Structure Doctrine} \]

Answer 1

The Correct Option is D

Concept: The First Constitutional Amendment Act, 1951 introduced important provisions such as Articles 31A and 31B and the Ninth Schedule. It was enacted mainly to protect land reform legislation from constitutional challenges.

Step 1: Understand the constitutional dispute. After the amendment was passed, questions arose regarding whether Parliament could amend Fundamental Rights through the constitutional amendment process.

Step 2: Examine the Shankari Prasad case. In Shankari Prasad Singh Deo v. Union of India (1951), the validity of the First Constitutional Amendment was challenged on the ground that it abridged Fundamental Rights and therefore violated Article 13(2).

Step 3: Analyze the Supreme Court's decision. The Supreme Court upheld the amendment and held that:

• Constitutional amendments are made under Article 368.

• A constitutional amendment is not a ``law'' within the meaning of Article 13.

• Parliament possesses the power to amend Fundamental Rights.
This became the first major constitutional amendment case in India. Therefore, Option (D) is correct.