I.R. GOELHO (DEAD)BY LRS. vs THE STATE OF TAMILNADU

The Supreme Court examined the validity of the insertion of the Gudalur Janmam Estates (Abolition and Conversion into Ryotwari) Act, 1969 and the West Bengal Land Holding Revenue Act, 1979 into the Ninth Schedule of the Constitution. It held that such insertion, particularly of provisions struck down as unconstitutional, undermines the basic structure doctrine established under Article 31B and the Kesavananda Bharati case. The Court concluded that amendments made post-24th April 1973 that include unconstitutional acts are subject to judicial review and can be challenged.