Glanrock Estate (P) Ltd vs The State Of Tamil Nadu

The Supreme Court examined the constitutional validity of the Constitution (Thirty-fourth Amendment) Act, 1974, which inserted the Gudalur Janmam Estates (Abolition and Conversion into Ryotwari) Act, 1969 into the Ninth Schedule. The Court reaffirmed the doctrine of basic structure, holding that amendments post-24.4.1973 are subject to judicial review if they infringe upon the basic structure of the Constitution. The Court upheld the previous ruling in Balmadies Plantations Ltd. v. State of Tamil Nadu regarding the immunity of the Janmam Act from Articles 14, 19, and 31, except concerning forest land acquisition, which remains unconstitutional under Article 31A.