Which one is correct chronological order of judgements passed by Supreme Court of India on following cases ?

Question

Accepted Answer

The correct option is 1:

The correct chronological order of the landmark Supreme Court judgments concerning the power of Parliament to amend the Constitution, particularly Fundamental Rights, is **Sankari Prasad, Sajjan Singh, Golaknath, Kesavananda Bharati, and Minerva Mills**. This sequence represents the evolution of the judicial interpretation of Article 368 and the doctrine of the Basic Structure.1.  **Sankari Prasad Deo v. Union of India (1951):** This was the first major constitutional challenge to the First Amendment. The Supreme Court unanimously upheld the Parliament's power under Article 368 to amend Fundamental Rights. The court held that 'law' under Article 13 (which voids laws inconsistent with Fundamental Rights) only refers to ordinary legislative law, not a constitutional amendment.
2.  **Sajjan Singh v. State of Rajasthan (1964):** This case challenged the 17th Amendment. The majority of the Supreme Court upheld the ruling in *Sankari Prasad*, confirming that Parliament could amend Fundamental Rights. However, two judges dissented, questioning the correctness of the earlier judgment, which foreshadowed the major shift to come.
3.  **I. C. Golaknath v. State of Punjab (1967):** This judgment marked a radical departure. A narrow 6:5 majority reversed the previous two rulings, holding that Parliament has **no power** to amend Fundamental Rights. It stated that a constitutional amendment is a 'law' under Article 13, and therefore, if it takes away or abridges Fundamental Rights, it is void. This decision created significant tension between the Judiciary and the Parliament.
4.  **Kesavananda Bharati v. State of Kerala (1973):** This is the most crucial case in Indian constitutional history. A larger bench (7:6) partially overruled *Golaknath*. It restored Parliament's power to amend *any* part of the Constitution, including Fundamental Rights, but simultaneously introduced the 'Doctrine of Basic Structure.' This doctrine dictates that Parliament cannot alter the fundamental features or the Basic Structure of the Constitution.
5.  **Minerva Mills Ltd. v. Union of India (1980):** This case solidified and elaborated on the Basic Structure Doctrine established in *Kesavananda Bharati*. The Court struck down parts of the 42nd Amendment Act (1976), reinforcing that the power of judicial review and the balance between Fundamental Rights and Directive Principles are integral components of the Basic Structure that cannot be removed by Parliament.The incorrect option is 2:
**Sajjan Singh, Golaknath, Sankari Prasad, Kesavananda Bharati, Minerva Mills**
This sequence is incorrect because the *Sankari Prasad* case (1951) was chronologically the first, preceding *Sajjan Singh* (1964). All subsequent options are based on an incorrect starting point or an incorrect transposition of the first two foundational judgments. The chronological progression is critical as each case built upon or challenged the preceding interpretation of the constitutional amendment power. Placing *Sankari Prasad* third incorrectly suggests that the landmark initial ruling on the First Amendment came after *Sajjan Singh* and *Golaknath*, which is historically inaccurate regarding the timeline of constitutional jurisprudence.

The incorrect option is 3:
**Sankari Prasad, Golaknath, Sajjan Singh, Kesavananda Bharati, Minerva Mills**
While this option correctly starts with *Sankari Prasad* (1951), it incorrectly places *Golaknath* (1967) immediately after it, skipping over the *Sajjan Singh* case. *Sajjan Singh* (1964) acted as an intermediate validation of the *Sankari Prasad* ruling, though it contained a dissent that paved the way for the radical shift in *Golaknath*. Furthermore, this option places *Sajjan Singh* after *Golaknath*, which is entirely wrong in the actual timeline. *Golaknath* reversed the precedent set by *Sajjan Singh* and *Sankari Prasad*.

The incorrect option is 4:
**Sankari Prasad, Sajjan Singh, Golaknath, Minerva Mills, Kesavananda Bharati**
This option is correct for the first three judgments: *Sankari Prasad* (1951), *Sajjan Singh* (1964), and *Golaknath* (1967). However, it incorrectly transposes the final two landmark cases. The *Minerva Mills* judgment (1980) followed the *Kesavananda Bharati* judgment (1973) by several years. *Kesavananda Bharati* is significant as it introduced the Basic Structure Doctrine, which *Minerva Mills* then applied and reinforced by striking down key provisions of the 42nd Amendment. Therefore, placing *Minerva Mills* before *Kesavananda Bharati* misrepresents the historical and doctrinal development of the Constitution.