Sajjan Singh was a landlord hailing from Deoli village in Rajasthan’s Pali district. In 1964, he initiated a legal challenge against the Rajasthan Tenancy Act, which permitted the state to take over his agricultural land exceeding the stipulated ceiling of 25 acres. He argued that this law infringed upon his fundamental rights as enshrined in the Constitution, especially his right to property, which was then protected under Article 31.
The legal challenge arose following the enactment of the 17th Constitutional Amendment, aimed at safeguarding agrarian reform laws from being contested under the fundamental rights provisions. Sajjan Singh questioned the legitimacy of Parliament's power to amend the Constitution in a manner that could undermine citizens’ rights.
The core issue in this case was whether Parliament possessed the authority to amend the Constitution in a way that could affect or restrict fundamental rights. This case raised critical questions about the judicial review of such amendments.
The Supreme Court, in a majority decision of 3:2, upheld the validity of the 17th Amendment, affirming that Parliament had the power to amend the Constitution even if it had incidental effects on fundamental rights. Chief Justice P.B. Gajendragadkar articulated that the power to amend under Article 368 encompassed the ability to modify Part III, which pertains to Fundamental Rights.
Justices J.R. Mudholkar and M. Hidayatullah expressed dissent, warning that Parliament’s power to amend the Constitution was not absolute. Mudholkar provocatively questioned whether the Constitution or Parliament held supreme authority, suggesting that a "basic structure" might exist that Parliament could not alter. This concept would significantly influence future constitutional interpretations.
This case is often compared with Shankari Prasad (1951), where the Court had affirmed Parliament's power to amend fundamental rights. While the Sajjan Singh verdict reinforced this stance, it was notable for the introduction of doubts through dissenting opinions for the first time.
The implications of this case resonated in subsequent Supreme Court decisions, such as Golaknath (1967) and Kesavananda Bharati (1973). In Golaknath, the Court shifted its position, ruling that Parliament could not amend fundamental rights. This was later nuanced in Kesavananda Bharati, which established the basic structure doctrine, allowing amendments but prohibiting alterations to core features like democracy and judicial review.
The Sajjan Singh case remains significant as it sparked an ongoing debate regarding the limits of constitutional amendments. It laid the groundwork for the basic structure doctrine, which continues to influence constitutional interpretation in India, highlighting the tension between legislative and constitutional supremacy.
Recently, the judiciary has revisited themes from this case in discussions concerning Parliament's amending power and judicial review, particularly in the context of the National Judicial Appointments Commission (NJAC), Tribunal reforms, and various constitutional amendments. Courts continue to navigate the balance between parliamentary authority and the preservation of fundamental rights.
For aspiring civil servants and constitutional scholars, this case underscores the significance of judicial independence, the importance of dissent in a democracy, and the ongoing debate regarding the extent of Parliament's amending power. It emphasizes the judiciary's critical role in safeguarding the essence of the Constitution.
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