UPSC Mains 2016 GS Paper 2 Q6: model answer
What was held in the Coelho case? In this context, can you say that judicial review is of key importance amongst the basic features of the Constitution?
What the question wants
State the Coelho judgment and assess whether judicial review is the most important basic feature.
How to structure it
What was held ... can you say: facts and holding, then argue judicial review's place among basic features.
- Ninth Schedule background
- Coelho holding
- Why judicial review is key
- Counterview
- Conclusion
How to think it through
The Ninth Schedule was meant as a safe locker for land reform laws. Over the years states stuffed it with 284 laws, including Tamil Nadu's 69% reservation. Coelho said the locker has a glass door: courts can look in.
Model answer
The First Amendment of 1951 created the Ninth Schedule with 13 land reform laws; by 2007 it held 284 laws. In I.R. Coelho v State of Tamil Nadu (2007), a nine-judge bench limited that shield.
What was held
- Laws placed in the Ninth Schedule after 24 April 1973 (the Kesavananda date) can be challenged if they violate the basic structure.
- Fundamental Rights in Articles 14, 19 and 21, which form the 'golden triangle', are part of the basic structure.
- The test is the 'rights test' (impact on rights), not only the form of the law.
- Judicial review itself is part of the basic structure.
Is judicial review the key basic feature?
Arguments for:
- It is the means by which every other basic feature (democracy, federalism, secularism, rights) is protected; without it the doctrine has no teeth.
- Kesavananda, Minerva Mills (1980), L. Chandra Kumar (1997) and Coelho all treat it as essential.
- The Court used it in NJAC (2015) to protect judicial independence.
Arguments against:
- The Constitution rests on many equal pillars: democracy, sovereignty, rule of law. Judicial review serves them, it does not outrank them.
- Overuse can turn courts into a third legislative chamber.
Conclusion
Judicial review is the guardian of the basic structure rather than its most important part. Its value lies in making the other features enforceable, which is why Coelho matters.
Draw: A locked box (Ninth Schedule) with a 'glass door' labelled judicial review after 1973.
Keywords, cases and data to drop in
Ninth Schedule, Article 31B, 24 April 1973, Coelho 2007, golden triangle, rights test, L. Chandra Kumar 1997, Minerva Mills.
Where most answers lose marks
- Not stating the 1973 cutoff date.
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Question text as printed in the official UPSC Civil Services (Main) question paper. The model answer is original Battle IAS work; use it to learn structure, not to memorise.
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