Sajjan Singh vs State of Rajasthan | Important Acts and Laws for Judiciary Exams PDF Download

Introduction

Sajjan Singh vs State of Rajasthan is a landmark case that played a crucial role in shaping the interpretation of the Indian Constitution's basic structure. The case emphasized certain fundamental elements that are considered immutable as they underpin the constitutional framework of India. One of the key aspects highlighted in this case is the concept of Fundamental Rights, which Justice Khanna stressed are inherent to every Indian citizen.

Significance of the Case

• The case established the concept of the basic structure of the Indian Constitution, outlining elements that are beyond the reach of parliamentary amendments.
• Before the introduction of the basic structure doctrine, Parliament had the authority to amend any part of the Constitution, including Fundamental Rights, under Article 368.
• Justice Khanna's ruling underscored the importance of safeguarding certain core features of the Constitution that are essential for upholding democracy and protecting individual rights.

Case Details

• Case Title: Sajjan Singh v. State of Rajasthan
• Court: Supreme Court of India
• Citation: AIR 1965 SC 845
• Judges: P. B Gajendragadkar, K. Subba Rao, K.N Wanchoo, M Hitayatullah, J. C Shah
• Date: 31st March 1965

Facts of the Case: Sajjan Singh vs State of Rajasthan

• Context: In 1951, several State legislative measures faced legal challenges concerning agrarian reform in the Courts.
• Legislative Support: The Constitution (First Amendment) Act 1951 introduced Articles 31A and 31B to assist State Legislatures in implementing their reform policies.
• Article 31A: Ensured Acts related to agrarian reform in the Ninth Schedule would not be void or retroactively voided.
• Ongoing Challenges: Despite the amendments, some State legislative measures continued to face legal challenges related to agrarian reform.
• Further Amendment: The Constitution (Seventeenth Amendment) Act 1964 was passed by Parliament to address the challenges and safeguard the validity of Acts.
• Ninth Schedule Amendments: 44 Acts were added to the Ninth Schedule through the 1964 amendment.
• Petitioners: Individuals directly impacted by these Acts filed writ petitions in the Supreme Court seeking clarity on their constitutionality.
• Judicial Process: The petitioners and interveners aimed to seek resolution and constitutional clarity through the judicial system.

Issue Raised

• Does altering a fundamental right under Article 368 constitute as "law" according to Article 13(2)?
• Is Parliament allowed to make amendments to a fundamental right in Part III of the Constitution through Article 368?
• Does the 26th Amendment Act, which abolished the princely rights and privy funds of former princely state rulers, hold legal validity?

Laws Applied

• Ninth Schedule of the Indian Constitution: Certain Acts and Regulations listed in the Ninth Schedule are protected from being declared void, even if they contradict or limit rights in the Constitution. These laws will remain valid unless a competent legislature decides otherwise.
• Parliament's Amendment Power (Article 368(1)): Parliament has the authority to amend the Constitution by adding, changing, or repealing any provision through the specified procedure. This grants Parliament the ability to modify the Constitution itself.
• Limitation on State Laws (Article 13(2)): States are prohibited from creating laws that infringe upon the rights outlined in the Constitution. Any law that violates this provision will be considered void to the extent of the violation.
• Right to Constitutional Remedies (Article 32(1)): Every individual has the right to approach the Supreme Court to enforce their fundamental rights as guaranteed by the Constitution. This provision ensures access to legal remedies for the protection of rights.

Arguments by Petitioner

The petitioners in the case of Sajjan Singh versus the State of Rajasthan challenged the validity of the Constitution (Seventeenth Amendment) Act based on several key arguments:

• They contended that the Seventeenth Amendment potentially impacted Article 226 under Chapter V, Part VI of the Constitution. They argued that the special procedure outlined in the proviso to Article 368, requiring ratification by a specific number of States for certain constitutional amendments, should have been followed.
• The petitioners aimed to revisit a previous decision from the case of Sri Sankari Prasad Singh Deo v. Union of India and State of Bihar (1952). In this earlier case, a similar argument was rejected when examining the validity of the First Amendment. The petitioners believed that this prior decision should be reexamined.
• They asserted that the Seventeenth Amendment Act dealt with issues concerning land, which they argued fell outside the scope of Parliament's authority to legislate on land-related matters. Consequently, they claimed the Act was invalid.
• Lastly, the petitioners argued that the Act attempted to override decisions made by Courts of competent jurisdiction, a move they deemed unconstitutional.

These arguments formed the core of the petitioners' challenge to the Constitution (Seventeenth Amendment) Act in the Supreme Court case of Sajjan Singh vs State of Rajasthan.

Judgment: Sajjan Singh versus State of Rajasthan

• The Supreme Court's ruling in Sajjan Singh v. State of Rajasthan emphasized the importance of harmonizing the main part of Article 368 and its proviso to ensure neither is overly restricted or expanded.
• When amending fundamental rights and potentially affecting the High Court's powers under Article 226, it is crucial to consider whether the proviso to Article 368 applies.
• If the impact of an amendment on Article 226 is indirect, incidental, or insignificant, the proviso may not be applicable. The Court must assess the true nature and purpose (pith and substance) of the impugned Act.
• In the case of the Constitution (Seventeenth Amendment) Act, the primary aim was to amend fundamental rights to facilitate a socioeconomic policy without significantly affecting Article 226.
• The Court found no valid reason to reconsider the Shankari Prasad case, highlighting the importance of cautiousness in revisiting prior decisions without compelling reasons.
• Parliament's enactment of the impugned Act did not involve creating new land legislation but rather validating existing land laws passed by State Legislatures.
• Parliament has the authority under Article 368 to exercise power both prospectively and retrospectively, including validating previously invalidated laws.
• Article 368 grants Parliament the authority to modify or change all provisions of the Constitution, including fundamental rights in Part III.
• The term "law" in Article 13(2) does not encompass laws passed by Parliament under its constituent power to amend the Constitution.
• Article 226 falls under the proviso to Article 368, while Article 32 falls under the main part of the section, potentially necessitating a remedy for amending both.
• The Court rejected the argument that the Constitution (Seventeenth Amendment) Act did not amend Part III's provisions but instead made independent provisions by adding Articles 31A and 31B and Acts to the Ninth Schedule.
• Acts included in the Ninth Schedule for validation are shielded from judicial review, but any future amendments to them would remain subject to scrutiny.

Conclusion

• In conclusion, the Supreme Court's ruling in the case upheld the constitutionality of the Constitution (Seventeenth Amendment) Act, 1964, which amended Articles 31A and 31B and added Acts to the Ninth Schedule. The Court affirmed that Parliament's power under Article 368 includes the authority to modify or amend provisions of the Constitution, including fundamental rights guaranteed by Part III.
• The Court's decision emphasized that previous rulings, such as the Shankari Prasad case, should not be revisited without compelling reasons. It underscored that fundamental rights in Part III are not immutable and can be subject to future amendments.
• Regarding the impugned Act, the Court rejected the argument that it made independent provisions, concluding that it indeed amended Part III of the Constitution. Additionally, while Acts included in the Ninth Schedule were validated, the power of legislatures to amend or repeal them in the future remained intact.
• Overall, the ruling reaffirmed the authority of Parliament to amend the Constitution while also highlighting the significance of judicial review in upholding constitutional principles.