What was the primary constitutional outcome of the Kesavananda Bharati case (1973)?

Correct Option

The correct option is It formulated the "Basic Structure" doctrine, limiting Parliament's amendment power..

Explanation

The Kesavananda Bharati v. State of Kerala (1973) judgment is the most significant ruling in Indian constitutional history regarding the scope of Parliament's amending power. It addressed the conflict between the power of Parliament to amend the Constitution under Article 368 and the inviolability of Fundamental Rights.

Option Analysis

• It formulated the "Basic Structure" doctrine, limiting Parliament's amendment power. is Correct: The Supreme Court, in a historic 7:6 majority verdict, overruled the earlier Golaknath (1967) judgment. It held that while Parliament has the power to amend any part of the Constitution (including Fundamental Rights), this power is not absolute. The Court formulated the "Basic Structure" doctrine, ruling that Parliament cannot alter or destroy the essential features or the fundamental framework of the Constitution.
• It established the supremacy of Directive Principles over Fundamental Rights. is Incorrect: The judgment did not establish a blanket supremacy of Directive Principles of State Policy (DPSP) over Fundamental Rights. While it upheld the validity of the first part of Article 31C (which gave precedence to certain DPSPs over specific Fundamental Rights), the broad supremacy of all DPSPs over Fundamental Rights was introduced later by the 42nd Amendment (1976) and was subsequently struck down in the Minerva Mills case (1980).
• It ruled that the Parliament has unlimited power to amend the Constitution. is Incorrect: The Court explicitly rejected the government's argument that Parliament possesses unlimited power to amend the Constitution. The judgment clarified that Article 368 confers a "power to amend," not a "power to destroy."
• It declared the Right to Property as an absolute Fundamental Right. is Incorrect: The case did not declare the Right to Property as absolute. In fact, the judgment upheld the 24th Amendment Act, which affirmed Parliament's power to dilute Fundamental Rights (including property rights), provided the basic structure remained intact. The Right to Property was eventually abolished as a Fundamental Right by the 44th Amendment Act (1978).

Key Takeaway: The primary outcome of the Kesavananda Bharati case was the establishment of the Basic Structure Doctrine, which acts as a limitation on the amending power of Parliament under Article 368, ensuring the core identity of the Constitution remains intact.