A Comparative Analysis of the Basic Structure Doctrine
Jitmanyu Satpati Writes
On 24th April 1973, a narrowly divided 13 judge bench of the Indian Supreme Court handed down its decision in the case of Kesavananda Bharati v State of Kerala[1](hereinafter Kesavananda). The decision – which spanned nearly 800 pages and included 11 separate opinions – was the culmination of a decades long struggle between the Indian Supreme Court and the Indian Parliament over the custody of the Indian Constitution and the limits which the Constitution placed on the amending power of Parliament.[2] In Kesavananda, the Supreme Court placed substantive limits on the amending power of Parliament by placing certain ‘essential features’ or ‘basic structure’ of the Constitution beyond the amending power of Parliament.[3] The Court also reserved for itself the power to identify these ‘essential features’ or ‘basic structure’ of the Constitution, thus establishing itself as the ultimate custodian and arbiter of the Constitution.[4] Although the basic structure doctrine was subject to strong criticism in the years following the decision[5], the Supreme Court reaffirmed and refined the doctrine in subsequent cases[6] and today the basic structure doctrine is entrenched in Indian constitutional jurisprudence.
In this Paper, I do not engage with Kesavananda beyond a brief overview. Instead, I attempt to build upon Mark Tushnet’s idea of contextualism[7]and apply it to the basic structure doctrine articulated in Kesavananda. To that end, I shall attempt to show that the acceptance or rejection of the basic structure doctrine by courts in other jurisdictions depends to a large extent on the historical context in which their constitution(s) were drafted. The jurisdictions that I analyze in this paper are Singapore and Kenya. I have chosen these jurisdictions because both these jurisdictions are former British colonies, both became independent around the same time, and both retain a sizeable common law influence in their legal systems. At the same time, there are important historical differences in the drafting/adoption of their constitution(s) and the structure of their constitution(s). Finally, both these jurisdictions have rejected the basic structure doctrine. I feel that the similarities and differences between these jurisdictions provides a good canvas for a comparative analysis of why both these jurisdictions rejected the basic structure doctrine.
This Paper is divided into five parts. Part I introduces the topic and explains the choice of jurisdictions along with the central idea that I explore in this Paper. Part II provides a brief overview of the decision in Kesavananda. Parts III and IV analyze the rejection of the basic structure doctrine by the courts in Singapore and Kenya and attempt to situate this rejection within the broader historical context of the constitution making process in both these jurisdictions. Part V concludes.
II. Kesavananda: A Brief Overview
Soon after the commencement of the Indian Constitution, various states enacted agrarian land reform legislation which were challenged as being violative of the (then) fundamental right to property.[8] After some of these statutes were invalidated by various High Courts, Parliament passed the First Amendment Act which introduced the Ninth Schedule.[9] Statutes inserted into the Ninth Schedule were immunized from being invalidated on account of being inconsistent with the Fundamental Rights under Part III of the Constitution.[10] After various rounds of litigation challenging the constitutionality of the First Amendment[11] and the insertion of statutes in the Ninth Schedule[12], an 11 judge bench of the Supreme Court in the Golaknath[13] case held that Parliament could not abridge or take away the fundamental rights through the exercise of its amending power as constitutional amendments were ‘law’ under art. 13 and thus subject to the restrictions under art. 13(2). Parliament responded by passing the Twenty-Fourth Amendment to nullify the Golaknath judgement. This Amendment, along with two other amendments giving precedence to certain directive principles over the fundamental rights[14] and inserting some statutes into the Ninth Schedule[15], were the subject matter of challenge in Kesavanda.
As alluded to previously, it is difficult to discern a clear majority in Kesavananda with regards to the basic structure doctrine. Rajeev Dhavan has argued that there was no clear majority in Kesavananda; instead there was a majority of six, a minority of three, and a cross-bench of three who agreed on some aspects of the basic structure doctrine and disagreed on others.[16] There were also doubts about whether the summary sheet annexed to the end of the judgement accurately reflected the majority holding.[17] At best, the judges unanimously held that the entire Constitution could not be repealed or replaced by Parliament in exercise of its amending power and a slim majority held that the Parliament could not amend the ‘basic structure’ or ‘essential features’ of the Constitution.[18] Beyond this, there was little consensus on what these ‘essential features’ were and little commonality in the reasoning the different judges adopted for limiting Parliament’s power to amend the Constitution.[19]
Given this lack of consensus among the judges, it is somewhat difficult to contextually analyze Kesavananda as a whole. However, some broad observations can be made. Monica Polzin has shown that most of the judges who endorsed the basic structure doctrine adopted a rule of law based approach to identifying the basic structure.[20] She also shows how the Indian Supreme Court’s articulation of the basic structure doctrine in Kesavananda is closer to Maurice Hauriou’s work which was based on structuralism and a distinction between the constituent power and the amending power rather than Carl Schmitt’s idea of a “mystical unconstrained constituent power”.[21] Moreover, some of the judges in Kesavananda argued that the ‘basic structure’ of the Constitution could only be altered by a Constituent Assembly specially convened for that purpose.[22] It is important to note here that some scholars have argued that previous theoretical work on the basic structure and historical arguments did not play a large in the Supreme Court’s reasoning in Kesavananda.[23] Nonetheless, it is of some significance that the Supreme Court’s conceptualization of the basic structure ultimately hewed towards a rule of law and constituent power based theory which was rooted in the history and structure of the Indian Constitution.
III. Teo Soh Lung: A Constitution made by Mere Mortals
The application of the basic structure doctrine to the Singapore Constitution first came up before the Singapore High Court (the lower tier of the Supreme Court of Singapore) in the case of Teo Soh Lung v. Minister of Home Affairs[24](hereinafter Teo). Teo involved a challenge to a constitutional amendment[25] to the Constitution of Singapore which curtailed the judicial power of Singapore Courts to review detention orders made on national security grounds under § 8 of the Internal Security Act[26] except as provided therein. In addition to arguing that her detention was illegal since it was not made on grounds of national security, Teo argued that the 1989 constitutional amendment was invalid as it curtailed judicial review which was a ‘basic feature’ of the Singapore Constitution. Chua, J of the Singapore High Court rejected this argument and held that the basic structure doctrine did not apply in Singapore and there were no implied limits on the Singapore Parliament’s amending powers.[27] Chua, J’s reasons inter alia were that there were differences between the making of the Indian and Singapore Constitutions which made the basic structure doctrine inapplicable to Singapore.[28] He also cited a Malaysian case which had held that the Indian Constitution had not been drafted by ‘mere mortals’[29], which was not the case for the Malaysian (and, by extension, Singapore) Constitution.
In order to understand Chua, J’s reasoning it is necessary to briefly examine the historical circumstances in which Singapore’s Constitution was drafted. Singapore’s first constitution was the 1963 Constitution, which was given to Singapore by their colonial overlord (the British) in order to enable Singapore to become a constituent state of the newly formed Federation of Malaysia.[30] The 1963 Constitution also provided that certain parts of the 1963 Malaysian Constitution would apply to Singapore.[31] Singapore separated from Malaysia in 1965 as a sovereign, independent state and this process was enabled through three legal instruments: (i) Independence of Singapore Agreement, 1965; (ii) The Proclamation of Singapore; and (iii) the Singapore Amendment enacted by the Malaysian Parliament to grant independence to Singapore.[32] The Singapore Amendment provided that the 1963 Singapore Constitution (including the parts of the Malaysian Constitution specified therein) would continue to apply to the new independent State of Singapore.[33] The Parliament (then called the Legislative Assembly) of independent Singapore subsequently passed two bills in 1965: The Constitution (Amendment) Act 1965 and the Republic of Singapore Independence Act, 1965, which were given retrospective effect from the date of independence from Malaysia. Between 1965 and 1969, the Parliament enacted 11 constitutional amendments.[34] Finally, on 30 March 1979, the Parliament enacted the Constitution (Amendment) Act of 1979 pursuant to which all the constitutional enactments from 1965 to 1967 were consolidated and printed as the first authoritative text of the Singapore Constitution in 1980.[35]
As the discussion in the preceding paragraph shows, Singapore never had a dedicated Constituent Assembly like India; instead elements of the Singapore Constitution were drafted successively by the British Parliament, the Malaysian Parliament, and the Legislative Assembly (and later Parliament) of independent Singapore. Furthermore, the Singapore Constitution is a combination of various enactments enacted by different bodies which were consolidated into a single consolidated text only in 1980. Given the lack of a Constituent Assembly representing the sovereign will of the Singapore People, the piecemeal and incremental manner in which the Singapore Constitution was drafted, and the fact that large parts of the Singapore Constitution were enacted by the Singapore Parliament in the exercise of its ordinary legislative power[36], it is not difficult to see why Chua, J was unable to bring himself to accept that certain features of the Singapore Constitution were unamendable by the Singapore Parliament.
IV. David Ndii: Internalizing the Basic Structure
The Courts in Kenya recently had occasion to grapple with the basic structure doctrine in the case of David Ndii & Ors. v. The Attorney General & Ors.[37](hereinafter Ndii),which wound its way from the Kenyan High Court all the way to the Kenyan Supreme Court.The petitioners in this case challenged a set of proposed amendments to the Kenyan Constitution known as the Building Back Better Amendments (hereinafter BBI Amendments) as inter alia being violative of the basic structure of the 2010 Kenyan Constitution. The BBI Amendments were proposed in the wake of a ‘handshake’ deal between the current President of Kenya Uhura Kenyatta and Raila Odinga (his chief opponent in the previous election) and sought to make far reaching changes to the Kenyan Constitution which included executive and parliamentary expansion, insertion of general language relating to national commitments, and changes to the eligibility conditions and tenure for judges.[38]
Before analyzing the judgement(s) in this case, it is necessary to briefly examine Kenyan constitutional history from Independence to the adoption of the 2010 (the current) Constitution, and the amendment provisions in the 2010 Kenyan Constitution. Kenya’s first Constitution dated back to Kenya’s independence from Great Britain in 1963 and was negotiated in London by Kenya’s political elite.[39] In the years after Kenya’s Independence, the Constitution was repeatedly amended by Kenya’s ruling party to centralize power and further their influence with the result that Kenya became a one-party state, de facto from 1969 to 1982 and de jure from 1982 onwards.[40] Agitations for multi-party elections and constitutional reform from the 1990s onwards led to a gradual process involving Constitutional Review Commissions and Constitutional Conferences which culminated in the 2010 Constitution.[41] The 2010 Constitution was the culmination of a long process involving a substantial degree of citizen participation and was approved by Kenyan voters through a special referendum.[42]
Coming to the amendment provisions in the 2010 Constitution, there are two methods to amend the Constitution: an amendment passed by a 2/3 majority of both houses of Parliament[43], or a popular initiative triggered by at least one million registered voters followed by a range of procedural and substantive steps and approval by a majority of county assemblies and simple majorities in both houses of Parliament (failing which it can be put to a referendum)[44] However, amendments to certain listed features (such as Kenyan territory, Bill of Rights etc.) have to be mandatorily passed by a simple majority (subject to certain quorum rules) in a referendum in addition to the processes discussed above.[45]
In Ndii, both the Kenyan High Court (5-0) and the Kenyan Court of Appeal (6-1) held that the basic structure doctrine was applicable to the Kenyan Constitution and that the doctrine imposed implied limitations on the amendment process prescribed in the Kenyan Constitution.[46] Both the courts looked inter alia to Kenyan constitutional history and the circumstances surrounding the drafting and ratification of the 2010 Constitution and held that the 2010 Constitution was an attempt to correct the culture of ‘hyper-amendments’[47] that had plagued the earlier Constitution and inject a spirit of public participation into the Constitution[48]. The Courts relied on this premise to differentiate the ‘primary constituent power’ which was possessed by the people from the ‘secondary constituent power’ (under arts. 255 and 257) and ‘constituted power’ (under art. 256) and held that the ‘basic structure’ of the Kenyan Constitution could only be altered through an exercise of the ‘primary constituent power’.[49] The exercise of the ‘primary constituent power’ in turn required a replication of the conditions under which the 2010 Constitution was drafted and ratified viz. civic education, public participation, debate, consultations, and public discourse, and a referendum.[50]
However, the Kenyan Supreme Court in a 6-1 decision set aside the decisions of the Kenyan High Court and the Kenyan Court of Appeals with respect to the basic structure doctrine, although it invalidated the BBI Amendments on other grounds.[51] The Kenyan Supreme Court held that the Kenyan people had responded to the problem of hyper-amendment and lack of public participation through art. 255 of the 2010 Constitution which required a referendum for amendments to certain important features.[52] The Kenyan Supreme Court held, in effect, that through the tiered amendment process in arts. 255- 257 of the 2010 Constitution, the basic structure doctrine had been internalized in the 2010 Constitution.[53] The Court further held that the unique amendment process in arts. 255 – 257 in the 2010 Constitution differentiated it from other jurisdictions which did not have such provisions (such as India) and thereby obviated the need for a judicially created basic structure doctrine.[54]Although the Kenyan Supreme Court looked at the same history and identified the same problems, it reached the opposite conclusion from the other courts by looking for the solution inside the 2010 Constitution rather than outside.
V. Conclusion
Bruce Ackerman, a noted American scholar, has divided American constitutional history into “constitutional moments” and periods of ordinary politics.[55] Constitutional moments, according to Ackerman, are extraordinary moments where the people, through widespread political expression, took it upon themselves to make a clean break from the past.[56] Moving beyond American constitutional history, the drafting and adoption of a new constitution can also be termed as a constitutional moment. If we look at the two jurisdictions examined in this paper (viz. Singapore and Kenya), it is clear that their constitutional moment (or lack thereof) and the historical circumstances surrounding that moment played a key role in determining whether they would accept the basic structure doctrine. In Singapore’s case, the lack of a clearly defined constitutional moment played a major role in the rejection of the basic structure doctrine by the Singapore Courts. In Kenya, the Kenyan Supreme Court’s interpretation of the amendment provisions was informed by the historical circumstances surrounding Kenya’s constitutional moment (i.e. the drafting and adoption of the 2010 Constitution) and the problems it sought to solve. Although it ultimately rejected the basic structure doctrine, it only did so because it found that those circumstances and problems were adequately addressed and solved within the constitutional framework.
At a broader level, we can say that the historical context in which a country’s Constitution in drafted and enacted plays a significant role in determining whether the courts of that country will be receptive towards the basic structure doctrine. Kesavananda’s conception of the basic structure doctrine, its identification of the basic features, and its proposed method of amending the basic structure hewed closely to the historical context and ideas animating the Indian Constitution even though this influence was not always explicitly acknowledged. The lack of a representative Constituent Assembly in Singapore coupled with the piecemeal manner in which the Singapore Constitution was enacted made it difficult for the Singapore courts to limit Parliament’s amending power or ascribe a special status or permanence to particular provisions or features of the Singapore Constitution. Finally, the historical context around the drafting and ratification of the 2010 Constitution was carefully analyzed by the Kenyan Courts, and the Kenyan Supreme Court rejected the basic structure doctrine only because it felt that this context had found expression in the tiered amendment process present in the 2010 Constitution.
This is not to say, however, that the historical context is decisive in all cases. Courts dealing with the question of the applicability of the basic structure doctrine routinely consider a range of other arguments and features (such as structuralism, textualism etc.). As the example of Kenya shows, the interaction of the historical context with the provisions and structure of the Constitution also plays an important role. However, most courts at least consider the historical context while deciding the applicability of the basic structure doctrine and many are influenced by the historical context even if it is not explicitly acknowledged as the basis of their decision. Thus, the historical context exerts a significant influence on the applicability of the basic structure doctrine, even if it is not ultimately dispositive.
(The Author is an LL.M Candidate at National Law School, Banglore,
He pursued his LL.B from NLUO.)
[1] (1973) 4 SCC 225.
[2] See Zia Mody, 10 Judgements that changed India 11 (2013).
[3] See Kesavananda Bharati, (1973) 4 SCC, at 1007.
[4] See Mody, supra note 2 at 14-15.
[5] See, for e.g., P.K. Tripathi, Rule of Law, Democracy, and Frontiers of Judicial Activism, 15 J. Indian L. Inst. 17, 33 (1975) (arguing that the basic structure doctrine was counter-majoritarian and anti-democractic); Rajeev Dhavan, The Supreme Court of India and Parliamentary Sovereignty: A Critique of its Approach to the Recent Constitutional Crisis 141 (1976) (arguing that there was no clear majority holding in the decision with respect to the basic structure).
[6] See, for e.g., Minerva Mills Ltd. and Ors. v. Union of India, AIR 1980 SC 1789 (India); Supreme Court Advocates-on-Record Association & Anr. v. Union of India, (2016) 5 SCC 1 (India).
[7] See Mark Tushnet, Some Reflections on Method in Comparative Constitutional Law, in The Migration of Constitutional Ideas 67 (Sujith Choudhry ed., 2006).
[8] See Mody, supra note 2, at 11.
[9] Id.
[10] India Const. art. 31B.
[11] Sri Sankari Prasad Singh Deo v. Union of India & Anr., AIR 1951 SC 458 (India).
[12] Sajjan Singh v. State of Rajasthan, AIR 1965 SC 845 (India).
[13] C. Golaknath & Ors. v. State of Punjab & Anr., AIR 1967 SC 1643 (India).
[14] The Constitution (Twenty-Fifth Amendment) Act, 1971 (India).
[15] The Constitution (Twenty-Ninth Amendment) Act, 1972 (India).
[16] See Dhavan, supra note 5.
[17] See Sachin Datta, Basic Structure Doctrine: The Battle behind the Scenes, Bar and Bench (May 22, 2020, 6:35 pm), https://www.barandbench.com/columns/basic-structure-doctrine-the-battle-behind-the-scenes.
[18] See Dhavan, supra note 5, at 154.
[19] Id.
[20] See Monika Polzin, The Basic-Structure Doctrine and its German and French Origins: A Tale of Migration, Integration, Invention, and Forgetting, 5:1 Indian L. Rev. 45, 59-60 (2021).
[21] Id.
[22] See His Holiness Kesavananda Bharathi Sripadagalvuru v. State of Kerala, (1973) 4 SCC 225, 431 (1973) (Shelat and Grover, JJ).
[23] See Sudhir Krishnaswamy, Democracy and Constitutionalism in India: A Study of the Basic Structure Doctrine 33-40 (2009).
[24] [1989] 1 SLR(R) 461 (Sing. High Ct.), aff’d,[1990] 1 SLR(R) 347 (Sing. Ct. of App.) (did not discuss applicability of basic structure doctrine).
[25] Constitution of the Republic of Singapore (Amendment) Act, 1989.
[26] The Internal Security Act, Cap. 143, 1985 Rev. Ed. (Sing.).
[27] See Teo Soh Lung, [1989] 1 SLR(R) ¶¶ 47, 59.
[28] Id.
[29] See Phang Chin Hok v. Public Prosecutor, [1980] 1 MLJ 70, 73 (Fed. Ct. of Malay.).
[30] See Sek Keong Chan, Basic Structure and Supremacy of the Singapore Constitution, 29 Sing. Acad. L. J. 619, 637 (2017).
[31] Id.
[32] Id. at 638.
[33] Id.
[34] Id. at 639
[35] Id.
[36] See Andrew J Harding, Does the ‘Basic Structure’ Doctrine Apply in Singapore’s Constitution? An Inquiry into Some Fundamental Constitutional Premises, in Constitutional Interpretation in Singapore: Theory and Practice 35-39 (Jaclyn L Neo ed., 2016).
[37] [2021] KEHC 9746 (KLR) (High Ct. of Kenya), aff’d sub nom. Independent Electoral and Boundaries Commission v. David Ndii & Ors., [2021] KECA 363 (KLR) (Kenyan Ct. of App.), aff’d on other grounds sub nom. The Hon’ble Attorney General & Ors. v David Ndii & Ors., available at https://www.judiciary.go.ke/courts/supreme-court-2/#decisions (Sup. Ct. of Kenya) (holding that the basic structure doctrine was not applicable to the 2010 Kenyan Constitution).
[38] See Ambreena Manji, The BBI Judgement and the Invention of Kenya, Verfassungsblog (May 22, 2021) https://verfassungsblog.de/the-bbi-judgment-and-the-invention-of-kenya/.
[39] See Alicia L Bannon, Designing a Constitution-Drafting Process: Lessons from Kenya, 116 Yale L. J. 1824, 1830 (2007).
[40] Id. at 1831.
[41] Id. at 1831-40.
[42] Id. at 1840-41.
[43] Constitution art 256 (2010) (Kenya).
[44] Id. art. 257.
[45] Id. art. 255.
[46] See Gautam Bhatia, The Kenyan Supreme Court’s BBI Judgement – I: On Constitutional Amendments and the Basic Structure, India Constitutional Law and Philosophy (Apr. 6, 2022) https://indconlawphil.wordpress.com/2022/04/06/the-kenyan-supreme-courts-bbi-judgment-i-on-constitutional-amendments-and-the-basic-structure/.
[47] See, for e.g.,David Ndii & Ors. v. The Attorney General & Ors., [2021] KEHC 9746 (KLR) (High Ct. of Kenya), ¶ 469.
[48] See, for e.g., Id. ¶ 469; Independent Electoral and Boundaries Commission, [2021] KECA, ¶¶ 76, 82 (Okwengu, JA).
[49] See David Ndii, [2021] KEHC, ¶¶ 472, 474; Independent Electoral and Boundaries Commission, [2021] KECA, ¶ 179 (Kiage, JA).
[50] See, for e.g., David Ndii, [2021] KEHC, ¶ 469; See also Gautam Bhatia, Notes From a Foreign Field: An Instant Classic – The Kenya High Court’s BBI Judgment, India Constitutional Law and Philosophy (May 14, 2021) https://indconlawphil.wordpress.com/2021/05/14/notes-from-a-foreign-field-an-instant-classic-the-kenyan-high-courts-bbi-judgment/.
[51] The Hon’ble Attorney General & Ors. v. David Ndii & Ors., available at https://www.judiciary.go.ke/courts/supreme-court-2/#decisions (Sup. Ct. of Kenya) (hereinafter BBI Supreme Court).
[52] See, for e.g., Id. ¶¶ 192-197 (Koome, CJ); See also Bhatia, supra note 46.
[53] See, for e.g., BBI Supreme Court, supra note 51,¶¶ 1439-42 (Lenaola, J); See also Bhatia, supra note 46.
[54] Id.
[55] See 2 Bruce Ackerman, We The People: Transformations 6 (2000).
[56] Id.
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