Table of content An Implied Limit on an Express Power The Pre-History: From Shankari Prasad to Golak Nath Shankari Prasad and Sajjan Singh: The Legislature Prevails Golak Nath: The Pendulum Swings Kesavananda Bharati: The Watershed The Court's Method: Reading 'Amend' in Article 368 The Preamble as a Mirror of Basic Structure Recognised Elements of the Basic Structure Secularism Rule of Law and Equality Judicial Review Republican and Democratic Form of Government Independence