Background of the Case: In the Waman Rao case, the constitutional validity of certain provisions of the Maharashtra Agricultural Lands (Ceiling on Holdings) Act, 1961, was challenged. The Bombay High Court had previously ruled that these provisions, included in the Ninth Schedule, could not be challenged for violating fundamental rights under Part III of the Constitution. However, after the emergency period was lifted, a petition for review of this judgement was considered by the Supreme Court in the Waman Rao case.
Issues Raised:
Whether the Parliament exceeded its amending power by introducing Article 31A through the 1st constitutional Amendment?
Whether Article 31A(1) provided immunity to laws from being challenged based on violations of Fundamental Rights, including Articles 14, 19, and 31?
Whether Article 31B (establishing the Ninth Schedule) could be challenged for infringing upon Fundamental Rights?
Whether Article 31C (aiming to achieve the goals of Article 39) could be challenged for inconsistency with citizens’ Fundamental Rights?
Supreme Court’s Judgement:
Validity of Article 31A: The Court held that Article 31A, introduced by the 1st constitutional Amendment, aimed to address social and economic disparities in the agricultural sector and did not violate the basic structure of the Constitution. The Court upheld its constitutionality based on its own merits without invoking the Doctrine of Stare Decisis.
Validity of Article 31B: The Court ruled that laws included in the Ninth Schedule before the Kesavananda Bharati case were protected under Article 31B. However, acts added after Kesavananda could be subject to scrutiny for violating the Constitution’s basic structure.
Validity of Article 31C: Article 31C, protecting laws implementing directive principles, was upheld as it did not violate the Constitution’s basic structure.
Doctrine of Stare Decisis: The Court clarified that the Doctrine of Stare Decisis applied to laws protected by the Constitution, not the Articles themselves. It held that since the validity of Article 31A was not contested in previous cases, it could not be upheld by invoking stare decisis.
Significance: The Waman Rao case clarified the constitutional validity of Articles 31A, 31B, and 31C. It affirmed that while laws in the Ninth Schedule before Kesavananda Bharati were protected, post-Kesavananda additions could be subject to scrutiny. The case underscored the importance of balancing social and economic goals with fundamental rights and established guidelines for future constitutional interpretation.
