{{quotation|Three Articles of our Constitution, and only three, stand between the heaven of freedom into which [[Rabindranath Tagore|Tagore]] [[Chitto Jetha Bhayshunyo|wanted his country to awake]] and the abyss of unrestrained power. They are Articles 14, 19 and 21. Article 31C has removed two sides of that golden triangle which affords to the people of this country an assurance that the promise held forth by the preamble will be performed by ushering an egalitarian era through the discipline of fundamental rights, that is, without emasculation of the rights to liberty and equality which alone can help preserve the dignity of the individual.<ref name=oa-4488/>}}
This latter view of Article 31C was questioned, but not overturned, in ''Sanjeev Coke Manufacturing Co v Bharat Cooking Coal Ltd.''<ref> (case''Sanjeev citation:Coke Manufacturing Co v Bharat Cooking Coal Ltd.''AIR 1983 SC 239).</ref> The concept of basic structure has since been developed by the Supreme Court in subsequent cases, such as ''Waman Rao v. Union of India'',<ref>''Waman Rao v. Union of India'' (AIR 1981 SC 271),</ref> ''Bhim Singhji v. Union of India'',<ref>''Bhim Singhji v. Union of India'' (AIR 1981 SC 234),</ref> ''S.P. Gupta v. President of India''<ref>''S.P. Gupta v. President of India'' (AIR 1982 SC 149)</ref> (known as Transfer of Judges case), ''S.P. Sampath Kumar v. Union of India'',<ref>''S.P. Sampath Kumar v. Union of India'' (AIR 1987 SC 386),</ref> ''P. Sambamurthy v. State of Andhra Pradesh'',<ref>''P. Sambamurthy v. State of Andhra Pradesh'' (AIR 1987 SC 663),</ref> ''Kihota Hollohon v. Zachilhu and others'',<ref>''Kihota Hollohon v. Zachilhu and others'' (1992 1 SCC 309)</ref> '' L. Chandra Kumar v. Union of India and others '',<ref>'' L. Chandra Kumar v. Union of India and others ''( AIR 1997 SC 1125),</ref> ''P. V. Narsimha Rao v. State (CBI/SPE)'',<ref>''P. V. Narsimha Rao v. State (CBI/SPE)'' AIR 1998 SC 2120),</ref> ''I.R. Coelho v. State of Tamil Nadu and others'',<ref>''I.R. Coelho v. State of Tamil Nadu and others'' (2007 2 SCC 1)</ref> and ''Raja Ram Pal v. The Hon'ble Speaker, Lok Sabha and others''<ref>''Raja Ram Pal v. The Hon'ble Speaker, Lok Sabha and others'' (JT 2007 (2) SC 1)</ref> (known as Cash for Query case).<ref name = "Lok Sabha Secretariat"/>
The Supreme Court's position on constitutional amendments laid out in its judgements is that Parliament can amend the Constitution but cannot destroy its "basic structure".<ref name="indianexpress2"/><ref name = "countrystudies">{{cite web |url=http://countrystudies.us/india/109.htm |title=India - The Constitution |publisher=Countrystudies.us |access-date=2013-12-01 |archive-url=https://web.archive.org/web/20121014185951/http://countrystudies.us/india/109.htm |archive-date=2012-10-14 |url-status=live }}</ref>
