Rule of Law as Basic Structure: Indira Nehru Gandhi Case

The question asks about a specific landmark judgment by the apex court (Supreme Court of India) where the 'doctrine of rule of law' was recognized as an integral part of the 'basic structure' of the Indian Constitution.

Understanding the Basic Structure Doctrine

The basic structure doctrine is a principle developed by the Indian judiciary, asserting that the Constitution of India has certain fundamental features that cannot be altered or destroyed by the Parliament through its amending powers. These features form the 'basic structure' which is considered inviolable.

Analyzing the Landmark Case: Indira Nehru Gandhi v. Raj Narain

The case of Indira Nehru Gandhi v. Raj Narain (1975) is pivotal in Indian constitutional law. In this significant judgment:

• The Supreme Court examined the constitutional validity of the 39th Constitutional Amendment Act, 1975, which placed the election of the Prime Minister beyond the scrutiny of the courts.
• A plurality of judges held that certain basic features of the Constitution could not be abrogated even by a constitutional amendment.
• Crucially, the court implicitly and explicitly recognized that the rule of law is a fundamental aspect of the Indian Constitution and forms part of its basic structure. The judgment struck down clauses of the 39th Amendment, finding them to be violative of the basic structure, including the rule of law.
• This case reinforced the idea that Parliament's power to amend the Constitution is not absolute and is limited by the inherent basic features of the Constitution.

Examining Other Options

• A. D. M. Jabalpur v. State of Jammu & Kashmir (1976): This case is infamous for ruling that the right to life and personal liberty under Article 21 could be suspended during a national emergency. It went against the spirit of the rule of law, rather than establishing it as a basic structure.
• Golaknath v. State of Punjab (1967): This case held that Parliament could not amend Fundamental Rights. While significant for limiting amendment powers, it predates the formal articulation of the basic structure doctrine in the context of the rule of law as discussed in the Indira Gandhi case.
• Ram Jawaya Kapur v. State of Punjab (1955): This case dealt with the separation of powers between the executive, legislature, and judiciary, asserting that the executive powers couldn't be exercised contrary to the Constitution. While related to constitutional principles, it's not the specific case that established the rule of law as part of the basic structure.

Conclusion

Based on the analysis, the apex court decision that firmly established the rule of law as part of the basic structure of the Indian Constitution is the case of Indira Nehru Gandhi v. Raj Narain.