The basic structure doctrine was
first articulated by Justice Hans Raj Khanna in
the landmark decision of Kesavananda Bharati
v. State of Kerala (case citation: AIR 1973 SC
1461). Previously, the Supreme Court had held
that the power of parliament to amend the
constitution was unfettered. However, in this
landmark ruling, the court adjudicated that while
parliament has "wide" powers, it did not have the
power to destroy or emasculate the basic
elements or fundamental features of the
constitution.