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Former CJI YV Chandrachud Nurtured Basic Structure Doctrine: Insights from Supreme Court Justice BV Nagarathna

 

Former CJI YV Chandrachud Nurtured Basic Structure Doctrine: Insights from Supreme Court Justice BV Nagarathna

Introduction: During a recent lecture, Supreme Court Justice BV Nagarathna credited the late Chief Justice of India (CJI) YV Chandrachud for his seminal contributions to the Basic Structure doctrine of the Indian Constitution. Justice Nagarathna's remarks came during the 216th Friday Club lecture at the Supreme Court, commemorating the 104th birth anniversary of the former CJI.

The Basic Structure Doctrine: The Basic Structure doctrine, first established in the landmark Kesavananda Bharati case of 1973, posits that certain fundamental features of the Constitution cannot be altered by any amendment. Justice YV Chandrachud, who served as CJI from 1978 to 1985, played a pivotal role in nurturing and refining this doctrine through his judgments. Justice Nagarathna emphasized that his balanced vision provided the doctrine with its essential framework, ensuring that the core principles of the Constitution remained intact.

Key Judgments: Justice Nagarathna highlighted two critical cases where CJI Chandrachud's contributions were particularly significant: Indira Gandhi vs. Raj Narain and Minerva Mills vs. Union of India. In these cases, Chandrachud's opinions reinforced the doctrine, safeguarding the democratic structure and ensuring that no single branch of government could undermine the Constitution's basic framework.

Impact on Indian Democracy: Justice Nagarathna argued that without the immutability of the Basic Structure doctrine, Indian democracy might have faced severe threats to its sanctity. She pointed out that CJI Chandrachud had no hesitation in upholding citizens' fundamental rights, as seen in the Rudul Shah case, where he awarded monetary compensation for the unlawful detention of a citizen, a novel concept at the time.

Rarest of Rare Doctrine: Another notable contribution of CJI Chandrachud was the 'rarest of rare' doctrine in the Bachan Singh case, which set the standard for imposing the death penalty in India. This doctrine continues to influence judicial decisions regarding capital punishment, ensuring it is applied only in the most exceptional circumstances.

Legacy and Influence: Justice Nagarathna lauded CJI Chandrachud's approach to adjudicating family law cases, noting his ability to delve into the psychological aspects of litigants. She also recalled Justice Chinnappa Reddy's description of Chandrachud as a master at constituting benches to bring out the best in judges. During his tenure, Chandrachud appointed 14 judges to the Supreme Court, leaving a lasting impact on the judiciary.

Personal Reflections: In her speech, Justice Nagarathna also shared personal anecdotes, noting that CJI Chandrachud was born on Prathama Ekadashi, a significant day in the Hindu calendar, and passed away on Harisheyana Ekadashi, another auspicious day. These reflections added a personal touch to her tribute, highlighting the deep respect and admiration she holds for the former CJI.

Conclusion: Justice BV Nagarathna's lecture underscores the profound influence of CJI YV Chandrachud on Indian constitutional law. His work in nurturing the Basic Structure doctrine and other judicial innovations has left an indelible mark on the Indian judiciary. As Justice Nagarathna is poised to become a future CJI herself, her reflections on Chandrachud's legacy offer a glimpse into the enduring principles that continue to guide the Indian legal system.

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