In the 1970s, state legislation (education is a subject covered by the Concurrent list in the Seventh Schedule of the Indian Constitution – i.e., both central and state governments can legislate on it) was increasingly encroaching on the rights of minority educational institutions which are protected by articles in the Indian constitution. In a landmark case St. Xavier's College Society vs. State of Gujarat, (1974) 1 SCC 717, Palkhivala argued that the extant right of a state government to administer an academic institution did not extend to a right to maladminister. The majority of the nine-judge bench upheld his contention, significantly strengthening the rights of the minorities.