This judgment ruled that Article 368 does not enable Parliament in its constituent capacity to delegate its function of amending the Constitution to another legislature or to itself in its ordinary legislative capacity. This ruling made all the deemed constitutional amendments stipulated under the legislative powers of the parliament as void and inconsistent after the 24th constitutional amendment. These are articles 4(2), 169(3)-1962, 239A2-1962, 244A4-1969, 356(1)c, para 7(2) of Schedule V and para 21(2) of Schedule VI. Also articles 239AA(7)b-1991, 243M(4)b-1992, 243ZC3-1992 and 312(4)-1977 which are inserted by later constitutional amendments and envisaging deemed constitutional amendments under legislative powers of the parliament, should be invalid. The Supreme Court declared in the case "A. K. Roy, etc vs Union Of India and Anr" in 1981 that article 368(1) clearly defines constituent power as 'the power to amend any provision of the constitution by way of an addition, variation or repeal.' it reiterated that constituent power must be exercised by the parliament itself in accordance with the procedure laid down in article 368.