Justice Hans Raj Khanna asserted through the Basic Structure doctrine that the constitution possesses a basic structure of constitutional principles and values. The Court partially cemented the prior precedent "Golaknath v. State of Punjab", which held that constitutional amendments through Article 368 were subject to fundamental rights review, but only if they could affect the 'basic structure of the Constitution'. At the same time, the Court also upheld the constitutionality of the first provision of Article 31-C, which implied that amendments seeking to implement the Directive Principles, which do not affect the 'Basic Structure,' shall not be subjected to judicial review.