This latter view of Article 31C was questioned, but not overturned, in "Sanjeev Coke Manufacturing Co v Bharat Cooking Coal Ltd." (case citation: AIR 1983 SC 239). The concept of basic structure has since been developed by the Supreme Court in subsequent cases, such as "Waman Rao v. Union of India" (AIR 1981 SC 271), "Bhim Singhji v. Union of India" (AIR 1981 SC 234), "S.P. Gupta v. President of India" (AIR 1982 SC 149) (known as Transfer of Judges case), "S.P. Sampath Kumar v. Union of India" (AIR 1987 SC 386), "P. Sambamurthy v. State of Andhra Pradesh" (AIR 1987 SC 663), "Kihota Hollohon v. Zachilhu and others" (1992 1 SCC 309)," L. Chandra Kumar v. Union of India and others "(AIR 1997 SC 1125), "P. V. Narsimha Rao v. State (CBI/SPE)" (AIR 1998 SC 2120), "I.R. Coelho v. State of Tamil Nadu and others" (2007 2 SCC 1), and "Raja Ram Pal v. The Hon’ble Speaker, Lok Sabha and others" (JT 2007 (2) SC 1) (known as Cash for Query case).