JUDICIAL ACTIVISM VIS- A- VIS ARTICLE 243-O OF THE ...xajzkjdx.cn/gallery/252-april2020.pdf · Judicial Activism, Judicial Review, Free and Fair Election, democracy, Gram Panchayat

JUDICIAL ACTIVISM VIS- A- VIS ARTICLE 243-O OF THE

CONSTITUTION OF INDIA

Vaibhav Uniyal (Assistant Professor, Law College Dehradun, Uttaranchal

University, Dehradun)

Prof. Dr. Rajesh Bahuguna (Dean, Law College Dehradun, Uttaranchal

University, Dehradun)

KEYWORDS

Judicial Activism, Judicial Review, Free and Fair Election, democracy, Gram

Panchayat.

ABSTRACT

Free and fair election in India is counted as one of the most important features of the

doctrine of basic structure in the Constitution of India. To ensure free and fair

elections in the world’s largest Democracy it is the most vital condition that the

judiciary be kept independent from any sort of adversity. This shall enable the

judiciary to follow the doctrine of judicial review at its best and exhaust the doctrine

of judicial activism. Having said so, it becomes implied that judiciary be allowed to

look into the matters pertaining to the election (of whatever level) throughout the

territory of India.

However, one cannot ignore the provision mentioned under Article 243- O of the

Constitution of India which limits the jurisdiction of the judiciary for matters relating

to the conduct of elections at the Panchayat level. The Constitution (seventy third

amendment) Act, 1991 added part IX to the Constitution of India. The objective was

to realize the noble dream of Mr. M.K. Gandhi (the father of the nation). Adding part

IX was cherished by all as it seemed to fulfil the aim of the Constitution of India of a

“welfare state”. Article 243- O, however, seems to spoil the entire generous concept

by limiting the judiciary to such an extent that the entire democratic setup of the

Journal of Xi'an University of Architecture & Technology

Volume XII, Issue IV, 2020

ISSN No : 1006-7930

Page No: 2692

nation seems to fall apart. No check on the system of election means leaving the

democracy at its own sake.

The following words, hence, analyse the contradictory nature of Article 243- O of the

Constitution of India and the doctrine of Judicial Review in India.

INTRODUCTION

Judiciary for any democratic nation is the most important wing. It is the judiciary only

which ensures the proper functioning of the constitutional machinery of a nation. The

Indian system is a unique blend of common law and civil law system. Civil law as

opposed to the common law is the one which is codified. Codification of law ensures

transparency and accountability in governance of a nation. They are the most

important requisites of any independent nation. This system, however, has to be

ensured as fulfilled and followed in its very essence. The function of ensuring this

following of the law is done by the judiciary of the nation. The strength of the

judiciary, further, lies in the fact of its being independent such that it can effectively

put a check on the constitutionality and validity of any enactment in a nation. This

feature of the judiciary is known as ‘Judicial review’. Judicial review in India is

regarded as the basic feature of the Constitution of India. It ensures formulation and

check on laws in the terms of the Constitution of India.

Advancements in the twenty first century led to a newly modified and improved

system termed as ‘Judicial Activism’. In the simplest way explained judicial activism

means the active participation of the judiciary in making laws for the nation. The

Supreme Court of India has recently been making laws on almost every subject

relating to the life and personal liberty of a person by virtue of Article 21 of the

Constitution of India. Through these systems of ‘Judicial Activism’ and ‘Judicial

Review’, the Supreme Court guards the Constitution of India in the best possible

manner and yet there are certain provisions which are expressly barred from judicial

review in ‘the supreme law of the land’.

The following is an effort to analyse one of the provisions of the Constitution of India

which has been kept out of the reach of the judiciary, though it has been termed as

‘the basic feature of the Constitution of India’.



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JUDICIAL REVIEW

The doctrine of judicial review originated and developed in the U.S.A. It was

propounded for the first time in the famous case of Marbury v. Madison (1803) by

John Marshall, the then chief justice of the American Supreme Court. In this case,

chief justice Marshall made it very clear that it was the province of the judiciary to

interpret the law and also that the judiciary must not enforce any law which it

considers to be a violation of the provision of the Constitution. Thus, the judicious

opinion of John Marshall has become the corner- stone of the doctrine of judicial

review. The judiciary, by using this power, keeps the legislative and the executive

organs within the purview of the Constitution.

Judicial review has not been specifically mentioned in the Indian Constitution though

it has been implied in a number of Articles. The Supreme Court in India possesses the

power of judicial review. The judges swear to protect, preserve and defend the

Constitution at the time of their assuming office. They remain cautious and vigilant in

considering the Constitutional validity of various laws. The Supreme Court of India

declared several laws enacted by the Central and State governments as invalid when

they are formulated and implemented against the basic principles of the Constitution.

Under a written Constitution from which the organs of government derive their

powers, there must be a final arbiter to see that each of the organs keeps to its

constitutionally demarcated area. Hence, the courts, through judicial review, acts as

the ‘balancing wheel’ of the Constitution. The training will enable a judge to decide

matters after weighing the pros and cons of the case. Judges work in an impartial

atmosphere not charged with political passion and it is but proper that they have the

power of judicial review.1

The Constitution itself confers the power of judicial review on the judiciary (both the

Supreme courts as well as High courts). Further the Supreme Court has declared the

power of judicial review as a basic feature of the Constitution or an element of the

basic structure of the Constitution. Hence, the power of judicial review cannot be

curtailed or excluded even by a constitutional amendment.

1 Dr. Myneni S.R. “Political Science for law students”



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The Constitution is the supreme law of the land and any law inconsistent therewith is

void. The term refers to “the power of a court to inquire whether a law, executive

order or other official action conflicts with the written Constitution, and if the court

concludes that it does, to declare it unconstitutional and void.” In other words, judicial

review is the power exerted by the courts of a country to examine the actions of the

legislative, executive and administrative arms of government and to ensure that such

actions conform to the provisions of the nation’s constitution. The institution of

judicial review is predicated upon the existence of a written Constitution that is also

rigid in the sense of being changeable only by some extraordinary process, usually

requiring some special legislative or popular majorities. Normally, though not

invariably, judicial review is associated also with a federal Constitution, involving

division of legislative powers between a Central Government and member States and

with a bill of rights or some other system of fundamental limitation in law making

powers.

Judicial review has two prime functions:

1) Legitimising government action.

2) Protect the Constitution against any undue encroachment by the government.

In the framework of a constitution which guarantees individual fundamental rights,

divides power between the Union and the States and clearly defines and delimits the

powers and functions of every organ of the state including the Parliament, judiciary

plays a very important role under their powers of judicial review.

Judicial review is the power of the judiciary to examine the constitutionality of

legislative enactments and executive orders of both the central and state governments.

On examination, if found to be in violation of the Constitution (ultra vires), they shall

be declared as illegal, unconstitutional and invalid (null and void) by the judiciary.

Consequently, they cannot be enforced by the government.

The Supreme Court used the power of judicial review in various cases, as for

example, the Golaknath case(1967), the Bank Nationalisation case(1970), the Privy

Purses Abolition case(1971), the Kesavananda Bharti case(1973), the Minerva Mills

case(1980), and so on.



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In 2015, the Supreme Court declared both the 99th Constitutional amendment, 2014

and the National Judicial Appointments Commission (NJAC) Act, 2014 as

unconstitutional, null and void.

Judicial review is needed for the following reasons:

a) To uphold the principle of the supremacy of the Constitution.

b) To maintain federal equilibrium (balance between the Centre and the States).

c) To protect the Fundamental Rights of the citizens.

“In India it is the Constitution that is supreme and that a statute law to be valid, must

be in conformity with the constitutional requirements and it is for the judiciary to

decide whether any enactment is constitutional or not”.2

“Our constitution contains express provisions for judicial review of legislation as to

its conformity with the constitution. This is especially true as regards the Fundamental

Rights, to which the court has been assigned the role of sentinel on the qui vive”.3

“As long as some fundamental rights exist and are a part of the Constitution, the

power of judicial review has also to be exercised with a view to see the guarantees

afforded by these rights are not contravened”.4

“The Constitution is the supreme lex, the permanent law of the land, and there is no

branch of government above it. Every organ of government, be it the executive, the

legislature, or the judiciary, derives its authority from the Constitution and it has to act

within the limits of its authority. No one however highly placed and no authority

howsoever lofty, can claim that it shall be the sole judge of the extent of its power

under the Constitution or whether its action is within the confines of such power laid

down by the Constitution. This court is the ultimate interpreter of the Constitution and

to this court is assigned the delicate task of determining what is the power conferred

on each branch of government, whether it is limited, and if so, what the limits are, and

whether any action of that branch transgress such limits”.5

2 Chief Justice Kania in A.K. Gopalan v. State of Madras(1950). 3 Chief justice Patanjali Shastri in State of Madras v. V.G. Row(1952). 4 Justice Khanna in Kesavananda Bharti v. State of Kerala(1973). 5 Justice Bhagwati in Rajasthan v. Union of India(1977).



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“It is the function of the judges, may their duty, to pronounce upon the validity of

laws. If courts are totally deprived of that power, the Fundamental Rights conferred

on the people will become a mere adornment because rights without remedies are as

writ in water. A controlled Constitution will then become uncontrolled”.6

“The judges of the Supreme Court have been entrusted with the task of upholding the

Constitution and to this end, have been conferred the power to interpret it. It is they

who have to ensure that the balance of power envisaged by the Constitution is

maintained and that the legislature and the executive do not, in the discharge of their

functions, transgress constitutional limitations”.7

“The founding fathers very wisely, therefore, incorporated in the Constitution itself

the provisions of judicial review so as to maintain the balance of federalism, to protect

the fundamental rights and fundamental freedoms guaranteed to the citizens and to

afford a useful weapon for availability, availment and enjoyment of equality, liberty

and fundamental freedoms and to help to create a healthy nationalism. The function of

judicial review is a part of constitutional interpretation itself. It adjusts the

constitution to meet new conditions and needs of the time”.8

Though the phrase ‘Judicial Review’ has nowhere been used in the Constitution, the

provisions of several Articles explicitly confer the power of judicial review on the

Supreme Court and the High Courts. These provisions inter alia are:

1) Article 13 declares that all laws that are inconsistent with or in derogation of

the Fundamental Rights shall be null and void.

2) Article 32 guarantees the right to move the Supreme Court for the enforcement

of the Fundamental Rights and empowers the Supreme Court to issue

directions or orders or writs for that purpose.

3) Article 226 empowers the High Courts to issue directions or orders or writs for

the enforcement of the fundamental rights and for any other purpose.

The constitutional validity of a legislative enactment or an executive order can be

challenged in the Supreme Court or in the High Courts on the following grounds:

6 Chief Justice Chandrachud in Minerva Mills v. Union of India(1980). 7 Chief justice Ahmadi in L. Chandra Kumar v. Union of India(1997). 8 Justice Ramaswami in S.S. Bola v. B.D. Sharma(1997).



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a) It infringes the Fundamental Rights (Part III).

b) It is outside the competence of the authority which has framed it.

c) It is repugnant to the constitutional provisions.

Although it is said that the Indian Constitution does not afford the same scope of

judicial creativity to the courts as does the U.S Constitution. In spite of all this, the

Supreme Court does play a significant role in the Indian Constitutional process. Since

the commencement of the Constitution, the Supreme Court has rendered hundreds of

decisions expounding various provisions of the Constitution, and thus, a distinct

Constitutional jurisprudence has come into existence. In many cases, the Supreme

Court has displayed judicial creativity of a high order. The high watermark of such

judicial creativity in India has been reached in such landmark cases as Golak Nath,

Keshvananda Bharti and Maneka Gandhi. In these cases, the role of the Supreme

Court is comparable to being constituent or constitution making.

JUDICIAL ACTIVISM

The concept of judicial activism originated and developed in U.S.A. This term was

first coined in 1947 by Arthur Schlesinger Jr., an American historian and educator. In

India, the doctrine of judicial activism was introduced in mid 1970s. Justice V.R.

Krishna Iyer, Justice P.N. Bhagwati, Justice O. Chinappa Reddy and Justice D.A.

Desai laid the foundation of judicial activism in the country.

Judicial activism denotes the proactive role played by the judiciary in the protection

of the rights of citizens and in the promotion of justice in the society. In other words,

it implies the assertive role played by the judiciary to force the other two organs of the

government (legislature and executive) to discharge their Constitutional duties.

Judicial activism is also known as judicial dynamism. It is the antithesis of “judicial

restraint”, which means self control exercised by the judiciary.

Judicial activism is a way of exercising judicial power that motivates judges to depart

from normally practised strict adherence to judicial precedent in favour of progressive

and new social policies. It is commonly marked by decision calling for social



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engineering, and occasionally these decisions represent intrusion in the legislative and

executive matters.9

Judicial activism is the practice in the judiciary of protecting or expanding individual

rights through decisions that depart from established precedent, or are independent of,

or in opposition to supposed constitutional or legislative intent.10

The concept of judicial activism is closely related to the concept of Public interest

litigation (P.I.L). It is the judicial activism of the Supreme Court which is the major

factor for the rise of P.I.L. In other words, P.I.L is an outcome of judicial activism. In

fact, P.I.L is the most popular form (or manifestation) of judicial activism.

According to Webster dictionary, ‘activism’ means ‘being active’. In this sense every

judge is an activist. Prof. Baxi noted that the term ‘activism’ has been used more in

ascriptive sense where judges are evaluated as activists by various groups in terms of

their interest, ideologies and values. Justice Bhagwati says the term ‘judicial activism’

is not the term of ‘fashion’ or ‘popularism’ but a term signifying an important source

of judicial power which judges should use for realization of ‘willed result’. Justice

Krishna Iyer once remarked that “every judge was an activist either in forward gear or

on the reverse gear.” According to justice Bhagwati, ‘judicial activism in India is

being used for achieving distributive justice which is otherwise labelled as ‘social

justice’.

Judicial activism centres on the issue whether judges do or do not make law or ought

or ought not to make law. However, the plain fact is that appellate justices make law,

not merely interpret law.

Judicial activism is but conscious exercise by judges of the power of judicial review

to meet changing needs of time. A wise and activist judge is one who needs the limits

on judicial power and the judicial function yet is ingenious and courageous to mould

the law case by case to answer the needs of the time. The law is not broken but it is

evolved. Judicial activism is defined as shaping of the basic law through bold act. The

court provides the moral leadership and clarifies the values and deals for a country

that had shown itself to be really in need of such guidance.

9 Black’s law dictionary. 10 Merriam Webster’s law dictionary.



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JUDICIAL ACTIVISM IN INDIA AND PUBLIC INTEREST LITIGATION

An activist judge should keep in mind the nature of the Constitution. Indian

Constitution is not only a legal document; it is also a socio- political document, a

repository of the values and aspirations of the people. The very objective of the Indian

Constitution is to establish an egalitarian society. In this regard, preamble of the

Constitution declares justice, social, economic and political to everyone and equality

of status and opportunity to all.

JUDICIAL ACTIVISM AND THE BASIC STRUCTURE OF THE

CONSTITUTION

The Supreme Court has created not only the ordinary law but also Constitutional law

in the course of its interpretative powers. The first phase of judicial activism

commenced from Kesavananda Bharti wherein Supreme Court evolved the basic

structure doctrine and any amendment which violates the basic structure of

Constitution is declared void. Although the judges enumerated certain essentials of

the basic structure of the Constitution, but they have made it clear that they were only

illustrative and not exhaustive. They will be determined on the basis of the facts in

each case.

According to Sikri C.J., the basic structure of the Constitution consists of the

following features:

1) Supremacy of the Constitution;

2) Republic and Democratic forms of the Government;

3) Secular Characteristic of the Constitution;

4) Separation of powers between the legislature, the executive and the judiciary;

5) Federal character of the Constitution.

Shelat and Grover, J.J., added the following to the basic structure of the Constitution

to the above list:

1) Dignity of the individual secured by various freedoms and basic rights in part

III and the mandate to build a welfare State contained by part V.

2) Unity and integrity of the nation.



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In Minerva Mills case, the Supreme Court has held that the following are the basic

features of the Constitution:

1) Limited power of Parliament to amend the Constitution.

2) Harmony and balance between Fundamental Rights and Directive Principles.

3) Fundamental rights in certain cases.

4) Power of judicial review in certain cases.

In the recent past, the Supreme Court has become the centre of controversy on

account of the sudden outburst in the level of judicial activism. Judicial activism has

been criticised by politicians and some Constitutional experts while it has been

welcomed generally by the lawyers and the public.

In a country, hit by rampant corruption and constant erosion of democratic norms, the

Supreme Court orders and judgments during 1996 came like a breadth of fresh air.

The Court in jain hawala, chandraswami and environmental degradation cases,

exercised jurisdiction with courage, creativity and circumspection giving proof of

vision, vigilance and practical wisdom.

By sensitising the Central Bureau of Investigation (C.B.I) and other Central

Investigating Agencies to the need to perform their constitutional obligations, the

apex court exposed magnitude of corruption in high places, particularly in the housing

scandal, fodder scam, Lakhubhai Pathak cheating and St. Kitts forgery cases.

It is felt that the judiciary for some years has been overwilling to jump into the arena

of legislative and executive functions. There appears to be a general agreement that in

recent years the Indian Supreme Court has brought out more far reaching changes

than the legislature and executive combined. Judicial activism, in fact, is not a

distinctly separate concept from usual judicial activities. The expression ‘activism’,

lexically as well as in ordinary parlance, means ‘being active’, ‘doing things with

decision’ and the expression ‘activist’ should mean ‘one who favours intensified

activities’. In this sense every judge is, or at least, should be an activist, as justice

Krishna Iyer observed, “Every judge is an activist either on the forward gear or on the

reverse.”

Judicial policy making can either be an activity in support of the legislative and

executive policy choices or in opposition to them. But, it is the latter pattern of



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activity that is usually styled as judicial activism and not policy making as such.

Judicial activism is policy making in competition with policy making by the

legislature and executive. The essence of true judicial activism is the rendering of

decisions which are in tune with the temper and tempo of the times.

Activism is judicial policy making which furthers the cause of social change or

articulates concepts such as liberty, equality or justice. Activism counters the

traditional concept that judiciary is a mere umpire; it on the contrary should work as

an active catalyst in the constitutional scheme. It has to be an arm of the social

revolution. An activist judge activates the legal mechanism and makes it play a vital

role in socio- economic process.

“Government by Judiciary,” Fehrendbacher writes, is now, in a sense democracy’s

non- democratic alternative to representative government when the latter bogs down

in failure of inaction. According to Upendra Baxi, if the executive or the legislature

defaults on its legal and constitutional obligations, courts cannot for long take a view

that violations of rights involved in such defaults are of no concern to them. What,

therefore, emerges is that province of judicial function can be construed only in the

context of the work being done by the other branches of the Constitution.

Ideally, Parliament and the executive are the custodians of honest public life. They

should, indeed, remove the mask which the corrupt wear and they are the ones who

should initiate action against those who steal, cheat or deceive. But when the

custodians themselves compromise with corruption or politicise it, the judiciary has to

step in. This is what has happened.

The Hawala diaries would have accumulated dust in the archives of C.B.I if the Supreme

Court had not forced the agency to take action against the recipients of illegal money.

Again, it was the Supreme Court which goaded and prodded the C.B.I to push the

proceedings.

The concept of judicial activism can be seen to be reflecting from the following trends

namely: expansion of rights of hearing in the administrative process; excessive

delegation without limitation, expansion of judicial control over discretionary powers;

expansion of judicial review over the administration; promotion of open government;

indiscriminate exercise of contempt power; exercise of jurisdiction when non- exist;



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over extending the standard rules of interpretation in its search to achieve economic,

social and educational objectives; and passing of orders which are per se unworkable.

In India, there are two major aspects of judicial activism followed by Indian judiciary.

The first comes in the form of various directions issued by the courts to the

government authorities for protecting fundamental and other rights of citizens and for

the fulfilment of a course of public interest. All the cases coming under the P.I.L are

covered under this aspect of judicial activism. The famous cases, where the court has

issued directions under P.I.L are: Agra Protection Home Case, Bihar (Bhagalpur)

under trial criminal case, the case of Bombay pavement dwellers, Sunil Batra v. Delhi

administration, case of construction workers of Tilonia (Rajasthan), Bandhua Mukti

Morcha v. Union of India, Asiad workers case, Peoples’ Union for democratic

reforms v. Union of India etc.

The second major aspect of judicial activism in India in the field of interpretation of

fundamental rights, particularly right to equality (Art. 14), right to freedom (Art. 19)

and right to life and personal liberty (Art. 21). The courts have discretion to expand

the scope of these rights. There is scope for a judge to read his personal philosophy

into the provisions. The power of interpretation sometimes had the effect of

undermining the powers of Parliament also. For example, in Keshvananda Bharti

case, 1973, the Supreme Court invented the principle of ‘Basic Structure’ which caps

the power of Parliament to alter or amend certain features of the Constitution. Similar

is the case with government decisions giving primacy to fundamental rights whereas

the Parliament resolving to give primacy to certain directive principles of state

policies over Fundamental Rights.

ARTICLE 243-O

What article 243-O contemplates is that an election to the Panchayat may be called in

question, only by means of an election petition provided under the law framed in that

behalf. It is not permissible to trace the powers of the court under Article 32 or Article

226 of the Constitution while that is expressly injuncted by the Constitution itself. The

negative expression in Article 243-O excludes the extraordinary jurisdiction conferred

on the High Court under Article 226 and constitutes as a Constitutional injunction

forbearing the court from exercising judicial review with respect to matters referred

therein. However, it is one thing to say that judicial review is forbidden by



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Constitutional means and yet another thing to declare that judicial review can only be

in the manner provided by the legislation enacted in that behalf invoking Article 243-

O. The providing of a legal remedy to review the election process saves the power of

courts to review the election process as also the criticism that judicial review is being

excluded. As such, it has to be held that an election coming within the ambit of

Article 243- O can be judicially reviewed.

Learned author M.P. Jain in his book on “Indian Constitutional Law” has stated:

“There are very good reasons for taking the view that the private clauses contained in

Articles 243- O and 243- ZG should not be allowed to curtail judicial review under

Articles 32 and 226. This is because of the Constitutional fundamental, accepted by

the Supreme Court in a large number of cases, that judicial review is a basic feature of

the Constitution which cannot be diluted by any Constitutional amendment. In some

pronouncements the analogy of Article 329 has been brought to interpret Articles 243-

O and 243- ZG. But, on a deeper consideration, this analogy is not correct even

though the phraseology of all these provisions is similar. There is a fundamental

difference between Article 329 and other Constitutional provisions.

Article 329 is part and parcel of the original Constitution and its interpretation became

established before the doctrine of “Basic features of the Constitution” emerged. On

the other hand, Articles 243- O and 243 ZG were added through Constitutional

amendments very much after the doctrine of judicial review being a basic feature of

the Constitution had become very well established.

Empowering an Executive District Magistrate to decide election disputes pertaining to

reserve candidates was held ultra vires Article 243- O. In that case, to adjudicate

election disputes pertaining to other constituencies was entrusted to judicial tribunal.

Entrusting adjudicating work to election disputes from the election tribunal subject to

judicial control to executive was held impermissible. (Hoti Lal v. State of U.P., A.I.R

2002 All 257.)

CONCLUSION

Whereas it is expedient in the interest of any Democratic nation to have a strong and

independent judiciary to ensure maintainability of the democratic system itself, the

Indian Union has been able to ensure so. Practises carried by the courts particularly



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the Supreme Court of India have proved the worth. Judicial review and judicial

activism, though criticised at large by legal scientists, are amongst the most prominent

features of the Indian judiciary. Even so, judicial review itself has been declared as

one of the features of the basic structure of the Constitution of India. Free and fair

election is another important dimension of the doctrine of basic structure as held by

the court in the case of Raj Narain v. Indira Nehru Gandhi.

The fact that village is the smallest unit of the country cannot be denied. Article 243-

O of the Constitution of India provides for non- interference of judiciary in electoral

matters of gram Panchayats. The “guardian of the Constitution of India” hence is not

allowed to look into the matter which is being termed as the basic structure of “the

supreme law of the land”.

In an era where there is no denial of the fact that judicial review and judicial activism

are the requirements of the hour, keeping aside a very important feature of the

doctrine of basic structure (i.e. free and fair elections) is in no case justified. It is clear

from the above discussion that Article 243- O stands in the way of the implementation

of judicial activism and judicial review at the fullest. If “free and fair elections” is one

of the key features of “the doctrine of basic structure” of the Constitution of India,

how will it be ensured without the judiciary being able to review it? Either “free and

fair elections” can be one of the features of “the doctrine of basic structure”, or the

courts can be barred from exercising any sort of jurisdiction over Article 243- O of

the Constitution of India.

REFERENCES

Manor James “Democratic decentralisation in India”; Sida 2003 Embassy of

Sweden, New Delhi

Johnson Craig “Decentralisation in India: Poverty, Politics and Panchayati Raj”;

Department of Political Science University of Guelph, Ontario Overseas Development

Institute 111 Westminster Bridge Road London SE1 7JD UK

Myneni S.R. “political science for law students”; Allahabad law agency, law

publishers Faridabad



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Arora N.D. “Political science for Civil services Main Examination”; Tata McGraw

Hill Education Private Limited, New Delhi

Fadia B.L. Fadia Kuldeep “Indian Government and Politics”; Sahitya Bhawan, Agra

Basu D.D. Introduction to The Constitution of India”; Lexis Nexis 21st edn.



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