In which of the following cases did the Supreme Court rule that Constitutional Amendments were also laws under Article 13 of the Constitution of India, which could be declared void for being inconsistent with Fundamental Rights ?

In the landmark case of I.C. Golaknath v. State of Punjab (1967), the Supreme Court reversed its earlier stance from the Shankari Prasad and Sajjan Singh cases [5]. By a narrow 6:5 majority, the Court ruled that Fundamental Rights occupy a 'transcendental and immutable' position, meaning Parliament cannot abridge or take away these rights [4]. Crucially, the Court held that a Constitutional Amendment Act is also a 'law' within the meaning of Article 13(2) [6]. Consequently, any amendment that violates Fundamental Rights would be considered void [5]. This interpretation was later countered by Parliament through the 24th Amendment Act (1971), which specifically amended Article 13 and Article 368 to state that Article 13 does not apply to constitutional amendments [2]. The Kesavananda Bharati case (1973) subsequently overruled Golaknath but introduced the 'Basic Structure' doctrine [1].

Sources

1. [2] Laxmikanth, M. Indian Polity. 7th ed., McGraw Hill. > Chapter 12: Basic Structure of the Constitution > EMERGENCE OF THE BASIC STRUCTURE > p. 127
2. [5] Indian Polity, M. Laxmikanth(7th ed.) > Chapter 8: Fundamental Rights > Laws inconsistent with fundamental rights > p. 77
3. [4] https://en.wikipedia.org/wiki/I._C._Golaknath_and_Others_v._State_of_Punjab_and_Anothers
4. [6] Indian Polity, M. Laxmikanth(7th ed.) > Chapter 90: Landmark Judgements and Their Impact > SHANKARI PRASAD CASE (1951) > p. 625
5. [1] Indian Polity, M. Laxmikanth(7th ed.) > Chapter 12: Basic Structure of the Constitution > EMERGENCE OF THE BASIC STRUCTURE > p. 127