Monday, January 23, 2023

Understanding India’s Constitutional Development: From British Enactments to Post-independence

 Writer's View Journal 

ISSN: 2456-3579

Vol. 6 No. 1 Varsh Pratipada 

Vikram Sambat 2078, Year 2021, Special Issue-I 

(An Interdisciplinary, Bilingual, Bi-annual, A peer Review, indexed and Open Accesses International Research Journal) 

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Understanding India’s Constitutional Development: From British Enactments to Post-independence

Abstract

The Constitution of a country is regarded as the fundamental law of the land which lays down a broader canvass to makes laws, rules and regulations for organizing the national life at both the collective and individual levels. It’s often argued that a Constitution is tailored in such a way that it succeeds to define how a country examines its past, determines its present and foresees its future. Unlike erstwhile Government of India Act, 1935, the present constitution adopted and enacted by the Constituent Assembly declared India as a Federal Democratic Socialist Secular Republic. The Constitution of India, the precursor of the new Indian renaissance, entered into force on January 26, 1950. The article delves to study the evolution and historical development of constitution in India.

Keywords:

Constitution, Historical background, India, British India


1.      Introduction

The Constitution of India and the basic structures it envisaged have allowed the democratic credentials to thrive on the sovereign soil of India. One of such basic structures has been the principle of federalism, which plays a stellar role in the consolidation of Indian democracy. In contrast to the British India regime, the current constitution establishes civil supremacy in the affairs of the state, giving life to the Abraham Lincoln’s memorable phrase: democracy is for the people, by the people and of the people.

The Constitution of India under Article 79 envisages for the Parliament of Republic, comprising House of People (i.e., Lok Sabha), Upper House (i.e., Rajya Sabha) and the President of India. The President of India does not sit in Parliament as a member but he is essential component of Parliament. Unlike United States, the Council of Ministers is collectively accountable to the Parliament in India. However, the members of Council of Ministers are personally accountable to the President in United States.  

To put it simply, “Though President is not a member of either House of parliament yet, like the British Crown, he is an integral part of the Parliament and performs certain functions relating to its proceedings. The President of America is not the integral part of Legislature. In India, the President summons two Houses of Parliament, dissolves the House of people and gives assent to Bills.[3] The keystone of the British Constitution is the doctrine of ‘sovereignty’ or ‘supremacy’ of parliament. In other words, the Parliament has the ultimate right to make or unmake any law whatever. “The Indian Parliament differs from its British counterpart in a substantial manner. Politically speaking, the Indian and British parliaments are both subject to similar restraints as both have parliamentary form of government. But, legally speaking, whereas the power of the British Parliament is undefined, that of the Indian parliament is defined, fettered and restrained. India’s Constitution is written; it is the fundamental law of the land; its provisions are enforceable by the courts and it cannot be changed in the ordinary legislative process. The Indian parliament has therefore to function within the constraints of Constitution from which its legislative powers emanate.”[4]

Moreover, “the Indian parliament is the creature of the Constitution. Therefore, a parliamentary law to be valid must in all conform in all respects with the Constitution. It is for the courts to decide whether an enactment is constitutional or not and they have the power to declare a parliamentary enactment void if it is inconsistent with a provision of Constitution. The courts would refuse to give effects to any unconstitutional law.”[5]   

Still, the pre-constitutional period largely departs from the current position and gives a depressing reality. For decades, Indians had to live under the rule of British colony for a no good reason. In 1600 AD, the British came to the Indian subcontinent to trade at the port of Surat, which is currently located in the state of Gujarat. In the 1750s, the East India Company began to intervene in political matters of India. When Robert Clive, an officer of the company, defeated the Bengal Nawab forces at the Battle of Plassey, the company saw an increase in its wealth and a change from a trading company to a dominant company in 1757. The British came to India in 1600 as traders, under the garb of East India Company, which had the exclusive right of trading in India under a charter granted by Queen Elizabeth-I. In 1765, the Company obtained the 'diwani' (rights over revenue and civil justice) of Bengal, Bihar and Orissa. This gave them an opportunity to emerge as a territorial power.

In 1858, in the wake of the ‘sepoy mutiny’, the British Crown assumed direct responsibility for the governance of India. This rule continued until India was granted independence on 15 August, 1947.[6] With the arrival of independence, India was in dire need of adopting a constitution, declaring India as a sovereign, democratic republic. A Constituent Assembly was formed for this purpose in 1946 and eventually, on 26 January, 1950, the Constitution of India came into being.  Although the arbitrary and undemocratic rule of British Raj was like bitter grapes, some of their colonial laws were of worthwhile consideration. Dr BR Ambedkar, the Chief Architect of Indian constitution, was of the view that about half of the provisions contained under the draft constitution (that is, current constitution) has been copied from the Government of India Act, 1935 and that the rest of it has been borrowed from the constitutions of other countries. He further said that there is nothing to be ashamed of in borrowing. The new thing in the constitution is that it contains provisions to accommodate the needs and aspirations of the people.[7] 

In fact, certain events in British rule established the legal framework for the organization and operation of the government and administrative agencies of British India. These events have greatly affected our constitution and government. The main focus of the paper is to shade light on the constitutional development after Indian Council Act, 1909.

2.      Historical Development

The historical background and evolution of the Indian Constitution can be studied under two broad heads:

  1. The Company Rule (1773 – 1858)
  2. The Crown Rule (1858 – 1947).

2.1  Scenario before Crown Rule

On December 31, 1600, Queen Elizabeth enacted a charter for a group of English Merchants, incorporating them into a body corporate to run trade under the name of Governor and Company of Merchants of London. Then, the Company of Merchants of London established a factory at Surat after obtaining the approval of the then Mughal Emperor Jahangir. This led to the establishment of many factories at different parts of India. The death of Mughal Emperor Aurangzeb in 1707 gave a jolt to the Mughal Empire. After sensing that the Mughal Empire was losing their ground, the British Company started establishing territorial supremacy over different parts of India.

In 1775, Robert Clive defeated Suraj-Ud-Dowla in the battle of Plessy. The saga of defeat does not end here. In 1764, English forces under the leadership of Major Munro defeated the Mir Khasim and Nawab Vazir of Oudh who had jointly fought against the English. This led to the military conquest of Bengal and Bihar.

The grant of Dewani by the Moghul Emperor Shah Alam in 1765, which provided a de jure basis for the exercise of British authority in Bengal, Bihar and Orissa, could be said to be the beginning of second period (1765-1858).[8] The company, which operated their business under the garb of trade and commerce for over a century and a half, started attributing territorial power in the idle of 18th century. In 1773, the Regulating Act, which was associated with the name of Lord North, provided a detailed provision for the administration of the Company’s Indian domains.  

Then, Pitt’s East India Company Act, 1784, which created a board of six commissioners to exercise “superintendence and control over all the British territorial possessions in the East Indies, and over the affairs of the united company of merchants trading thereto,” was passed to bring a system of double government.

The 1784 Act was modified in points of detail by successive charter acts of 1793, 1813 and 1853 continued to operate until the year of 1858.[9] Subsequently, the British parliament enacted Government of India Act of August 1858 after the mutiny of 1857. This Act vested powers over Indian territories to the Crown which was governed by East India Company.        

2.2  Dawn of Crown Rule

The British government took over the governance of India from East India Company in 1858, after unsuccessful attempts of Indians to overthrow that regime in 1857. Up to this time, the company was governing its possessions in India at the central level through the Governor General and his council and at the Provincial level through Governor and his council.[10] Then, Indian Councils Act, 1861 was brought into effect but this law did not provide any space to Indians. However, the Indian Councils Act, 1892 provided arrangement for the inclusion of Indians in the Legislative Councils but not in the Executive Councils.

Nevertheless, the Government of India Act of 1858 was the first statute passed by parliament which is marked as the beginning of the evolution of the Indian Constitution.[11] For most of the Nineteenth Century, India was ruled by the British. India was considered the jewel in the crown of the British Empire. Queen Victoria had been made Empress of India and the British had a major military presence in India.[12] In 1885, educated middle class nationals had founded the Indian National Congress (INC). Their aim was to get a much greater say in the way India was governed. In response to this development, the Morley-Minto reforms were introduced in 1909. Morley was the Secretary of State for India and Lord Morley was Viceroy of India. Their reforms lead to the creation of an office of governor in each province in India and Indian nationals were allowed to sit in the councils which advised these governors.[13]

Indian Councils Act of 1909, also known as the Morley-Minto Reforms, changed the name of the Central Legislative Council to the Imperial Legislative Council. The act introduced a system of Communal representation for Muslims by accepting the concept of ‘separate electorate.’ It was the first attempt to introduce a representative and popular element in Indian Administration. Lord Minto came to be known as the ‘Father of communal electorate’.[14]

In addition to this, in 1909, the Minto-Morley Reforms was passed to extend the powers of the Legislative Councils, though the composition or powers of the Executive Councils were not changed. This Act brought significant changes that include, hike in number of legislative members in the central legislature from 16 to 60. The memberships of legislatures of Madras, Bombay, Bengal, UP and Eastern Bengal were raised to 50 and 30 in case of Punjab and Burma. Moreover, the power of legislature was enlarged for serious discussions in matters relating to budget, right of any member to bring resolution for alteration in budget; and right to raise questions in proceedings, except in the matters concerning to military, political and provincial affairs, foreign relations or sub-judice cases.

The Act was introduced with an objective to ensure the accommodation of Indians in Governor General’s Council but in reality the same became a distant dream. However, the Secretary of State in 1907 had provided two berths to two Indians in his councils, one each at Governor’s council at Bombay and Madras.

The Act 1909 failed to survive for long for some of the obvious reasons. It provided power on each legislator to move a resolution for alteration of the budget but it did not made the president of the legislative council bound to pay heed to such resolution. Similarly, the unfettered power and control over law-making and finance remained with British. The provincial governments were not provided with autonomy as their power was subject to the (discretionary) power of Secretary of State of India. The Act did not host any scheme to address the concerns of Indians.

3.      Toward British India’s constitutional documents

On August 20, 1917, Montagu, the then Secretary of State for India, made a declaration in the House of Commons that the policy of His Majesty was to increase association of Indians in every branch of administration and for the self-governance institutions with a view to progressively realize the responsible government in India as an integral part of British Empire. After this historic announcement, Montagu and Lord Chemsford, the then Viceroy made a visit to India and submitted Montagu-Chelmsford Report. On the basis of this report, a Bill, which was examined by the Joint Select Committee, was introduced in the House that took the shape of Act in 1919, that is, the Government of India Act, 1919. The Act was the first comprehensive constitutional document of India.[15] This Act established the position of a High Commission with a sitting in London to represent India in England[16].

As per the Act, the superintendence, direction and control of the government of India were vested in the Governor-General-in-Council. The Governor General had the power to overturn the majority decisions of the council if he had a reason to believe that any of such a proposal could affect the safety, tranquility or interest of British India on its implementation. This Act too, like the previous Acts, did not provide for the mandatory inclusion of any Indian in the council. Also, the executive was not responsible to the legislature.

The Central legislature consisted of Governor general and two Houses, namely Council of States and the Legislative Assembly. A Bill, subject to the satisfaction of Governor General, could be introduced in either House. The Governor General had power to prevent any Bill from tabling in the House on the ground of being inconsistent to the interest of British India. The Governor General had the power to withhold the assent on any Bill and reserve the Bill for seeking further assent of His Majesty.

This way, it shows that the executive was not only unaccountable to the House but was also bestowed with the power to surpass the legislature. However, the concept of provincial autonomy was given life. The Presidencies of Bengal, Bombay and Madras and the provinces of Assam, Bihar, and Orissa, Punjab and UP declared as the Governor’s provinces, while the rest of the territory was put under Lt. Governor as in case of Burma or under a Chief Commission as in the case of Delhi, Coorg etc. The Governors and Councilors were appointed by His Majesty of England. The Ministers were appointed by Governor from amongst persons who were neither member of his council, nor other officials. They held the office during the pleasure of Governor and required to be elected members of state legislatures, if not at the time of appointment then within six months of such appointment. Ministers were not answerable to the legislature.

The provincial legislatures, called Legislative Councils, comprised of members of Executive Council and such other elected or nominated members. The members of the Council saw 70 per cent of elected members and not more than 20 percent to be from officials. The elected members were represented from various communities according to fixed quota. The term of the council was of three years unless dissolved earlier or extended by one year by Governor.

The Legislative Council had power to legislate on the wide matters, including that of finance. A Bill rejected by the council could be passed by the Governor. Every Bill passed by legislature was supposed to receive assent of Governor and then assent of Governor General to become a law. Also, the Bill so assented by the Governor and Governor General could be disallowed by the King.

In 1920, Gandhi announced that any constitution of India should not be a gift of the British but must be the product of Indian people enacted by the representatives elected by the people. The Congress Party had boycotted the provincial elections.

3.1  An appraisal of Government of India Act, 1935

In 1924, Reforms Inquiry Committee under the Chair of Sir Alexander Muddiman was appointed to suggest reformations in the Act. The majority of the committee felt the need of ensuring fair trial, while the minority proposed for the formation of Royal Commission to suggest constitutional reforms.

On November 8, 1927, Royal Commission known as Simon Commission was formed which suggested that the changes regarding the federal constitution or the other would be discussed among the people after Indian princes join federation.

In order to bring reformation in constitution, three round-table conferences were held; out of which two failed but one produced a white paper suggesting the formation of federation with autonomous provinces and for the creation of responsible government at the centre and provinces.

Then, in November 1934, a Joint Select Committee was formed under Chair of Marquess Linlithgow, which submitted recommendations and based on their recommendations, the Government of India, 1935 was adopted and it received Royal assent on August 2, 1935.

The Government of India Act, 1935 divided the country into two parts—the Governor’s Provinces and the Indian states. The Governor’s provinces were bound to be the member of the federation, while the Indian states had freedom to become such members by executing instrument of accession.[17] The Act, 1935 sought to change the character of government from unitary to federal.[18]

The central government had large control over the provinces. The executive comprised of Governor General and a Council of Ministers. The Governor General had to act on the aid and advice of the Council of Ministers, except in the matters of external affairs, defense and ecclesiastical affairs, administration of tribal areas or matters which were under the responsibility of Governor General. The Governor General had the power to legislate an ordinance and an Act. He could assume all or any powers of federal authorities. In case of Governor’s provinces, he was Governor General and with respect to the Indian states, he was representative of the England’s crown.

The federal legislature was composed of the King, represented by the Governor General, the council of state and the legislative assembly. The council of state consisted of 156 representatives of British India and not more than 104 representatives of Indian states. The Legislative Assembly was comprised of a maximum 125 representatives of Indian states nominated by the rulers of states and 250 representatives of British India elected by the provincial assemblies. The council of states was a permanent House with one-third of its members retiring every third year. In this legal framework, the Governor General had huge powers on legislating business.

The Government of India Act, 1935 had a provision for the Federal Court established at Delhi. It was comprised of Chief Justice and six other judges who were appointed by a warrant under Royal Sign Manual and who held the office until the age of 65 or removed earlier. The Federal Court had original, appellate and advisory jurisdiction. An appeal against the decision of Federal Court lied before the Privy Council.

The provincial executive consisted of the Governor and his council of Ministers. Like Governor General, Governor had the power to make laws under the subjects of his jurisdiction. He was not bound to act on the advice of council of Ministers.

The composition of the provincial legislature varied from the province to province. Out of 11 provinces, there were bicameral legislatures in six and unicameral in five. The duration of the Legislative Assembly, the lower House at provinces, was of five years; while in case of Legislative Council, upper House at provinces, one-third members renewed at every third year.

3.2  Constitutional development after 1935

In October 1940, the Viceroy announced that the coming into operation of federal part of constitution would be indefinitely postponed. In the same year, Muslim League passed its “Pakistan Resolution” at Lahore demanding the setting up of a separate sovereign Muslim state consisting of Muslim dominated provinces of India. In 1942, Cripps Mission was constituted under the chair of Sir Stanford Cripps who had proposed for constituting an Indian Union of Independent Dominion under British Commonwealth.  It moved many proposals including the election of members by Electoral College for the making of constitution.

The Congress party agreed to cooperate if a purely national cabinet could be appointed at the centre.[19]  However, Muslim Leagues rejected the proposal. Ultimately, Cripps Mission failed. Later, Indian Congress Committee passed the famous “Quit India” resolution demanding complete freedom from British India.

At this backdrop, its comprehensible that how Indian Congress favored Cripps Mission and later raised the agenda of complete freedom after the failure of Cripps Mission. It shows their greed of power and smartness in taking U-turn for the purpose of safe landing in politics.

In 1945, Lord Wavell, the then Viceroy of India, announced his proposals on radio “to ease the present political situation and to advance India towards her goal of full self-government.” Then, a cabinet Mission consisting of then Secretary of State for India Lord Pethick Lawrence, Sir Stanford Cripps and AV Alexander visited India on March 24, 1946 and made proposals including that of establishment of union of India consisting of the provinces and Indian states having the power to deal with subjects of defense, foreign affairs and communication with ancillary powers to raise finance for these subjects. The proposal also included other matters, like executive and legislature consisting of representatives of British India and of Indian states; residual powers with provinces; provincial legislature and executive; or Constituent Assembly at New Delhi consisting of all representatives for adopting a constitution.

On July 27, 1946, Muslim League which had accepted the proposal of Cabinet Mission earlier on June 6, 1946, reiterated its demand for the creation of sovereign Pakistan and they decided to go for “direct action” and to observe August 16, 1946 as “Direct Action Day”.

The effect of all this was violence in the country and non-cooperation of Muslim League in the Constituent Assembly which held its first session on December 9, 1946.[20]  Meanwhile, a national government under the leadership of Jawaharlal Nehru was formed on September 2, 1946. The Government was not supported by Muslim League, though they sent their representatives in the government on October 26, 1946. It shows that the Muslim League had interest in power sharing even under adverse situations or situations contrary to the party line.   

3.3 Mandates under 1947 Independence Act

In March 1947, Lord Mount Batten became Viceroy and on June 3, 1947 issued a statement that partition was the only solution to solve the existing problem. Finally, Mount Batten plan was given a shape and then Indian Independence Act, 1947 was enacted.

The Indian Independence Act, 1947 was passed by the British Parliament within less than a fortnight and got Royal assent on July 18, 1947. The Act provisioned for the creation of two Independent Dominions, India and Pakistan where Governor General appointed by King would hold an office at each dominion. It set August 15, 1947 as the date of establishment of Independent dominions of India and Pakistan. It provisioned the legislatures of two dominions would have sovereignty over enacting laws and the laws made by them would not be declared void in case of being inconsistent to the laws of England. The Act came into operation on August 15, 1947, paving the ways for making an end to 182 years old British Rule and Lord Mountbatten himself was worn-in as the first Governor General of free-India.

4.      Framing of the Constitution of India

Interestingly, the Constituent Assembly had convened its business much before the adoption of Indian Independence Act, 1947. The first sitting of the Constituent Assembly took place on December 9, 1946. The Constituent Assembly was a sovereign body formed in 1946 by British to draft a constitution suiting the normative structure of India.  Though the meeting was boycotted by the Muslim League, the members had reached to an understanding over the business and the election of the Interim President of the Assembly.      

On August 29, 1947, a Drafting Committee was formed under the chairmanship of DR BR Ambedkar which prepared a draft constitution that was put before the Constituent Assembly on February 21, 1948.  After a deliberate discussion over the draft, members to the Assembly proposed 7635 amendments and 2473 Amendment Resolutions were discussed. The members agreed to borrow scores of provisions from erstwhile Government of India Act, 1935 as well. The provisions like federal scheme, office of governor, judiciary, Public Service Commission, emergency provisions, or administrative details were borrowed from the Government of India Act, 1935.[21]

An Objective Resolution was moved by the Jawaharlal Nehru which prescribed the objectives of the constitution to be adopted and enacted by the Assembly. Sir BN Rao was appointed as the constitutional advisor to the Constituent Assembly. His main job was to suggest the Assembly to adopt best international practices under the constitution. It took 2 years 11 months 18 days to enact the Constitution of India.

On November 26, 1949, the Constitution was certified by the President of the Constituent Assembly Dr Rajendra Prasad and was declared as passed. While the provisions relating to citizenship, elections, provisional parliament, temporary and transitional provisions were given immediate effect, the rest of the provisions of the Constitution entered into force on January 26, 1950 and this date is taken as the date of commencement of the Constitution of India which is the supreme law of land in the world’s largest democracy. The Constitution which originally contained 8 schedules and 395 Articles, presently it hosts 395 Articles (total number 444), 22 Parts and 12 Schedules.

The Constitution of India begins with a preamble which declares India to be sovereign, socialist, secular, democratic republic. The terms socialist, secular and integrity were added in the preamble by virtue of 42nd amendment to the constitution of 1976. KM Munshi, a Constituent Assembly member, was of the opinion that the preamble reflected the change that had come over the country as a result of partition and integration of the Indian states. To a matter of pride and honor, the Constitution of India stands as one of the world’s most progressive constitutional documents that has rightly succeeded to unite over 1.38 billion people in a bond of trust and tranquility. 

5.      Conclusion

Prior to the enactment of Constitution of India, the people and the affairs of India were governed under the Government of India Act, 1935, which became effective in 1937. The Act, 1935 was enacted by the British government and correspondingly, it ensured the sovereignty of England in the affairs of India. The Act made a significant change in the constitutional affairs. It adopted federal character. The Indian Federation consisted of provinces in which British India was divided and the States under the native princes. 

In post-independence regime, India was in dire need of adopting a Constitution for the people, ensuring the rights, freedoms and complete sovereignty. The Constituent Assembly formed much before the independence was assigned to sketch a constitution for the Republic. Finally, the Constitution of India came into being on January 26, 1950 which is regarded as the date of commencement of Indian constitution. The Indian constitution is pregnant with democratic principles which have potential to help India thrive on the path of sovereign democracy, prosperity and tranquility. The federal democracy, independent judiciary, non-discrimination at private or public life, civil supremacy, or judicial review is hailed as the basic structures of the constitution.  In doing so, the constitution leaves no room for the revival of any colonial, unruly or undemocratic forces, like that of pre-independence era.

Adopting a nation’s Constitution is a matter of pride for every country and the people living therein. The ratification of the 1950 Constitution is a sign that the country was geared-up for consolidating the agendas of different political movements happened to oust the British Empire. It led to the overthrowing of a long-stayed British Raj. Under the new Constitution, India’s federal structure is merited with a development that divided the country into provinces, with clear lists of legislative powers for the central and provincial governments.

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[1] Asst. Professor, Department of Law, SRT Campus, Tehri, a constituent campus of HNB Garhwal University

[2] Judicial Officer, Dhanusha District Court, Janakpur, Nepal

[3] J.N.Pandey, Constitutional Law of India 502 (Central Law Publication, Allahabad, 51st edn., 2014).

[4] M.P. Jain, Indian Constitutional Law 115 (LexisNexis, Gurgaon, 7th edn., 2016).

[5] Ibid

[6] http://www.igntu.ac.in/eContent/BA-PoliticalScience-02Sem-DrudaySingh

Indian%20Government%20and%20Politics.pdf (accessed on 16-06-2021)

[7] J Sai Deepak, “Dr Ambedkar on constitutional morality”, The Daily Guardian, (Aug 14, 2020), available at: https://thedailyguardian.com/dr-ambedkar-on-constitutional-morality/ (Accessed on June 16, 2021).

[8] M Ramaswamy, Constitutional Developments in India 1600-1955 , p. 327 (Vol. 8, No. 3, May 1956) Standford Law Review , available at: https://www.jstor.org/stable/1226621 (accessed on June 15, 2021).

[9] Id at P. 328

[10] VN Shulka, The Constitution of India, A-4 (EBC Lucknow, 18th Edn., 2021).

[11] Meenakshi Chahar, “Historical background and evolution of Indian Constitution”, Legal Bites, (Oct 5, 2019), available at: https://www.legalbites.in/historical-background-and-evolution-of-the-indian-constitution/ (Accessed on June 18, 2021).

[12] https://www.historylearningsite.co.uk/modern-world-history-1918-to-1980/india-1900-to-1947/

[13] Ibid

[14]Department of political science, BA Course, available at: http://www.igntu.ac.in/eContent/BA-PoliticalScience-02Sem-DrudaySingh-Indian%20Government%20and%20Politics.pdf (Accessed on June 21. 2021).

[15] VN Shulka, The Constitution of India, A-6 (EBC Lucknow, 18th Edn., 2021).

[16]Constitutional history of India”, available at: https://constitutionnet.org/country/constitutional-history-india (Accessed on June 21, 2021).  

[17]VN Shulka, The Constitution of India, A-10 (EBC Lucknow, 18th Edn., 2021).

[18] M.P. Jain, Indian Constitutional Law 9 (LexisNexis, Gurgaon, 7th edn., 2016).

[19] VN Shulka, The Constitution of India, A-14 (EBC Lucknow, 18th Edn., 2021).

[20] Id at p A-16

[21] Constitution Day: Borrowed features in the Indian Constitution from other countries, India Today, (Nov 26, 2019), available at https://www.indiatoday.in/education-today/gk-current-affairs/story/constitution-day-borrowed-features-in-the-indian-constitution-1622632-2019-11-26 (Accessed on June 16, 2021).


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