The Supreme Court has held that even during a National Emergency under Article 352, the basic structure of the Constitution cannot be destroyed, meaning amendments or actions during Emergency cannot alter core features like democracy, secularism, federalism, judicial review.

Emergency and basic structure doctrine: (a) Constitutional principle: Basic structure doctrine (Kesavananda Bharati, 1973) holds that Parliament cannot amend Constitution to destroy core features (democracy, secularism, federalism, judicial review, rule of law, dignity), (b) Application to Emergency: (i) Even during Emergency, basic structure cannot be destroyed; Emergency powers subject to basic structure limits, (ii) Actions during Emergency (legislation, executive orders) cannot alter core constitutional features, (iii) Judicial review: Courts can examine whether Emergency actions comply with basic structure, not just procedural compliance, (c) Applications: (i) Post-1978: Emergency actions subject to basic structure review; courts strike down actions violating core features, (ii) Federal balance: Ensures Emergency powers used for genuine crisis response, not destruction of constitutional identity, (d) Rationale: (i) Constitutional supremacy: Basic structure preserves constitutional identity against transient majorities, even during crisis, (ii) Rights protection: Core features essential for rights protection, democratic governance, even during Emergency, (iii) Democratic legitimacy: Emergency powers enable crisis response but cannot alter foundational constitutional values, (e) Illustrates constitutional resilience: Basic structure doctrine ensures Constitution's core identity preserved even during crisis; balance between crisis response capacity and preservation of constitutional democracy.