The Supreme Court has held that even during a National Emergency under Article 352, constitutional resilience must be preserved, meaning core constitutional features like basic structure cannot be destroyed, ensuring Constitution's identity preserved even during crisis.

Constitutional resilience during Emergency: (a) Basic structure doctrine: Core constitutional features (basic structure) cannot be destroyed even by constitutional amendment, even during Emergency, (b) Application to Emergency: (i) Even during Emergency, constitutional resilience preserved: Core features (democracy, secularism, federalism, judicial review, rule of law, dignity) cannot be destroyed, (ii) Emergency powers subject to constitutional resilience: Actions cannot alter core constitutional features, even during crisis, (iii) Judicial review: Courts can examine whether Emergency actions preserve constitutional resilience, not just procedural compliance, (c) Applications: (i) Post-1978: Courts more willing to strike down Emergency actions violating constitutional resilience, (ii) Rights protection: Ensures core constitutional features preserved even during crisis, (d) Rationale: (i) Constitutional supremacy: Constitutional resilience preserves constitutional identity against arbitrary power, even during crisis, (ii) Rights protection: Core features essential for rights protection, democratic governance, even during Emergency, (iii) Democratic legitimacy: Ensures Emergency powers used for genuine crisis response, not constitutional alteration, (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.