The Supreme Court held in Minerva Mills case (1980) that judicial review is part of the basic structure and cannot be abrogated by constitutional amendment.

Minerva Mills Ltd. v. Union of India (1980): SC struck down parts of 42nd Amendment that sought to exclude judicial review of constitutional amendments. Held: judicial review is part of basic structure; Parliament cannot destroy it. Also held balance between Fundamental Rights (Part III) and Directive Principles (Part IV) is basic structure. Reinforced Kesavananda doctrine.