• The IR Coelho v. State of Tamil Nadu (2007) case also referred to as the 9th Schedule Case and involved an exhaustive discussion on Article 31-B of the Indian Constitution. This case removed the shield that the legislature took to shield the laws violative of the fundamental rights, from judicial review. The judgment used the Kesavananda Bharati v State of Kerala (1973) as precedent. The supremacy of the judiciary as the final interpreter of law was finally restored. 
• The power to amend the Constitution was given in the hands of the legislature. In order to free India from the zamindari system. The Constitution went through its First Amendment, in the year 1951 when the Ninth Schedule became part of this document. It contains a list of central and state laws that are shielded from Judicial review. The Ninth Schedule is the detailed explanation of Article 31-B of the Indian Constitution. Initially, it had 13 laws, all of them aimed at land reforms but presently it contains 284 laws covering reservation, trade, industries, mine, etc. The tool to bring land reforms in India became a dustbin for governments. A constitutional dustbin of limitless capacity. 
• The Ninth Schedule tied the hands of the judiciary. Even if a law violated the fundamental rights it could be protected from being declared void by the judiciary by simply placing it in the Ninth Schedule outside the scope of judicial review. A key feature of the Ninth Schedule is that it is retrospective in nature. If a law is added in the Ninth Schedule after it is declared unconstitutional, it will be considered valid and part of the schedule from the date of its commencement.
• The Constitution of India has divided the powers of the legislature, the executive, and the judiciary. The judiciary is the final interpreter and the guardian of the Constitution. Judicial review is the power of the judiciary to check if the laws made by the legislature or the executives are in accordance with the constitutional values. This prevents the executive and the Legislature from acting in an arbitrary manner, maintaining the supremacy of the Constitution, and protecting the rights of the people. 

The basic structure is nothing but a tool or judicial innovation to ensure that the legislature does not abuse the power given to it in Article 368. There is no precise definition of what is part of the basic structure. It is an evolving concept and through various judgments, we now have a list of features that are part of the basic structure. Some of the features are:  

• Supremacy of the Constitution.
• Unity and sovereignty of India.
• A democratic and republican form of government.
• Federal character of the Constitution.
• Secular character of the Constitution.
• Separation of power.
• Individual freedom.
• Rule of law.
• Judicial review.
• Parliamentary system.
• Rule of equality.
• Harmony and balance between the Fundamental Rights and DPSP.
• Free and fair elections.
• Limited power of the parliament to amend the Constitution.
• Power of the Supreme Court under Articles 32, 136, 142, and 147.
• Power of the High Court under Articles 226 and 227.

This is just an indicative list and not a complete list.

• The judgment of the Court in IR Coelho v. State of Tamil Nadu (2007) case highlighted the following: 
• The basic structure is the very essence of the Indian Constitution any law amendment found inconsistent with Part 3 of the Indian Constitution even if it is in the Ninth Schedule would be struck down by the process of judicial review.  
• Every constitutional amendment has to be judged on its own merits. The ‘effect and impact’ test should be considered while determining if any law is damaging or destroying the basic structure.
• Effect and Impact test means that what part of the Constitution is being amended will not be considered for checking its validity, rather the consequences of the amendment on the Constitution will be a determinative factor.
• All the amendments made to the Constitution after 24th April 1973 have to go through a test if it is in accordance with the essential features of the Constitution as reflected in Article 21 read with Article 14 and Article 19.  
• Judicial review is a part of the basic structure and any law cannot be shielded from it.  
• The validity of the Ninth Schedule has already been upheld by this court and it will not be open to challenges on the principles declared in the judgment. However, any law added in the Ninth Schedule after 24th April 1973 violative of Article 21 read with Article 19 Article 14 and the principles underlying thereunder can be challenged.

The judgment has further strengthened the concept of basic structure doctrine in a constitutional setup that is so diverse that needs new amendments every now and then. The importance of Judicial review was again emphasized as it is an effective tool to protect the rights of the people. The sole intention of bringing the ninth schedule was to bring land reforms but soon enough it lost its focus and became a shield in the hands of the legislature, who abused this power. The judiciary through this case in very clear words stated that anything that is violative of the basic structure would be struck down. Thus, taking away the shield highlighting the basic structure doctrine.