Forty-second Amendment of the Constitution of India
|The Constitution (Forty-second Amendment) Act, 1976|
|Parliament of India|
|An Act further to amend the Constitution of India.|
|Enacted by||Lok Sabha|
|Date passed||2 November 1976|
|Enacted by||Rajya Sabha|
|Date passed||11 November 1976|
|Date assented to||18 December 1976|
|Date commenced||3 January 1977|
|Bill introduced in the Lok Sabha||The Constitution (Forty-fourth Amendment) Bill, 1976|
|Bill published on||1 September 1976|
|Introduced by||H.R. Gokhale|
|Bill introduced in the Rajya Sabha||Constitution (Forty-fourth Amendment) Bill, 1976|
|Bill published on||4 November 1976|
|43rd and 44th Amendments|
|Provides for curtailment of fundamental rights, imposes fundamental duties and changes to the basic structure of the constitution by making India a "Socialist Secular" Republic|
|Status: Substantially amended|
The Forty-second Amendment of the Constitution of India, officially known as The Constitution (Forty-second Amendment) Act, 1976, was enacted during the Emergency (25 June 1975-21 March 1977) by the Indian National Congress government headed by Indira Gandhi. Most provisions of the amendment came into effect on 3 January 1977, others were enforced from 1 February and Section 27 came into force on 1 April 1977. The 42nd Amendment is regarded as the most controversial constitutional amendment in Indian history. It attempted to reduce the power of the Supreme Court and High Courts to pronounce upon the constitutional validity of laws. It laid down the Fundamental Duties of Indian citizens to the nation. This amendment brought about the most widespread changes to the Constitution in its history, and is sometimes called a "mini-Constitution" or the "Constitution of Indira".
Almost all parts of the Constitution, including the Preamble and amending clause, were changed by the 42nd Amendment, and some new articles and sections were inserted. Seven of the thirteen consequential provisions were designed to weaken judicial review, and the amendment's fifty-nine clauses stripped the Supreme Court of many of its powers and moved the political system toward parliamentary sovereignty. It curtailed democratic rights in the country, and gave Gandhi the constitutional authority to do almost anything she wanted, by providing sweeping powers to the Prime Minister's Office, virtually exempting it from any kind of scrutiny. The amendment gave Parliament unrestrained power to amend any parts of the Constitution, disallowing judicial review of those changes. It also deprived citizens of direct access to the Supreme Court; gave Directive Principles of State Policy precedence over Fundamental Rights, and made any law passed in pursuance of a Directive Principle immune from scrutiny by the Supreme Court; and transferred more power from the state governments to the central government, eroding India's federal structure. The 42nd Amendment also amended the Preamble and changed the characterization of India from "sovereign democratic republic" to a "sovereign, socialist secular democratic republic", and also changed the words "unity of the nation" to "unity and integrity of the nation".
The Emergency era had been widely unpopular, and the 42nd Amendment was the most controversial issue. The amendment drew nationwide criticism, and the clampdown on civil liberties and widespread abuse of human rights by police angered the public. The Janata Party which had promised to "restore the Constitution to the condition it was in before the Emergency", won the 1977 general elections. The Janata government then brought about the 43rd and 44th Amendments in 1977 and 1978 respectively, to restore the pre-1976 position to some extent, and undo the more draconian parts of the 42nd Amendment. However, the Janata Party was not able to fully achieve its objectives. In order to pass the 44th Amendment in the Rajya Sabha by the requisite two-thirds majority, it needed the support of the Congress party, which had by then split into two again, with one group supporting Gandhi and others opposed to her. Congress members from both factions, supported many of the changes the Janata government wanted to bring, but they also refused some.
On 31 July 1980, in its judgement on Minerva Mills v. Union of India, the Supreme Court declared two provisions of the 42nd Amendment which prevent any constitutional amendment from being "called in question in any Court on any ground", and accord precedence to the Directive Principles of State Policy over the Fundamental Rights of individuals respectively, as unconstitutional.
Proposal and enactment
Then Prime Minister Indira Gandhi set up a committee in 1976 under the Chairmanship of then Minister of External Affairs Swaran Singh "to study the question of amendment of the Constitution in the light of experience". The 42nd Amendment was enacted following the recommendations of the Swaran Singh Committee.
The bill for the Constitution (Forty-second Amendment) Act, 1976 was introduced in the Lok Sabha on 1 September 1976, as the Constitution (Forty-fourth Amendment) Bill, 1976 (Bill No. 91 of 1976). It was introduced by H.R. Gokhale, then Minister of Law, Justice and Company Affairs. It sought to amend the Preamble and articles 31, 31C, 39, 55, 74, 77, 81, 82, 83, 100, 102, 103, 105, 118, 145, 150, 166, 170, 172, 189, 191, 192, 194, 208, 217, 225, 226, 227, 228, 311, 312, 330, 352, 353, 356, 357, 358, 359, 366, 368 and 371F and the Seventh Schedule. It also sought to substitute articles 103, 150, 192 and 226; and insert new Parts IVA and XIVA and new articles 31D, 32A, 39A, 43A, 48A, 131A, 139A, 144A, 226A, 228A and 257A in the Constitution. In a speech in the Lok Sabha on 27 October 1976, Gandhi claimed that the amendment "is responsive to the aspirations of the people, and reflects the realities of the present time and the future".
The bill was debated by the Lok Sabha from 25 to 30 October and November 1 and 2. Clauses 2 to 14, 6 to 16, 18 to 20, 22 to 28, 31 to 33, 35 to 41, 43 to 50 and 56 to 59 were adopted in their original form. The remaining clauses were all amended in the Lok Sabha before being passed. Clause 1 of the bill was adopted by the Lok Sabha on 1 November and amended to replace the name "Forty-fourth" with "Forty-second", and a similar amendment was made on 28 October to Clause 5 which sought to introduce a new article 31D to the Constitution. Amendments to all the other clauses were adopted on 1 November and the bill was passed by the Lok Sabha on 2 November 1976. It was then debated by the Rajya Sabha on 4, 5, 8, 9, 10 and 11 November. All amendments made by the Lok Sabha were adopted by the Rajya Sabha on 10 November, and the bill was passed on 11 November 1976. The bill, after ratification by the States, received assent from then President Fakhruddin Ali Ahmed on 18 December 1976, and was notified in The Gazette of India on the same date. Sections 2 to 5, 7 to 17, 20, 28, 29, 30, 33, 36, 43 to 53, 55, 56, 57 and 59 of the 42nd amendment came into force from 3 January 1977. Sections 6, 23 to 26, 37 to 42, 54 and 58 went into effect from 1 February 1977 and Section 27 from 1 April 1977.
The Act was passed in accordance with the provisions of Article 368 of the Constitution, and was ratified by more than half of the State Legislatures, as required under Clause (2) of the said article. State Legislatures that ratified the amendment are listed below:
Did not ratify:
The amendment had four major purposes. First, to exclude the courts entirely from election disputes. This was to protect Gandhi's election to Parliament, as well as future elections contested by her and her successors. The same immunity was also extended to the President, the Vice President and the Speaker. An amendment to the 42nd Amendment bill, which had sought to grant lifelong immunity from civil or criminal prosecution to the three officials mentioned as well the Prime Minister, was dropped after it was passed by the Lok Sabha but had yet to be sent to the Rajya Sabha. The amendment's opponents described it as a "convenient camouflage".
Second, the amendment transferred more power from the state governments to the central government, eroding India's federal structure; and enabling the Centre to rule the country as a unitary, not a federal, system. The third purpose of the amendment was to give Parliament unrestrained power to amend any parts of the Constitution, disallowing judicial review of those changes and also give maximum protection to social revolutionary legislation from judicial challenge. The fourth purpose was to give Directive Principles of State Policy precedence over Fundamental Rights, and make any law passed in pursuance of a Directive Principle immune from scrutiny by the Supreme Court. This was described by supporters of the measure, as a way "to trim" the judiciary so as to "make it difficult for the court to upset parliament's policy in regard to many matters".
|This article is part of the series:
Constitution of India
Almost all parts of the Constitution, including the Preamble and amending clause, were changed by the 42nd Amendment, and some new articles and sections were inserted. Some of these changes are described below.
The 42nd Amendment deprived citizens of direct access to the Supreme Court, except when violation of the fundamental rights resulted from Central law. The Parliament was given unrestrained power to amend any parts of the Constitution, disallowing judicial review of those changes. This essentially invalidated the Supreme Court's ruling in Kesavananda Bharati v. State of Kerala in 1973. The amendment to article 368, prevented any constitutional amendment from being "called in question in any Court on any ground". It also declared that there would be no limitation whatever on the constituent power of Parliament to amend by way of definition, variation or repeal the provisions of the Constitution. The 42nd Amendment also restricted the power of the courts to issue stay orders or injunctions. A person holding an office of profit is disqualified from the membership of Parliament or State Legislature under the Constitution. The 42nd Amendment revoked the courts' power to determine constituted an office of profit. A new article 228A was inserted in the Constitution which would gave High Courts the authority to "determine all questions as to the constitutional validity of any State law". Seven of the thirteen consequential provisions were designed to weaken judicial review. The amendment's fifty-nine clauses stripped the Supreme Court of many of its powers and moved the political system toward parliamentary sovereignty. The 43rd and 44th Amendments reversed these changes. The 44th Amendment removed most of the restrictions imposed by the 42nd Amendment on the powers of the High Court and the Supreme Court.
Article 74 was amended and it was explicitly stipulated that "the President shall act in accordance with the advice of the Council of Ministers". However, no such provision was made regarding the Governors of states, leaving them with certain discretionary functions to discharge without being bound by ministerial advice. Article 352 was amended to authorize the President to vary proclamation of emergency, which he could not do previously. Changes were also made to Articles 353, 358 and 359 to provide for this. Prior to the 42nd Amendment, the proclamation of Emergency under Article 356 required approval from Parliament to operate at the end of every six months, but this period was now extended to one year. Article 357 was amended so as to ensure that laws made for a State, while it was under Article 356 emergency, would not cease immediately after the expiry of the emergency, but would instead continue to be in effect until the law was changed by the State Legislature. Articles 358 and 359 were amended, to allow suspension of Fundamental Rights, and suspension of enforcement of any of the rights conferred by the Constitution during an Emergency.
The 42nd Amendment added new Directive Principles, viz Article 39A, Article 43A and Article 48A. The amendment to Article 31C gave precedence to all Directive Principles over the Fundamental Rights, irrespective of any inconsistency they may have with any of the rights conferred by Articles 14, 19 or 31. The 42nd Amendment gave primacy to the Directive Principles, by stating that "no law implementing any of the Directive Principles could be declared unconstitutional on the grounds that it violated any of the Fundamental Rights". The Amendment simultaneously stated that laws prohibiting "antinational activities" or the formation of "antinational associations" could not be invalidated because they infringed on any of the Fundamental Rights. The 43rd and 44th Amendments repealed the 42nd Amendment's provision that Directive Principles take precedence over Fundamental Rights, and also curbed Parliament's power to legislate against "antinational activities". The 42nd Amendment also added a new section to the Article on "Fundamental Duties" in the Constitution. The new section required citizens "to promote harmony and the spirit of common brotherhood among all the people of India, transcending religious, linguistic and regional or sectional diversities."
The 42nd Amendment enlarged central power to intervene in the states, extending the term of President's rule from six months to a year, and also gives the Union Government the right to authorize the use of any central military force "for dealing with any grave situation of law and order in any State." The 42nd Amendment granted power to the President, in consultation with the Election Commission, to disqualify members of State Legislatures. Prior to the Amendment, this power was power vested in the Governor of the State. Article 105 was amended so as to grant each House of Parliament, its members and committees the right to "evolve" their "powers, privileges and immunities", "from time to time". Article 194 was amended to grant the same rights as Clause 21 to State Legislatures, its members and committees. Two new clauses 4A and 26A were inserted into article 366 of the Constitution, which defined the meaning of the terms "Central Law" and "State Law" by inserting two new clauses 4A and 26A into article 366 of the Constitution.
The 42nd Amendment froze any delimitation of constituencies for elections to Lok Sabha, and State Legislative Assemblies, at the point of 1971 census until the first census after the year 2000, by amending article 170 (relating to composition of Legislative Assemblies). The total number of seats in the Lok Sabha and the Assemblies remained the same until the 91st Amendment, passed in 2003, extended the freeze up to 2026. The number of seats reserved for the Scheduled Castes and Scheduled Tribes in the Lok Sabha and State Legislative Assemblies was also frozen by the 42nd Amendment, and the quorum in a House of Parliament or a State Legislature was left to be determined by each House. The amendment also extended the term of Lok Sabha and Legislative Assemblies members from five to six years, by amending article 172 (relating to MLAs) and Clause(2) of Article 83 (for MPs).
Amendment of the Preamble
The 42nd Amendment changed the characterization of India from a "sovereign democratic republic" to a "sovereign, socialist secular democratic republic", and also changed the words "unity of the nation" to "unity and integrity of the nation". Hormasji Maneckji Seervai, a jurist and an eminent authority on the Constitution, severely criticized this amendment stating that the newly inserted words are "ambiguous" and "should not have been inserted in the Preamble without a reason".
B. R. Ambedkar, the principal architect of the Constitution, was opposed to declaring India's social and economic structure in the Constitution. During the Constituent Assembly debates on framing the Constitution in 1946, K.T. Shah proposed an amendment seeking to declare India as a "Secular, Federal, Socialist" nation. In his opposition to the amendment, Ambedkar stated, "My objections, stated briefly are two. In the first place the Constitution, ... , is merely a mechanism for the purpose of regulating the work of the various organs of the State. It is not a mechanism where by particular members or particular parties are installed in office. What should be the policy of the State, how the Society should be organised in its social and economic side are matters which must be decided by the people themselves according to time and circumstances. It cannot be laid down in the Constitution itself, because that is destroying democracy altogether. If you state in the Constitution that the social organisation of the State shall take a particular form, you are, in my judgment, taking away the liberty of the people to decide what should be the social organisation in which they wish to live. It is perfectly possible today, for the majority people to hold that the socialist organisation of society is better than the capitalist organisation of society. But it would be perfectly possible for thinking people to devise some other form of social organisation which might be better than the socialist organisation of today or of tomorrow. I do not see therefore why the Constitution should tie down the people to live in a particular form and not leave it to the people themselves to decide it for themselves. This is one reason why the amendment should be opposed. His second objection was that the amendment was "purely superfluous" and "unnecessary", as "socialist principles are already embodied in our Constitution" through Fundamental Rights and the Directive Principles of State Policy. Referring to the Directive Principles, he asked Shah, "If these directive principles to which I have drawn attention are not socialistic in their direction and in their content, I fail to understand what more socialism can be". Shah's amendment failed to pass, and the Preamble remained unchanged until the 42nd Amendment.
During the Emergency, Indira Gandhi implemented a 20-point program of economic reforms that resulted in greater economic growth, aided by the absence of strikes and trade union conflicts. Encouraged by these positive signs and distorted and biased information from her party supporters, Gandhi called for elections in May 1977. However, the Emergency era had been widely unpopular, and the 42nd Amendment was the most controversial issue. Almost all parts of the Constitution saw changes through this amendment. It drew nationwide criticism, and the clampdown on civil liberties and widespread abuse of human rights by police had angered the public.
In its election manifesto for the 1977 elections, the Janata Party promised to "restore the Constitution to the condition it was in before the Emergency and to put rigorous restrictions on the executive's emergency and analogous powers". The election ended the control of the Congress (Congress (R) from 1969) over the executive and legislature for the first time since independence. After winning the elections, the Moraji Desai government attempted to repeal the 42nd Amendment. However, Gandhi's Congress party held 163 seats in the 250 seat Rajya Sabha, and vetoed the government's repeal bill.
The Janata government then brought about the 43rd and 44th Amendments in 1977 and 1978 respectively, to restore the pre-1976 position to some extent, and undo the more draconian parts of the 42nd Amendment. The amendments first removed some of the particular devices Gandhi had used to clear the way for executive prerogative. The President could only be asked to proclaim a State of Emergency upon the decision of the Cabinet conveyed to him in writing. The provision for protecting the Prime Minister from the normal consequences of campaign law violations was repealed. The amendments also curbed Parliament's power to legislate against "antinational activities". The 44th Amendment removed most of the restrictions imposed by the 42nd Amendment on the powers of the High Court and the Supreme Court. It also declared that the "right to life" could not be suspended during an Emergency, as was the case earlier. However, the Janata Party was not able to fully achieve its objectives. In order to pass the 44th Amendment by the requisite two-thirds majority, it needed the support of the Congress party, which had by then split into two again, with one group supporting Gandhi and others opposed to her. Congress members from both factions, supported many of the changes the Janata government wanted to bring, but they also refused some, such as the precedence given to Directive Principles over Fundamental Rights, and the exclusion of socio-economic laws from judicial review.
Legal challenges of the amendment
The constitutionality of sections 4 and 55 of the 42nd Amendment were challenged in Minerva Mills v. Union of India, when Charan Singh was caretaker Prime Minister. Section 4 of the 42nd Amendment, had amended Article 31C of the Constitution to accord precedence to the Directive Principles of State Policy articulated in Part IV of the Constitution over the Fundamental Rights of individuals articulated in Part III. Section 55 prevented any constitutional amendment from being "called in question in any Court on any ground". It also declared that there would be no limitation whatever on the constituent power of Parliament to amend by way of definition, variation or repeal the provisions of the Constitution. On 31 July 1980, when Indira Gandhi was back in power, the Supreme Court declared sections 4 and 55 of the 42nd amendment as unconstitutional. It further endorsed and evolved the basic structure doctrine of the Constitution. In the judgement on Section 4, Chief Justice Yeshwant Vishnu Chandrachud wrote:
Three Articles of our Constitution, and only three, stand between the heaven of freedom into which Tagore wanted his country to awake and the abyss of unrestrained power. They are Articles 14, 19 and 21. Article 31C has removed two sides of that golden triangle which affords to the people of this country an assurance that the promise held forth by the preamble will be performed by ushering an egalitarian era through the discipline of fundamental rights, that is, without emasculation of the rights to liberty and equality which alone can help preserve the dignity of the individual.
On Section 4, Chandrachud wrote, "Since the Constitution had conferred a limited amending power on the Parliament, the Parliament cannot under the exercise of that limited power enlarge that very power into an absolute power. Indeed, a limited amending power is one of the basic features of our Constitution and therefore, the limitations on that power can not be destroyed. In other words, Parliament can not, under Article 368, expand its amending power so as to acquire for itself the right to repeal or abrogate the Constitution or to destroy its basic and essential features. The donee of a limited power cannot be the exercise of that power convert the limited power into an unlimited one." The ruling was widely welcomed in India, and Gandhi did not challenge the verdict. The Supreme Court's position on constitutional amendments laid out in its judgements in Golak Nath v. State of Punjab, Kesavananda Bharati v. State of Kerala and the Minvera Mills case, is that Parliament can amend the Constitution but cannot destroy its "basic structure".
On 8 January 2008, the Supreme Court issued notice to the Centre and the Election Commission (EC) on a petition, filed by Sanjiv Agarwal of the Kolkata-based NGO Good Governance India Foundation, challenging the validity of Section 2 of the 42nd Amendment, which inserted the word "socialist" in the Preamble to the Constitution. Fali Nariman, counsel for the petitioner, argued that the 42nd Amendment evolved in the climate of national Emergency and violated the basic structure of the Constitution. The NGO also challenged Section 29A(5) of the Representation of People Act, 1951, a rip-off from the 42nd Amendment which mandates political parties to pledge allegiance to the principles of socialism, failing which they would not be registered with the EC. In its first hearing of the case, Chief Justice K. G. Balakrishnan, who headed the three-judge bench, observed, "Why do you take socialism in a narrow sense defined by communists? In broader sense, it means welfare measures for the citizens. It is a facet of democracy. It hasn't got any definite meaning. It gets different meanings in different times." Justice Kapadia stated that no political party had, so far, challenged the amendment and everyone had subscribed to it. The court would consider it only when any political party challenged the EC. However, the Supreme Court asked the Centre and the EC to explain why political parties should swear allegiance to socialism. The petition was withdrawn on 12 July 2010 after the Supreme Court declared the issue to be "highly academic". The Bench observed, "This question is highly academic. Let us not go into it now."
The 42nd Amendment is regarded as the most controversial constitutional amendment in Indian history. It drew nationwide criticism, for providing sweeping powers to the Prime Minister's Office, virtually exempting it from any kind of scrutiny, The amendment has been criticized by legal experts and political activists for attempting to deprive citizens of direct access to the Supreme Court. It started a debate in the country over whether the amendment sought to change the very basic structure of the Constitution. Chief Justice Y.V. Chandrachud reacting to the amendment stated, "Government and Judges might come and go but democracy; the basic features of the Constitution should remain eternal". The Indian Express, in 1998, stated that the 42nd Amendment "was almost like rewriting the Constitution", and that it "reflected the extreme politics of the Emergency times".
In the book JP Movement and the Emergency, historian Bipan Chandra wrote, "Sanjay Gandhi and his cronies like Bansi Lal, Minister of Defence at the time, were keen on postponing elections and prolonging the emergency by several years ... In October–November 1976, an effort was made to change the basic civil libertarian structure of the Indian Constitution thorough the 42nd amendment to it. ... The most important changes were designed to strengthen the executive at the cost of the judiciary, and thus disturb the carefully crafted system of Constitutional checks and balance between the three organs of the government." Chandra states that the Emergency centralised and concentrated unlimited state and party power in the hands of the Prime Minister to be exercised in an "authoritarian manner" through a small coterie of politicians and bureaucrats.
- Hart, Henry C. (April 1980). "The Indian Constitution: Political Development and Decay". Asia Survey, Vol. 20, No. 4, Apr., 1980. University of California Press. Retrieved 12 April 2012.
- Dev, Nitish. "Constitutional Amendments of India". PublishYourArticles.org. Retrieved 12 April 2012.
- John R. Walker (June 21, 1977). "Janata's flaws shown by wins in northern India". The Calgary Herald. Southam News Services. Retrieved 21 November 2013.
- John R. Walker (June 22, 1977). "Janata continues winning in India". Ottawa Citizen. Southam News Services. Retrieved 21 November 2013.
- "The bill finally cometh". The Sunday Indian. August 21, 2011. Retrieved 2013-11-23.
- R.C. Bhardwaj, ed. (01). Constitution Amendment in India (Sixth ed.). New Delhi: Northern Book Centre. pp. 76–84;190–196. Retrieved 21 November 2013.
- "Forty Second Amendment". Indiacode.nic.in. Retrieved 2013-11-26.
- Lok Sabha Debates, Fifth Series, vol. 65, no.3, cols.141-2.
- "Parliament Has Unfettered Right". Indira Gandhi, Selected Speeches and Writings, vol.3. pp. 283–91.
- "The Constitution (Amendment) Acts". Constitution.org. Retrieved 2013-11-25.
- Granville, Austin. Working A Democratic Constitution - The Indian Experience. p. 371.
- "'Issue too academic', so PIL on socialism in statute withdrawn". The Indian Express. 2010-07-13. Retrieved 2013-11-23.
- "The Rise of Indira Gandhi". Library of Congress Country Studies. Retrieved 2009-06-27.
- "A living legend". The Indian Express. 24 January 1998. Retrieved 2013-11-23.
- "Indian Constitution: Sixty years of our faith". The Indian Express. 2010-02-02. Retrieved 2013-11-23.
- Prateek Deol. "42nd Constitutional Amendment: A Draconion Act Of Parliament - Gujarat National Law University". Legalserviceindia.com. Retrieved 2013-11-23.
- "India - The Constitution". Countrystudies.us. Retrieved 2013-11-23.
- "Spotlight: Even modified Indian model will be 'too little too late' for Sri Lankan Tamils". Tamilcanadian.com. 2006-11-08. Retrieved 2013-11-23.
- "Delimitation of constituencies". The Hindu. 2001-09-17. Retrieved 2013-11-23.
- "CONSTITUENT ASSEMBLY OF INDIA - VOLUME VII". NIC. 15 November 1948. Retrieved 2013-11-23.
- Paul R. Brass (1994). The Politics of India Since Independence. Cambridge University Press. pp. 40–50. ISBN 978-0-521-45970-9.
- "When in doubt, amend". Indian Express. 2009-08-21. Retrieved 2013-11-23.
- Raghav Sharma (2008-04-16). "Minerva Mills Ltd. & Ors. v. Union of India & Ors: A Jurisprudential Perspective". Social Science Research Network. Retrieved 2012-07-17.
- "Minerva Mills Ltd. & Ors. vs. Union of India & Ors.". Open Archive. Retrieved 2012-07-17.
- "Front Page : 'Socialist' tag in statute challenged". The Hindu. 2008-01-09. Retrieved 2013-11-23.
- "India a socialist nation? SC says keep the tag". Ibnlive.in.com. 2008-01-08. Retrieved 2013-11-23.
- J. Venkatesan (2010-07-13). "Petition against term "socialist" in Constitution rejected". The Hindu. Retrieved 2013-11-23.
- "New book flays Indira Gandhi's decision to impose Emergency". IBN Live News. 2011-05-30. Retrieved 2013-11-23.