[ Dissent ]
Subba Rao in Sajjan Singh: the dissent that drew the line eight years before Kesavananda did
In 1965, four judges of the Supreme Court held that Parliament's amending power was unlimited. The fifth, Justice K. Subba Rao, said the question was open. Eight years later, Kesavananda agreed. A reconstruction of the dissent that the Court had refused to entertain, and the doctrinal architecture it quietly assembled.