The case of I.R. Coelho (Dead) by Lrs vs. State of Tamil Nadu & Ors. revolved around the interpretation of the scope of protection granted under the Ninth Schedule of the Indian Constitution. The Ninth Schedule was introduced through the First Amendment to provide protection to certain laws from judicial review, essentially making them immune to challenges on the grounds of violating fundamental rights. The dispute centered on whether laws added to the Ninth Schedule after April 24, 1973, could be subjected to judicial review if they violated fundamental rights.

• 1. Scope of the Ninth Schedule: Whether laws included in the Ninth Schedule after the date of the Kesavananda Bharati case (April 24, 1973) are protected from judicial review.
• 2. Judicial Review of Fundamental Rights: Whether laws placed in the Ninth Schedule after the aforementioned date could be challenged on the grounds of violating fundamental rights.

The Supreme Court, in its observation, clarified that while the Ninth Schedule provides protection to laws from judicial review under Article 31-B of the Constitution, this protection is not absolute. The Court recognized that the purpose of the Ninth Schedule was to prevent the striking down of laws that aimed to achieve socio-economic reforms. However, it noted that the fundamental rights guaranteed by the Constitution are essential and cannot be completely overridden by any legislation, even those included in the Ninth Schedule.

The Court observed that the protection granted by the Ninth Schedule does not extend to laws that violate the basic structure of the Constitution. The basic structure doctrine, established in the Kesavananda Bharati case, implies that certain fundamental principles of the Constitution cannot be altered or destroyed by amendments. Therefore, any law included in the Ninth Schedule that infringes upon these fundamental principles is open to judicial review.

The Supreme Court held that laws added to the Ninth Schedule after April 24, 1973, are indeed subject to judicial review if they contravene the basic structure of the Constitution. This decision upheld the principle that fundamental rights and the basic structure doctrine are inviolable and cannot be compromised, even by amendments that place laws in the Ninth Schedule. The judgment effectively balanced the need for legislative protection with the enduring supremacy of constitutional values.