High Quality Content by WIKIPEDIA articles! The basic structure doctrine is the judge-made principle that certain features of the Constitution of India are beyond the limit of the powers of amendment of the Indian parliament. The doctrine, which was first expressed by the Indian Supreme Court in Kesavananda Bharati v. State of Kerala (1973), reflects judicial concern at the perceived threat to the liberal constitutional order posed by the Indian National Congress` majority in central and state legislatures, in particular under Indira Gandhi.