It was 

thought and believed by Palkhivala that the trained judicial perceptions can 

identify the elements and define the contours of the basic structure but, 

despite the long and skilled arguments of the petitioner's counsel and the 

numerous detailed judgments of the Supreme Court, the essential elements 

• of the so-calledIt was 

thought and believed by Palkhivala that the trained judicial perception3

 can 

identify the elements and define the contours of the basic structure but, 

despite the long and skilled arguments of the petitioner's counsel and the 

numerous detailed judgments of the Supreme Court, the essential elements 

of the so-called basic structure defy clear identification. Even the judges 

who support the theory of basic structure define it in different ways. Even 

if one is able to see the vague outlines of the basic structure, the element 

of permanence which is supposed to be its bed-rock is far from certain. 

Whether there are certain unencroachable limits of the basic structure or 

not, it is very clear to this author that there are certain limits of judicial 

review which the judiciary should refrain from transgressing. basic structure defy clear identification. Even the judges 

who support the theory of basic structure define it in different ways. Even 

if one is able to see the vague outlines of the basic structure, the element 

of permanence which is supposed to be its bed-rock is far from certain. 

Whether there are certain unencroachable limits of the basic structure or 

not, it is very clear to this author that there are certain limits of judicial 

1. review which the judiciary should refrain from transgressing.

•