The 'Basic Structure Doctrine' was enunciated by the Supreme Court during the:

The Kesavananda Bharati case was the culmination of a serious conflict between the judiciary and the Government, which was headed by Mrs Indira Gandhi. Though, the phrase 'basic structure' was introduced for the first time by M.K. Nambiar and other counsels while arguing for the petitioners in the Golaknath case, it was only in the Kesavanada Bharati's case that the concept surfaced in the text of the apex court's verdict.