Which Supreme Court case established the 'Doctrine of Eclipse', stating that existing laws inconsistent with Fundamental Rights are not null and void ab initio, but become dormant or eclipsed?

💡 Solution & Explanation

The Supreme Court formulated the Doctrine of Eclipse in the Bhikaji Narain Dhakras case, ruling that pre-constitutional laws violating fundamental rights are not rendered void ab initio but remain eclipsed and unenforceable until the constitutional obstruction is removed. Cases like Kesavananda Bharati addressed the amending power of Parliament under the basic structure theory rather than pre-constitutional law dormancy. This doctrine ensures that dormant statutes can regain full legal force if the corresponding constitutional restrictions are subsequently amended.