In Indian constitutional law, in which of the following Supreme Court cases was it held that fundamental rights were unamendable by Parliament?

Introduction / Context:
The relationship between Parliament's power to amend the Constitution and the protection of fundamental rights has been a central theme in Indian constitutional law. Several landmark Supreme Court judgments have addressed whether Parliament can amend or abridge fundamental rights. This question asks which case specifically held that fundamental rights were unamendable, a doctrine that played a crucial role in the constitutional debate before later developments such as the basic structure doctrine.

Given Data / Assumptions:

• The cases listed are A. K. Gopalan, Keshvananda Bharati, M. C. Mehta, and Golak Nath.
• The question is about the Supreme Court holding that fundamental rights are unamendable.
• We assume basic familiarity with landmark cases on constitutional amendments and rights.

Concept / Approach:
In the 1967 case I. C. Golak Nath v. State of Punjab, the Supreme Court, by a slim majority, held that Parliament has no power to amend Part III of the Constitution, which contains fundamental rights. The Court treated constitutional amendment under Article 368 as law within the meaning of Article 13 and therefore subject to the limitation that laws violating fundamental rights are void. This effectively meant that fundamental rights were unamendable. Later, in the 1973 Keshvananda Bharati case, the Court modified this position and introduced the basic structure doctrine, holding that Parliament can amend fundamental rights so long as it does not damage the basic structure of the Constitution. Therefore, the strict unamendability doctrine is specifically associated with Golak Nath, not with the later cases.

Step-by-Step Solution:
Step 1: Recall that A. K. Gopalan mainly dealt with personal liberty and preventive detention, not directly with the power to amend fundamental rights.Step 2: Remember that M. C. Mehta cases are environmental law cases and do not concern the amending power regarding fundamental rights.Step 3: Note that Keshvananda Bharati introduced the basic structure doctrine, allowing amendments including those affecting fundamental rights, subject to not damaging the basic structure, and therefore did not declare rights completely unamendable.Step 4: Recall that Golak Nath case held that Parliament could not amend or abridge fundamental rights at all, treating them as unamendable.Step 5: On this basis, select Golak Nath case as the correct answer.

Verification / Alternative check:
To verify, consider the timeline. Golak Nath judgment in 1967 created a strong restriction on Parliament's amending power by declaring fundamental rights unamendable. This led to a constitutional and political response and later amendments. Keshvananda Bharati judgment in 1973 partly relaxed this by allowing amendments but limiting them through the basic structure doctrine. Standard constitutional law textbooks and exam notes summarise Golak Nath as the case where fundamental rights were held to be unamendable, which confirms this answer.

Why Other Options Are Wrong:
A. K. Gopalan case: This case primarily interpreted Article 21 and the concept of procedure established by law; it did not centre on Parliament's power to amend fundamental rights.

Keshvananda Bharati case: This judgment allowed Parliament to amend any part of the Constitution, including fundamental rights, so long as the basic structure was not damaged. It did not treat fundamental rights as entirely unamendable.
M. C. Mehta case: This name refers to a series of public interest environmental cases, such as Oleum gas leak and Ganga pollution, which are unrelated to the amending power over fundamental rights.

Common Pitfalls:
Many students confuse Golak Nath with Keshvananda Bharati because both deal with Article 368 and constitutional amendments. Some may mistakenly pick Keshvananda Bharati, thinking of its importance in constitutional law, without recalling the precise holding about unamendability. To avoid this, remember the chronological sequence: Golak Nath declared fundamental rights unamendable, and Keshvananda Bharati later modified this by introducing the basic structure doctrine that balances amendment power with constitutional limitations.

Final Answer:
The Supreme Court held that fundamental rights were unamendable in the Golak Nath case.