In the context of Indian Polity, the concept of judicial review in the Indian Constitution has been borrowed from the constitution of which country?

Introduction / Context:
Judicial review is a central feature of modern constitutional democracies. In India, this power allows the higher judiciary to examine laws and executive actions and to strike them down if they violate the Constitution. The framers did not invent this idea in isolation. They studied several foreign constitutions and consciously borrowed useful features. This question tests knowledge of comparative constitutional influences on the Indian Constitution and asks from which country the specific idea of judicial review was taken. Understanding this origin helps aspirants connect Indian Polity with wider global constitutional practice and situate the Supreme Court of India within a broader tradition of constitutional courts that act as guardians of fundamental rights and the basic structure of the Constitution.

Given Data / Assumptions:

• The subject is Indian Polity and constitutional design.
• The focus is on the concept of judicial review of legislation and executive action.
• The question asks about the foreign constitution from which this idea was borrowed.
• The options list four countries with written or unwritten constitutional traditions.

Concept / Approach:
Judicial review in simple terms is the power of courts to test the validity of laws and government actions against the Constitution. If any law is inconsistent with constitutional provisions, the court can declare it void. The United States of America developed a strong model of judicial review through case law, especially through the famous decision in Marbury v Madison in 1803. The Indian Constituent Assembly closely studied this model. While provisions for judicial review are written explicitly in the Indian Constitution, the inspiration and core logic of courts striking down unconstitutional laws is clearly borrowed from the American system, not from the British parliamentary tradition where Parliament is legally supreme. Therefore the correct approach is to recall this well known linkage between Indian and United States constitutional practice.

Step-by-Step Solution:

Step 1: Recall that Britain has parliamentary sovereignty, so courts there traditionally cannot invalidate Acts of Parliament. This makes England an unlikely source for the strong Indian style of judicial review. Step 2: Remember that the United States Constitution operates under the doctrine of constitutional supremacy, where the Constitution is above ordinary law and the Supreme Court claims power to strike down inconsistent laws. Step 3: During Constituent Assembly debates, many members referred to the American model when discussing the role of the Supreme Court of India as guardian of fundamental rights. Step 4: Canada and Australia have federal constitutions and some forms of judicial review, but exam oriented polity texts clearly point out that the Indian concept is mainly borrowed from the United States. Step 5: On this basis, select USA as the correct answer from the given options.

Verification / Alternative check:
A quick way to verify the answer is to map major constitutional features and their sources. Parliamentary system and cabinet responsibility come mainly from Britain. Directive Principles have roots in the Irish Constitution. Fundamental Rights, judicial review, and the idea of a written supreme Constitution are closely linked with the United States model. Most standard polity reference books present a table of borrowed features where judicial review is listed under the United States. This cross checking confirms that USA is the correct source country in this question.

Why Other Options Are Wrong:
England: The British system is based on parliamentary sovereignty, so courts historically do not strike down primary legislation, making it an incorrect source for strong judicial review. Canada: While Canada has a written Constitution and judicial review, Indian exam syllabi do not treat it as the primary source for this feature. Australia: The Australian Constitution influenced federal structure, not mainly the power of judicial review in Indian Polity. These three countries therefore do not match the specific borrowed feature asked in the question.

Common Pitfalls:
Many learners know that India borrowed several features from many countries but confuse which feature came from where. A common mistake is to associate judicial review with England simply because India followed the British parliamentary system. Another error is to assume that any federal country like Canada or Australia must be the source without checking standard tables of borrowed provisions. Some aspirants also mix up sources of Fundamental Rights, judicial review, and due process, even though their exam oriented mapping to the United States is quite consistent. Careful memorisation of these linkages prevents such confusion.

Final Answer:
The concept of judicial review in the Indian Constitution was primarily borrowed from the Constitution of the USA.