the freezing of the law rejects judicial independence. Rutter believes that as long as the subject matter of judicial review remains within the common law, "courts are the proper and only authentic expositors of what the law is at any given time". Basic features doctrine Teo Soh Lung is also significant because the High Court denied the application of the basic features doctrine in Singapore. This doctrine, first developed in Indian case law, prevents attempted constitutional amendments which abrogate any of its "basic structure" or "essential features" even if the procedural requirements for constitutional amendments are met. Chua J. held that the doctrine was not applicable to the Singapore Constitution: "Considering the differences in the making of the Indian and our Constitution, it cannot be said that our Parliament's power to amend our Constitution is limited in the same way as the Indian Parliament's power to amend the Indian Constitution." In Malaysia, the basic features doctrine was also found to be inapplicable by the Federal Court in Phang Chin Hock v. Public Prosecutor. The Court remarked that the Indian Constitution was not drafted by "mere mortals", while the same could not be said for the Malaysian Constitution. The Indian Constitution was drafted by a constituent assembly representative of the Indian people in territorial, racial and community terms, while both the Malaysian and Singapore Constitutions were enacted by ordinary legislatures. Reliance on the drawing of distinctions between the Indian Constitution on the one hand and the Malaysian and Singapore Constitutions on the other on the basis of the history of their framing has been criticized as weak and inadequate. A contrary opinion notes that the basic features doctrine is necessary to provide a legal safeguard for the basic structure of the Constitution. The less permanence judges attach to the Constitution the more easily it can be eroded, and the less stability is accorded to the "supreme law of the land". This fear can be reinforced by the example of Hitler's "legal" rise to power in 1933 – the lack of restrictions on constitutional amendment allowed him to diminish the Weimar Constitution and set up his dictatorship. With the dominance of one party in the Singapore Parliament, it is all the more important to protect the essential features of Singapore's Constitution. Nonetheless, the rejection of the basic features doctrine may have paved the way for fundamental changes to be made to the