the Government to cause Teo's pending court proceedings (a tort claim, a judicial review application and the present habeas corpus application) to fail. Therefore, they amounted to judicial rather legislative action. Further, relying on the Indian Supreme Court cases Kesavananda Bharati v. State of Kerala (1973), Minerva Mills Ltd. v. Union of India (1980) and P. Sambamurthy v. State of Andhra Pradesh (1986), Parliament's powers to amend the Constitution were limited by implied limitations derived from the basic structure of the Constitution itself. Since the Constitution was founded on the basis of separation of powers, Parliament was not empowered to amend the Constitution in a manner which acted retrospectively and allowed it to usurp judicial power, which amounted to judicial action. Teo's counsel also submitted that Article 149(1) imposed the overriding requirement that legislation enacted pursuant to the new Article 149(3) had to be "designed to stop or prevent" subversive action of the kind specified in Articles 149(1)(a) to (e). The purported ISA amendments were void because they were not intended to stop or prevent subversive action. Rather, they were enacted to prevent "acts done and decisions made in bad faith, for improper purposes, irrelevant to the stopping or prevention of subversive action" from being judicially reviewed by a court, and to retrospectively deprive the applicant of the benefit of the judgment in her favour in Chng Suan Tze. Chua J. rejected the application of the basic features doctrine in Singapore. He reasoned that a constitutional amendment, being part of the Constitution itself, can never be invalid if the procedure for amendment is complied with. If the framers of the Constitution had intended limitations on the power of amendment, they would have expressly provided for such limitations. Furthermore, if the courts were allowed to impose limitations on the legislative power to amend, they would be usurping Parliament's legislative function, contrary to Article 58. In any case, Chua J. did not agree that Parliament had violated the basic structure of the Constitution. The subjective test reinserted into the ISA had served the national security interests of Singapore for a long time. The amendments merely reaffirmed the law which the courts had followed since Lee Mau Seng, and ensured that the legislative intent behind the ISA was not disregarded. Moreover, nothing in the amendments was unrelated to national security. A reaffirmation of the original principles could not be said to be objectionable