structure of the Constitution, stating that it includes the supremacy of the Constitution; the republican and democratic form of government; the secular character of the Constitution; the separation of powers between the legislature, the executive and the judiciary; and the federal character of the Constitution. He said that these basic features are founded on the "dignity and freedom of the individual", which is of "supreme importance". On the other hand, Justice Ajit Nath Ray dissented and gave reasons for rejecting the basic features doctrine. He stated that since the Constitution is the source of all legal validity and is itself always valid, a constitutional amendment, being part of the Constitution itself, will also always be valid. The power to amend the Constitution is wide and unlimited, and there is neither a distinction nor any possibility of a difference between essential and non-essential features of the Constitution that may impede amendment. In fact, if Parliament's power to amend is extinguished because of essential features that are not expressly defined in the Constitution, the courts would be creating a new constitution. Justice Ray presented other problems of the basic features doctrine, criticizing it as being uncertain in scope. Without an evident definition of what the basic features are, the task of trying to amend the Constitution becomes unpredictable. In his view, all the provisions of the Constitution are essential but this does not prohibit them from being amendable. Position in Singapore In the High Court case of Teo Soh Lung v. Minister for Home Affairs (1989), the applicant's counsel argued that the Singapore courts should recognize the basic features doctrine and thereby limit the power of Parliament to amend the Constitution. The doctrine was rejected by Justice Frederick Arthur Chua. He noted that Article 5 of the Constitution does not place any limitations on Parliament's power to amend the Constitution, and concluded that if the framers of the Constitution had intended for such limitations to apply they would have expressly provided for them. Justice Chua also referred to the Malaysian case Phang Chin Hock, in which the Federal Court had rejected the basic features doctrine, stating that "if our Constitution makers had intended that their successors should not in any way alter their handiwork, it would have been perfectly easy for them to so provide; but nowhere in the Constitution does it appear that that was their intention". Moreover, if proposed constitutional