articulated in Part III. Section 55 prevented any constitutional amendment from being "called in question in any Court on any ground". It also declared that there would be no limitation whatever on the constituent power of Parliament to amend by way of definition, variation or repeal the provisions of the Constitution. On 31 July 1980, when Indira Gandhi was back in power, the Supreme Court declared sections 4 & 55 of the 42nd amendment as unconstitutional. It further endorsed and evolved the basic structure doctrine of the Constitution. As had been previously held through the basic structure doctrine in the Kesavananda case, the Court ruled that Parliament could not by amending the constitution convert limited power into an unlimited power (as it had purported to do by the 42nd amendment). In the judgement on section 55, Chief Justice Yeshwant Vishnu Chandrachud wrote, The ruling was widely welcomed in India, and Gandhi did not challenge the verdict. In the judgement on Section 4, Chandrachud wrote: This latter view of Article 31C was questioned, but not overturned, in Sanjeev Coke Manufacturing Co v Bharat Cooking Coal Ltd. (case citation: AIR 1983 SC 239). The concept of basic structure has since been developed by the Supreme Court in subsequent cases, such as Waman Rao v. Union of India (AIR 1981 SC 271), Bhim Singhji v. Union of India (AIR 1981 SC 234), S.P. Gupta v. President of India (AIR 1982 SC 149) (known as Transfer of Judges case), S.P. Sampath Kumar v. Union of India (AIR 1987 SC 386), P. Sambamurthy v. State of Andhra Pradesh (AIR 1987 SC 663), Kihota Hollohon v. Zachilhu and others (1992 1 SCC 309), L. Chandra Kumar v. Union of India and others (AIR 1997 SC 1125), P. V. Narsimha Rao v. State (CBI/SPE) (AIR 1998 SC 2120), I.R. Coelho v. State of Tamil Nadu and others (2007 2 SCC 1), and Raja Ram Pal v. The Hon'ble Speaker, Lok Sabha and others (JT 2007 (2) SC 1) (known as Cash for Query case). The Supreme Court's position on constitutional amendments laid out in its judgements is that Parliament can amend the Constitution but cannot destroy its "basic structure". Recognition Aside from India, the basic structure doctrine has been adopted in a number of jurisdictions, and rejected in some others. Bangladesh The basic structure doctrine was adopted by the Supreme Court of Bangladesh in 1989, by expressly