academic scrutiny is the nature of section 8B(2) as an ouster clause. An ouster clause is an objectively worded provision which is drafted to exclude the jurisdiction of the courts. In Teo Soh Lung, the Court of Appeal declined to address the constitutionality of section 8B and, in particular, how section 8B(2) should be interpreted. Michael Hor has described the judiciary's reluctance to address these points as "an elegant piece of judicial 'kung fu'" in which it chose to evade the problem. In a lecture to law students in 2010, Chief Justice Chan Sek Keong commented that, in general, "ouster clauses may be inconsistent with Article 93 of the Constitution, which vests the judicial power of Singapore in the Supreme Court", though he expressed no concluded opinion on the matter. However, it seems unlikely that Article 93 can be relied on to invalidate section 8B(2) since Parliament specifically enacted Article 149(3) to protect the 1989 amendments to the ISA from inconsistency with Article 93. Tham Chee Ho has opined that where a jurisdictional error of law is involved, judicial review will be available despite the presence of an ouster clause. However, an ouster clause still precludes judicial review of non-jurisdictional errors of law. If this distinction between jurisdictional and non-jurisdictional errors of law exists, section 8B(2) will preclude judicial review of non-jurisdictional errors of law but not jurisdictional errors. Notably, there is a difference between English and Singapore law as regards this issue. In R. v. Lord President of the Privy Council, ex parte Page (1992), Lord Browne-Wilkinson commented that the case of Anisminic Ltd. v. Foreign Compensation Commission (1968) had the effect of rendering the distinction between jurisdictional and non-jurisdictional errors of law obsolete. This has limited the effect of ouster clauses in the United Kingdom since all errors of law are considered as jurisdictional. However, the Singapore courts have not yet adopted this legal position, and there are cases indicating that the distinction between jurisdictional and non-jurisdictional errors of law still exists. Basic features doctrine The basic features doctrine developed in Kesavananda Bharati v. The State of Kerala (1973) and Minerva Mills Ltd. v. Union of India (1980) by the Supreme Court of India rests on the notion that there are certain elements of the nation's constitutional structure which cannot be amended by Parliament. In the High Court case of Teo Soh Lung v. Minister for Home Affairs