 Loh referred to Article 4(1), which specifies that the Constitution is "the supreme law of the Federation", and to the Basic Structure doctrine of Indian case law, to argue that the amendment had contravened the spirit and basic structure of the Constitution by invalidating the right of "habeas corpus".Federal Justice Raja Azlan Shah rejected the argument of the appellant, stating that although Article 4(1) declared that any unconstitutional law passed after independence would be void, this did not apply to the Constitution itself — the Constitution could not be internally inconsistent.In his judgement, he stated that law made under ordinary legislative power, and law in the form of Constitutional amendments, were two different things, and as such constitutional amendments were not subject to the inconsistency clause of Article 4(1)