In Golak Nath v. State of Punjab, the Court had also held a procedurally perfect amendment to the Constitution invalid. In Golak Nath, however, the analysis turned on the particular language of the existing constitution. The majority in the earlier case relied on the facts that 1) Article 13 prohibited the making of “any law” abridging guaranteed individual rights, and 2) an amendment to the Constitution, a parliamentary act, was a “law” subject to the limitations of Article 13. When, predictably, Parliament amended Article 13 to exclude constitutional amendments from the category of laws so limited, the Supreme Court was obliged to address the issue in more general terms.47