There are few instances of courts following the precedent of Kesavananda Bharati in inferring limitations on the amendment power from the inherent characteristics of authorized constitutional change.48 On the contrary, there are at least some courts that have expressly rejected it.49 But the core notion on which the judgment *725 was based--that there is something wrong with the idea that an “amendment” might alter the essential character of a constitution while simultaneously invoking its authority--has been embraced by many modern constitution-makers. It finds expression in numerous provisions withdrawing certain subjects from the power of amendment.50 The distinction was presaged by Schmitt in his dictum that amendments may