The issue which was under the consideration in front of the Supreme Court in the case Kihoto Hollohan v.Zachillhu was the Constitutional validity of the Tenth Schedule introduced by the Constitution (Fifty Second Amendment) Act, 1985. The Constitution (Fifty-second Amendment) Act changed four articles of the Constitution, viz. 101(3) (a), 102(2), 190(3)(a) and 191(2) and added tenth schedule thereto.
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