The First Amendment (1951) added the Ninth Schedule to protect certain laws from judicial review. Which of the following best describes the intended constitutional problem it sought to solve?

The Ninth Schedule was introduced by the First Constitutional Amendment Act, 1951, as a direct response to early judicial decisions invalidating land reform laws. In cases such as State of Bihar v. Kameshwar Singh (1952), zamindari abolition statutes were struck down for violating Articles 14, 19, and 31 (right to property). Parliament viewed this as a serious obstacle to implementing the Directive Principles of State Policy, particularly Articles 38 and 39(b) and (c), which aim at reducing economic inequality and preventing concentration of wealth. The Ninth Schedule was therefore conceived as a protective constitutional device to immunize specific socio-economic legislation from fundamental rights challenges. At that stage, parliamentary supremacy in social reform was emphasized over individual property rights, reflecting the Constitution’s transformative character.