The Doctrine of an eclipse is known to be applied in cases in which an act or law tends to

violate the fundamental rights guaranteed under the Indian Constitution.

The fundamental rights will overshadow the other act or law and make it unenforceable.
The unenforceability of the overshadowed act or law is not void ab initio or null, meaning
they can be reinforced again if the earlier restrictions posed by the Fundamental rights are
taken away.
The theory of this Doctrine is explained in Article 13 of the Indian Constitution that
envisages four principles for applying Fundamental Rights. Art 13 deals with laws
inconsistent with or in derogation of the Fundamental Rights
Some significant features and characteristics of the Doctrine are as follows:
 Applicability to Pre Constitutional Laws- the law, must be valid for the Doctrine to
apply on Applicability to Post Constitutional Laws- They cannot apply to post-
constitutional laws. This is because they are invalid at their inception and thus,
cannot be validated by any subsequent amendment.
 Conflict with the fundamental rights- The past law is supposed to be violating a
fundamental right. Only then can it be overshadowed and be termed as inoperative.
 Inoperative- The Doctrine is based on the principle that the law violates
fundamental rights. It is not nullity or void ab initio but only becomes defective and
unenforceable. 
 Fundamental Rights and Amendment- If there is an amendment to the relevant FR
in the future, it will automatically make the impugned law operative.
 
Landmark judgments
 
In Deep Chand v. State of Uttar Pradesh, the Supreme Court meticulously observed that
the Doctrine applies only to pre-constitutional laws as given under Article 13(1). It does not
apply to any post-constitutional law under Article 13(2) because the post-constitutional
laws in violation of fundamental rights are void ab initio and stillborn.
The judgment of Bhikaji and Deep Chand was upheld in the case of State of Gujarat v.
Ambica Mills, Mahendra Lal Jain v. State of Uttar Pradesh, P. L. Mehra v. D. R. Khanna,
and Sagir Ahmed v. State of Uttar Pradesh.
The Doctrine of Eclipse and article 368, the debate on the validity and absoluteness of
Article 368 started with the case of Golaknath. The judgment of I. C. Golaknath was
overturned in the legendary case of Keshavananda Bharti v. Union of India.
The Doctrine is seen to extend to the provisions under the Indian Penal Code, as observed
in the cases of Rathinam and Gian Kaur.
In India, the Doctrine of Eclipse is one such theory that is said to safeguard the pre-
constitutional laws from being completely wiped out. It gives us a very refined, nuanced
aspect of the rule of law. Theorists believe that if there were no Doctrine of Eclipse, then
constitutionalism would have been compromised. This theory has helped break the thin
line between pre-constitutional laws and post-constitutional laws. It is a tool to harmonize
the central dictates of the Indian Constitution.