Karl: reads AK Gopalan-it read article 19 separately from 21- RC Cooper overruled and said FRs can't be read in silos. when mylords are resting fundamental rights, they can't be interpreted in a manner where exercise of one would trample the other.

and lastly, the doctrine of non-retrogression. doctrine of progressive realisation of rights and non-retrogression. This Hon’ble Court has held that the State must move forward and refrain from adopting an approach / interpretation which will result in regression of rights.