The First Amendment Act, 1951, added Articles 31A and 31B and the Ninth Schedule to the Constitution. These provisions were enacted primarily to validate state laws relating to agrarian reform and abolition of zamindari, which had been challenged in courts on the grounds that they violated fundamental rights like the right to property (Article 31) and equality (Article 14). The Ninth Schedule protected laws included within it from judicial review on the ground that they violated Fundamental Rights.