The framers of the Indian Constitution did not work in isolation. They studied every major constitution then in force and borrowed features that suited Indian conditions. The result is the longest written constitution in the world — 395 articles, 8 schedules, and 22 parts at the time of adoption — drawing on the Government of India Act, 1935, the British parliamentary system, the US Bill of Rights, the Irish Directive Principles, the Canadian federal scheme, the Australian Concurrent List, and the Soviet Fundamental Duties. Knowing which feature came from where is one of the most reliably tested points in constitution basics.
The biggest single source — the Government of India Act, 1935
The single biggest source of the Indian Constitution is the Government of India Act, 1935. By some estimates, two-thirds of the constitutional text was drawn from the 1935 Act, often verbatim. This included the federal scheme, the office of Governor, the role of Public Service Commissions, the structure of the federal judiciary, the emergency provisions, the administrative provisions, and the entire framework of the legislative lists.
The 1935 Act was a substantial document — 321 sections and 10 schedules — designed by the British government to provide a federal structure for India while preserving Crown supremacy. It was never fully implemented. The federal portion of the 1935 Act, which would have created an All-India Federation including the princely states, never came into force because the princes did not accede in sufficient numbers. But the provincial portion did come into force in 1937, and from 1937 onwards British India was governed under the 1935 Act with elected provincial governments.
By 1947, the 1935 Act had been the working constitution of British India for a decade. The Constituent Assembly chose to build on this foundation rather than start from scratch. The federal scheme — Centre with strong powers, State Legislatures with limited but real authority, three legislative lists — was retained almost exactly. The institutional architecture — Federal Court, Public Service Commission, office of Governor — was retained with modifications. The emergency provisions of Articles 352, 356, and 360 trace directly to similar provisions in the 1935 Act.
The continuity from the 1935 Act was not just textual but institutional. The Indian Civil Service was reorganised but its administrative structure was preserved. The provincial governments that had been functioning since 1937 continued to function under the new constitution with minimal disruption. The provincial High Courts established under the 1935 Act became the State High Courts under the new Constitution. The Reserve Bank of India and other institutions established under colonial legislation continued their work. The Constituent Assembly's choice was to evolve from the 1935 framework rather than break with it.
Britain — parliamentary system, rule of law, single citizenship
From Britain came the basic feature of the parliamentary form of government. The President as constitutional head of state, the Prime Minister and Council of Ministers as the real executive, ministerial responsibility to the legislature, the convention that the executive emerges from and is accountable to the legislature — all of these come from the Westminster system. The Indian Constitution adapted Westminster rather than copying it, but the conceptual structure is British.
From Britain also came the doctrine of the rule of law, articulated by A.V. Dicey and absorbed into Indian constitutional thinking through both the colonial inheritance and the Constituent Assembly's deliberations. The principle that the State and the citizen are equally subject to the same law, that there is no arbitrary government action, and that disputes between the citizen and the State are decided by ordinary courts — all of these have British roots.
The concept of single citizenship is also British in origin. Unlike the US (which has both federal and state citizenship) and Australia, India has a single citizenship — a citizen of India, not of any particular State. This was a deliberate choice to promote national unity, and it draws on the British model where citizens are subjects of the Crown without a separate sub-national citizenship.
The provisions on parliamentary privileges in Articles 105 and 194 are also borrowed from Britain. Article 105(3) originally provided that the privileges of each House of Parliament shall be those enjoyed by the House of Commons of the UK Parliament on 26 January 1950. This made British parliamentary practice directly relevant to Indian parliamentary law, and the Supreme Court has frequently surveyed British developments to interpret these provisions.
USA — Fundamental Rights, judicial review, written Constitution
From the United States came the idea of a written Constitution as a higher law that constrains the legislature. Britain has an unwritten constitution; America established the model of a single document, judicially enforceable, that operates as the supreme law. The Indian Constitution follows the American model — it is a single document; it is the supreme law; legislative and executive acts are subject to it.
The chapter on Fundamental Rights in Part III is modelled on the US Bill of Rights, though significantly adapted. The American Bill of Rights operates by negative formulation — "Congress shall make no law..." The Indian Fundamental Rights are similarly framed in negative terms but include explicit limitations within the constitutional text itself. Article 19's freedoms are subject to "reasonable restrictions" listed in clauses (2) to (6); Article 21's right to life is subject to "procedure established by law".
The doctrine of judicial review is American in origin — established by Chief Justice Marshall in Marbury v. Madison (1803). The Indian Constitution does not use the phrase "judicial review", but Articles 13, 32, 226, and 227 collectively give the Supreme Court and High Courts the power to test legislative and executive actions against constitutional standards. The Supreme Court has held judicial review to be part of the basic structure of the Constitution.
The office and procedure of impeachment of the President are also drawn from the US, though adapted. The Vice-President as ex-officio Chairman of the upper house mirrors the US Vice-President's role as President of the Senate. The structure of the Supreme Court as the apex constitutional court is American in inspiration.
Ireland — Directive Principles, presidential election, nominated members
From the Constitution of Ireland (1937) came the most distinctive Indian innovation: the Directive Principles of State Policy. The Irish Constitution had introduced "Directive Principles of Social Policy" — non-justiciable directions to the legislature setting out economic and social goals. The Indian Constituent Assembly adopted this concept and expanded it. Part IV of the Indian Constitution, with Articles 36 to 51, is closely modelled on the Irish chapter.
The method of election of the President — by an electoral college of elected members of Parliament and elected members of State Legislative Assemblies, using the system of proportional representation by single transferable vote — is also drawn from Ireland. Article 55's electoral formula has direct Irish ancestry.
The provision for the President to nominate members of the Rajya Sabha (those distinguished in literature, science, art, and social service) under Article 80(3) is similar to the Irish provision for nominated Senators. The Indian provision for 12 nominated members is smaller in proportion, but the idea is Irish.
Canada and Australia — federal scheme, Concurrent List
From the Canadian Constitution Act of 1867 came the federal model with a strong Centre. Canada was the first federation to adopt the principle that residuary powers (those not specifically allocated to the provinces) lie with the federal government — opposite to the American model where residuary powers lie with the states. India followed Canada on this point. Article 248 and entry 97 of the Union List place residuary powers with the Centre.
The principle of strong Centre with limited State autonomy is also Canadian. The Canadian Centre can override provincial legislation in certain circumstances; the Indian Centre has similar powers under Articles 252, 253, and 256. The Canadian appointed Governor of provinces is mirrored by the Indian appointed Governor of States.
From the Australian Constitution of 1901 came the Concurrent List — a list of subjects on which both the Centre and the States can legislate, with Central legislation prevailing in case of conflict. The Australian Constitution's section 51 provides for concurrent powers; the Indian Constitution's Concurrent List in the Seventh Schedule is similar in concept though longer in content.
The principle of freedom of trade, commerce and intercourse across State boundaries (Article 301) is drawn from section 92 of the Australian Constitution. The provision for joint sittings of the two Houses to resolve deadlocks (Article 108) is also Australian in origin.
Other sources — USSR, France, South Africa, Japan, Weimar
Several other constitutions contributed specific features. From the Constitution of the USSR came the Fundamental Duties — Article 51A, added by the 42nd Amendment in 1976. The Soviet Constitution had a chapter on duties of citizens; India adapted this concept and inserted Part IVA. The ideal of "social, economic, and political justice" in the Preamble is also influenced by Soviet constitutional thinking.
From France came the trio of "liberty, equality, fraternity" in the Preamble — borrowed in spirit from the French Revolution and adapted into the Indian constitutional vocabulary. The concept of the Republic — a State without monarchy, with the head of state elected — is also French in inspiration, though the British Parliamentary system was the more proximate model.
From the South African Constitution came the amendment procedure for certain provisions of the Constitution — combining the requirement of a special majority in Parliament with ratification by half the State Legislatures. Article 368's procedure for amendments affecting the federal structure is South African in inspiration.
From Japan came the phrase "procedure established by law" in Article 21. The Japanese Constitution of 1947 used this phrase; the Indian Constituent Assembly adopted it deliberately to distinguish Indian constitutional practice from the American "due process of law", which the Assembly thought gave courts too much discretion to second-guess legislation. The Supreme Court later in Maneka Gandhi (1978) read substantive content into the Indian phrase, partially closing the gap.
From the Weimar Constitution of Germany came the suspension of Fundamental Rights during emergency — a feature later partially incorporated into Article 359. The lessons of the Weimar experience also shaped Indian thinking on the dangers of unrestricted emergency powers.
One last point worth holding. The Indian Constitution is sometimes criticised as derivative — a patchwork stitched together from foreign sources. The framers themselves rejected this characterisation. Ambedkar's response in the Constituent Assembly was direct: borrowing what worked from other constitutions did not make the Indian document derivative. Every constitution borrows. What matters is the synthesis — the way the borrowed elements are combined into a coherent whole that suits Indian conditions. The result, by Ambedkar's own description, was a Constitution "adopted, enacted and given to ourselves" by the people of India, regardless of the origin of its individual features.
What students must hold
The Prelims often tests source-feature pairings. Hold these reliably:
From GoI Act 1935 — federal scheme, office of Governor, public service commissions, federal judiciary, emergency provisions, administrative details. The biggest single source.
From Britain — parliamentary government, rule of law, single citizenship, parliamentary privileges, the bicameral legislature.
From USA — written Constitution, Fundamental Rights (Bill of Rights), judicial review, impeachment, Vice-President as ex-officio chair of Rajya Sabha.
From Ireland — Directive Principles (Part IV), election of President by electoral college using STV, nomination of members to upper house.
From Canada — federation with strong Centre, residuary powers with the Centre, Governor of States appointed by the Centre.
From Australia — Concurrent List, freedom of trade and commerce across States, joint sitting of the two Houses.
From USSR — Fundamental Duties (Part IVA), social/economic/political justice in Preamble.
From France — liberty, equality, fraternity in Preamble, the concept of Republic.
From Japan — "procedure established by law" in Article 21.
From South Africa — procedure for amendment of the Constitution involving State ratification.
For the broader story of how these borrowings produced the Preamble and the basic constitutional architecture, see the linked articles.