Shrimathy Annie Mascaraene (Travancore State) addressed to the Constituent Assembly on 18 November 1949, as follows:-

“The frame-work of our Constitution is modelled  after the American-Constitution, that is a Federal  Constitution, in which powers is distributed between Centre and  Local Governments. It is not new to us. It is based on the Swiss Constitution, which had been adopted by America, followed by Australia and Canada. And,today tried and adopted by the greatest democratic nation in the world. But the similarity ends there, our Constitution that has got shape of American Constitution differs from it. In this regard to the Executive Power of a President, unlike the American President, we have our own President advised by a Cabinet of Ministers with Cabinet rank  Parliamentary responsibilities and ministerial obligations, so much so our Constitution is the Composite Constitution, in the rigidity of a Written Constitution. But with a conventional adjustments of  British Constitution side by side,  its rigidity, we have also incorporated in a Separation of Powers, which is as rigid as in any other Constitution based on a democratic principles. OurJudiciary with its Original and Appellate Jurisdiction and with the right of  interpretation of the Constitution differs from that of American, where Judiciary has right of judicial review of Executive, Legislative activities.”

The extension of the area of Judicial Review may be covered by Suo Moto jurisdiction of  judiciary.