This case concerns the constitutionality of Section 3(d) of the 2005 Amendment (“Amendment”) to India’s Patent Law, which was added to comply with Trade-Related Aspects of Intellectual Property Rights (TRIPS) and World Trade Organization’s (WTO) minimum standards for protecting intellectual property. Section 3(d) requires that inventions based on a known substance be patentable only if they show the “enhanced efficacy” of the known substance. Novartis, a large pharmaceutical company, submitted a patent application for its leukemia medication, Gleevec. Novartis’ application was denied on