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97th Amendment (2011): (a) Added Article 43B (DPSP) for voluntary formation, autonomous functioning, democratic control of co-operative societies, (b) Added Part IXB for constitutional framework for co-operatives. Supreme Court in Union of India v. Rajendra N. Shah (2021) struck down Part IXB as it related to State co-operatives (required State ratification under Article 368), upheld only for UTs and multi-State co-operatives. Illustrates federal amendment procedure constraints.