Which of the following is NOT recognised by the Supreme Court as part of the 'basic structure' of the Constitution?

1. The Supreme Court has identified supremacy of the Constitution, republican and democratic form of Government, secularism, separation of powers, federalism, judicial review, the rule of law, etc., as basic features. 2. The right to property as a FUNDAMENTAL RIGHT was deleted by the 44th Amendment, 1978; it is now only a legal/constitutional right under Article 300A. 3. Hence option D is NOT a basic feature. 4. Note that the right to property's deletion was itself upheld. _Source: Constitution of India (Bare Act, updated to 105th Amendment Act 2021), Govt. of India Legislative Dept., Kesavananda Bharati; Minerva Mills; S. R. Bommai; 44th Amendment 1978_