The correct answer is option 1 - the 38th Amendment. The 38th Amendment to the Constitution of India made a Proclamation of Emergency immune from judicial review.

A Proclamation of Emergency is a declaration made by the President of India in times of crisis or emergency, which suspends certain fundamental rights and grants the central government with additional powers.

The 38th Amendment was passed in 1975 during the period of the Indian Emergency, which was declared by then Prime Minister Indira Gandhi. This amendment inserted Article 359A into the Constitution, which stated that during a Proclamation of Emergency, the President`s decision to suspend certain fundamental rights could not be challenged in any court of law.

It is important to note that the 38th Amendment was highly controversial and seen as a curtailment of individual freedoms and an erosion of the separation of powers between the executive and the judiciary. The 38th Amendment was repealed by the 44th Amendment in 1978, which restored the power of judicial review over a Proclamation of Emergency.