<s>[INST] What happened to Clause (4) of Article 213 in terms of its inclusion and subsequent removal from the Constitution? [/INST] Clause (4) of Article 213 was inserted by the Constitution (Thirty-eighth Amendment) Act, 1975 with retrospective effect. However, it was later omitted by the Constitution (Forty-fourth Amendment) Act, 1978 which came into force on 20-6-1979. </s>