Minerva Mills v. Union of India (1980)

Constitutional Law I · DPSP & the FR–DPSP Relationship

Facts.

The 42nd Amendment had given Directive Principles sweeping primacy and tried to place constitutional amendments beyond judicial review. Minerva Mills, a nationalised textile undertaking, challenged these changes.

Issue.

Can Parliament give the Directive Principles such primacy that they override the Fundamental Rights, and can it exclude amendments from judicial review?

Held.

The Court struck down the offending clauses. It held that the harmony and balance between the Fundamental Rights and the Directive Principles is part of the basic structure; the two are complementary and supplementary, and neither may be sacrificed for the other. Limited amending power and judicial review are themselves basic features.

Why it matters.

It settles the modern relationship between Parts III and IV — rights and directives as the “two wheels of the same chariot” — and is the leading authority for the harmonious approach.

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