✏️ Sample Solved Problem (IRAC Method) — KSLU Constitutional Law Notes

✏️ Sample Solved Problem (IRAC Method)

Problem: A petitioner asks the court to enforce a directive-principle goal (say, a minimum standard of living / quality food) as a fundamental right under Article 32. The State pleads that Directive Principles are non-justiciable and so cannot be enforced.

I — Issue

Whether a goal contained in the (non-justiciable) Directive Principles can be enforced through Article 32, and how the State’s non-justiciability plea is met.

R — Rule

DPSP (Part IV) are not directly enforceable by courts (Art. 37).
But where a directive’s substance is also an integral facet of a fundamental right — especially Article 21 (life with dignity) — it becomes enforceable as part of that fundamental right: FRs and DPSP are complementary (Minerva Mills, 1980), and Art. 21 has been read to include livelihood, health, food and a life of dignity (Olga Tellis; PUCL v. Union of India — the right-to-food case).

A — Analysis

The decoy is the State’s technically-correct premise — qua Part IV, the directive is indeed non-justiciable, so it cannot be enforced as a directive. But the petitioner’s route is different: he asks the court to enforce the same content as a dimension of Article 21. A minimum standard of living and access to adequate food are facets of the right to live with dignity; framed that way, the claim is squarely within Art. 32’s enforcement of a fundamental right, and the non-justiciability of Part IV is no bar.

C — Conclusion

The petition is maintainable — not to enforce a Directive Principle as such, but to enforce its substance as an integral part of Article 21. The State’s non-justiciability plea fails because FRs and DPSP are read harmoniously (Minerva Mills; Olga Tellis; PUCL).

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