In which of the following cases the Supreme Court held that ‘the Indian…
2022
In which of the following cases the Supreme Court held that ‘the Indian Constitution is founded on the bedrock of the balance between the Fundamental Rights and the Directive Principles’?
- A.
A. K. Gopalan vs. State of Madras
- B.
Kesavananda Bharati vs. State of Kerala
- C.
Maneka Gandhi vs. Union of India
- D.
Minerva Mills vs. Union of India
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Show answer & explanation
Correct answer: D
Concept
Articles 14, 19 and 21 (Fundamental Rights, Part III) and the Directive Principles of State Policy (Part IV) are meant to be complementary, not antagonistic. The Supreme Court has repeatedly held that giving absolute primacy to one over the other destroys the harmony of the Constitution; preserving the equilibrium between the two is itself part of the basic structure.
Application
This exact formulation — that the Constitution is founded on the bedrock of the balance between the Fundamental Rights and the Directive Principles — was laid down in Minerva Mills Ltd. v. Union of India (1980). While striking down clauses of the 42nd Constitutional Amendment, the Court reasoned as follows:
Section 4 of the 42nd Amendment had extended Article 31C to give every Directive Principle precedence over the rights in Articles 14 and 19.
The Court held that to destroy the guarantees of Part III in order to achieve the goals of Part IV is to subvert the Constitution, since the two together form its core.
It concluded that harmony and balance between Fundamental Rights and Directive Principles is an essential feature of the basic structure, and so the offending clause was unconstitutional.
Cross-check / Contrast
The other named cases dealt with different constitutional questions, so none of them is the source of the ‘balance / bedrock’ formulation:
A. K. Gopalan v. State of Madras (1950): adopted a narrow, isolated reading of Articles 19, 21 and 22 (the rights stand in separate watertight compartments) — it predates and contradicts the harmony idea.
Kesavananda Bharati v. State of Kerala (1973): introduced the basic structure doctrine itself, but its central holding is the limit on Parliament’s amending power, not the Part III–Part IV equilibrium.
Maneka Gandhi v. Union of India (1978): expanded ‘procedure established by law’ under Article 21 to mean fair, just and reasonable procedure, interlinking Articles 14, 19 and 21 — a different doctrine.
Hence Minerva Mills v. Union of India is the correct answer.