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Minerva Mills balance principle: (a) Context: 42nd Amendment (1976) gave Directive Principles primacy over Fundamental Rights; Minerva Mills challenged this, (b) Supreme Court holding: (i) Balance between FRs (Part III) and DPSP (Part IV) is part of basic structure, (ii) Parliament cannot destroy this balance by giving absolute primacy to DPSP over FRs, (iii) Both are complementary: FRs provide means, DPSP provide ends for establishing egalitarian society, (c) Applications: (i) Subsequent amendments must maintain FR-DPSP balance, (ii) Judicial review ensures neither part destroyed, (iii) Harmonious construction: Courts interpret FRs, DPSP to give effect to both where possible, (d) Rationale: (i) FRs protect individual liberty against state excess, (ii) DPSP guide state policy towards social justice, (iii) Balance ensures neither individual rights nor collective welfare absolutely dominant, (e) Illustrates constitutional harmony: Basic structure doctrine preserves complementary relationship between rights, directive principles; neither can be destroyed without altering constitutional identity.