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In Minerva Mills v. Union of India (1980), the Supreme Court emphasized that Fundamental Rights and Directive Principles are complementary and harmonious, with FRs providing means and DPSP providing ends for establishing an egalitarian society, and neither can be given absolute primacy over the other.
- True
- False
Answer: True
Minerva Mills (1980) harmony between FRs and DPSP: (a) Context: Challenge to 42nd Amendment provisions giving Directive Principles primacy over Fundamental Rights, (b) Supreme Court holding: (i) Balance between Fundamental Rights (Part III) and Directive Principles (Part IV) is part of basic structure, (ii) FRs and DPSP are complementary and harmonious: FRs provide means (individual liberty, rights protection), DPSP provide ends (social justice, egalitarian society), (iii) Neither can be given absolute primacy: Parliament cannot destroy this balance by giving absolute primacy to DPSP over FRs or vice versa, (c) Applications: (i) Subsequent amendments: Must maintain FR-DPSP balance; courts can strike down amendments violating this balance, (ii) Harmonious construction: Courts interpret FRs, DPSP to give effect to both where possible, not as conflicting, (iii) Policy formulation: State policies should advance DPSP goals while respecting FR protections, (d) Rationale: (i) FRs protect individual liberty against state excess, (ii) DPSP guide state policy towards social justice, collective welfare, (iii) Balance ensures neither individual rights nor collective welfare absolutely dominant; both essential to constitutional vision, (e) Illustrates constitutional harmony: Basic structure doctrine preserves complementary relationship between rights, directive principles; neither can be destroyed without altering constitutional identity, ensuring balanced approach to individual liberty and social justice.