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In Minerva Mills v. Union of India (1980), the Supreme Court held that the balance between Fundamental Rights (Part III) and Directive Principles (Part IV) is part of the basic structure of the Constitution, meaning Parliament cannot give absolute primacy to ______ over Fundamental Rights through constitutional amendment.
- Directive Principles
- Fundamental Duties
- Preamble
- Seventh Schedule
Answer: Directive Principles
Minerva Mills FR-DPSP balance: (a) Context: Challenge to 42nd Amendment provisions giving Directive Principles primacy over Fundamental Rights (Articles 14, 19), (b) Supreme Court holding: (i) Balance between Fundamental Rights (Part III) and Directive Principles (Part IV) is part of basic structure, (ii) Parliament cannot destroy this balance by giving absolute primacy to DPSP over FRs or vice versa, (iii) Both are complementary: FRs provide means (individual liberty, rights protection), DPSP provide ends (social justice, egalitarian society), (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.