Minerva Mills v. Union of India (1980)

Minerva Mills v. Union of India (1980) – Reinforcing the Balance Between Fundamental Rights and Directive Principles

Summary:
This landmark case reaffirmed that while Parliament can amend the Constitution, it cannot destroy its basic structure. It struck a balance between Fundamental Rights and Directive Principles of State Policy, ensuring neither dominates the other.

Background:

The Minerva Mills Ltd. case emerged during the post-Emergency period, when questions about the extent of Parliament’s amending power came under sharp scrutiny.

In 1975, the government took over Minerva Mills, a sick industrial firm, under the Sick Textile Undertakings (Nationalisation) Act. The owners challenged this move, leading to a broader constitutional debate. At the heart of the case were two major constitutional amendments passed during the Emergency:

• 42nd Amendment, which:

  • Gave supremacy to Directive Principles over Fundamental Rights.

  • Stated that amendments could not be questioned in court.

  • Expanded Parliament’s powers under Article 368.

Legal Issues Raised:

1. Can Parliament use its power to amend the Constitution in a way that eliminates or reduces judicial review?

2. Can Directive Principles override Fundamental Rights?

3. Do such sweeping changes violate the basic structure of the Constitution?

Supreme Court’s Key Observations:

• Parliament’s Power is Limited: The Court struck down clauses of the 42nd Amendment that gave Parliament unlimited power to amend the Constitution. It ruled that judicial review and Fundamental Rights are essential features of the Constitution and form part of its basic structure.

• Balanced Coexistence: The Court emphasized a harmony between Fundamental Rights and Directive Principles. They are both essential to India’s constitutional framework, and neither can be sacrificed for the other.

• Struck Down Sections of 42nd Amendment:

  • Section 4 and Section 55, which curtailed judicial review and made Directive Principles superior, were held unconstitutional.

Impact of the Judgment:

• Reaffirmed the Basic Structure Doctrine first laid down in the Kesavananda Bharati case.

• Prevented the misuse of constitutional amendments to suppress individual liberties.

• Cemented the judiciary’s role as a guardian of the Constitution.

• Preserved the delicate balance between welfare goals (Directive Principles) and personal freedoms (Fundamental Rights).