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Zorluk: ZorFundamental Rights, Directive Principles, and Fundamental Duties

The constitutional relationship between Fundamental Rights (Part III) and Directive Principles of State Policy (Part IV) has evolved through key judicial pronouncements. Which of the following statements accurately reflects the established constitutional position regarding their harmony and precedence?

  1. A
    Directive Principles under Part IV automatically supersede Fundamental Rights in all circumstances, and laws implementing them are completely immune from judicial review.
  2. The Indian Constitution is founded on the bedrock of a harmonious balance between Part III and Part IV, and giving absolute primacy to one over the other distorts the basic structure.Cevap
  3. C
    High Courts are explicitly barred under Article 226 from issuing writs against state actions taken in furtherance of any Directive Principle.
  4. D
    The writ jurisdiction of High Courts under Article 226 is narrower than that of the Supreme Court under Article 32, as High Courts can only enforce Fundamental Rights.

Cevap

The correct position is that the Indian Constitution is founded on the bedrock of a harmonious balance between Part III (Fundamental Rights) and Part IV (Directive Principles of State Policy), and giving absolute primacy to one over the other distorts the basic structure of the Constitution.
The statement emphasizing a harmonious balance between Part III and Part IV as an essential basic structure feature accurately summarizes the ruling of the Supreme Court in Minerva Mills v. Union of India (1980). The Court observed that Part III and Part IV are like two wheels of a chariot, and absolute subordination of one to the other destroys the constitutional scheme.

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1
Analyze the constitutional interplay between Part III and Part IV
Recognize that while Fundamental Rights are justiciable legal guarantees and Directive Principles are fundamental in the governance of the country, neither part was intended to completely destroy the core of the other.
Judicial precedents, particularly Champakam Dorairajan (1951), Kerala Education Bill (1958), Kesavananda Bharati (1973), and Minerva Mills (1980), shaped this doctrine.
2
Evaluate the Minerva Mills v. Union of India (1980) ruling
The Supreme Court struck down Section 55 and Section 4 of the 42nd Constitutional Amendment Act, 1976, which had sought to give primacy to all DPSPs over Articles 14 and 19.
The Court held that the harmony and balance between Part III and Part IV is itself a basic feature of the Constitution.
3
Assess the scope of Writ Jurisdiction (Article 32 vs Article 226)
Article 32 can only be invoked for Fundamental Rights violation, whereas Article 226 permits High Courts to issue writs for Fundamental Rights and ordinary legal/statutory rights.
This confirms that High Courts are not barred from judicial review of DPSP-based enactments, and their scope is wider, not narrower.

Anahtar Kavram

Harmony and Balance between Fundamental Rights and Directive Principles of State Policy (Minerva Mills Doctrine)
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