The case involved a challenge to the constitutional validity of Articles 31B and 31C of the Indian Constitution, and the 42nd Amendment (Article 368(4), 368(5). Article 31B provided immunity to certain laws from judicial review, while Article 31C aimed to ensure the implementation of specific Directive Principles of State Policy (DPSPs). Articles 368 on the other hand enabled Parliament with unlimited powers to amend the Constitution. Minerva Mills Ltd. and other petitioners contended that these provisions infringed upon fundamental rights and violated the basic structure of the Constitution..
IssuesThe Supreme Court examined the relationship between fundamental rights and Directive Principles of State Policy. The Court noted that while the state has the power to make laws to implement DPSPs, such laws must not infringe upon the basic structure of the Constitution. The Court reaffirmed the significance of judicial review as a fundamental tenet, emphasizing that any alteration undermining this principle is unconstitutional..
DecisionThe Court upheld the validity of Articles 31B and 31C, affirming that Article 31C is valid only concerning Articles 39(b) and 39(c) of the Constitution and does not extend to all DPSPs. The Court struck down the amendments made under Article 368 (42nd Amendment) as unconstitutional for violating the principle of judicial review, which forms part of the Constitution's basic structure. Thus, while the challenged articles were retained, their application was clarified and limited in scope. This landmark judgment reaffirmed the balance between fundamental rights and the Directive Principles.