Introduction:

The case of Minerva Mills Ltd. & Ors. v. Union of India & Ors. (AIR 1980 SC 1789) stands as a cornerstone in the evolution of India's constitutional jurisprudence, particularly concerning the doctrine of the basic structure of the Constitution. This landmark judgment, delivered by a Constitution Bench of the Supreme Court, challenged the constitutional validity of the 42nd Amendment Act, 1976, enacted during the Emergency. The amendment had introduced significant changes, including Article 31C, which sought to give primacy to the Directive Principles of State Policy over the Fundamental Rights guaranteed under Articles 14 and 19. The case became a crucial battleground for safeguarding the fundamental principles upon which the Indian Constitution is founded.

Essential Background and Issues:

Minerva Mills a textile undertaking, was nationalized by the government. The constitutional validity of this nationalization was challenged, and during the proceedings, the validity of certain provisions of the 42nd Amendment Act also came under scrutiny. The key issues before the Supreme Court were:

• 1. Whether Section 4 of the 42nd Amendment Act, which amended Article 31C of the Constitution, was constitutionally valid?
• The amended Article 31C stated that no law giving effect to the policy of the State towards securing all or any of the principles laid down in Part IV (Directive Principles) shall be deemed to be void on the ground that it is inconsistent with or takes away or abridges any of the rights conferred by Article 14 (equality before law) or Article 19 (protection of certain freedoms). This effectively sought to elevate Directive Principles over certain Fundamental Rights.
• 2. Whether Section 55 of the 42nd Amendment Act, which amended Article 368(4) and (5) and placed limitations on the power of judicial review over constitutional amendments, was constitutionally valid?
• These amendments aimed to curtail the power of the judiciary to review constitutional amendments, asserting the absolute power of Parliament to amend any provision of the Constitution.

Analysis:

The Supreme Court, in a majority judgment authored by Chief Justice Y.V. Chandrachud, struck down both the challenged amendments, reaffirming and strengthening the doctrine of the basic structure of the Constitution, which was first propounded in the Kesavananda Bharati case (1973).

Regarding the amended Article 31C, the Court held that it destroyed the basic structure of the Constitution by giving an unqualified primacy to Directive Principles over Fundamental Rights under Articles 14 and 19. The Court emphasized that the Constitution is founded on a harmonious balance between Fundamental Rights and Directive Principles. While Directive Principles aim at social and economic justice, they cannot be achieved at the cost of annihilating fundamental freedoms. The Court stated that these rights are two wheels of the chariot of social justice, and neither can be sacrificed at the altar of the other. To give absolute primacy to one over the other would upset the delicate balance meticulously crafted by the framers of the Constitution.

Concerning the amendments to Article 368, the Court held that they were also violative of the basic structure of the Constitution. The amendments sought to remove all limitations on the amending power of Parliament, including the power of judicial review. The Court asserted that the power of judicial review is an integral part of the basic structure of the Constitution. Without it, the fundamental rights would be rendered meaningless, and there would be no effective check on the legislative power of Parliament. The Court reiterated that while Parliament has the power to amend the Constitution, this power is not unlimited and cannot be used to alter or destroy the fundamental features of the Constitution.

Judgment:

The Supreme Court declared Section 4 and Section 55 of the 42nd Amendment Act, 1976, as unconstitutional and void on the ground that they damaged the basic structure of the Constitution. The Court upheld the principle that the amending power of Parliament under Article 368 is subject to inherent limitations, and Parliament cannot exercise this power to alter the basic framework of the Constitution.

Conclusion:

The Minerva Mills case is a landmark judgment that significantly reinforced the doctrine of the basic structure of the Constitution. It served as a crucial check on the legislative power of Parliament, particularly in the aftermath of the Emergency, and reaffirmed the judiciary's role as the guardian of the Constitution. The judgment underscored the importance of maintaining a balance between Fundamental Rights and Directive Principles and firmly established judicial review as an essential component of the basic structure, ensuring that the Constitution remains the supreme law of the land and that fundamental rights are not arbitrarily abrogated in the pursuit of socio-economic goals. The case continues to be cited as a leading authority on the limitations of the amending power of Parliament and the enduring significance of the basic structure doctrine in Indian constitutional law.