Background: The Minerva Mills case arose from the constitutional challenge against certain amendments made to the Constitution of India, specifically the 42nd Amendment enacted in 1976. These amendments included provisions that limited judicial review of laws passed by Parliament and emphasized the primacy of Directive Principles of State Policy over Fundamental Rights. Minerva Mills, a textile manufacturer, contested these amendments, arguing they undermined the basic structure of the Constitution.
Key Issue: The primary issue was whether the amendments infringed upon the basic structure doctrine established in earlier Supreme Court rulings, particularly the balance between Fundamental Rights and Directive Principles of State Policy.
Arguments:
Minerva Mills’ Argument: The petitioners contended that the amendments diluted the protection of Fundamental Rights guaranteed by the Constitution. They argued that limiting judicial review was detrimental to the principle of rule of law and the fundamental rights of citizens.
Union of India’s Argument: The government defended the amendments, asserting that they aimed to strengthen the Directive Principles and promote social welfare. It argued that Parliament had the authority to amend the Constitution, including provisions related to Fundamental Rights.
Judgment: The Supreme Court of India ruled in favor of Minerva Mills, declaring that the amendments violated the basic structure of the Constitution. The court held that the supremacy of Fundamental Rights cannot be compromised by any constitutional amendment. It reaffirmed the significance of judicial review as a mechanism to protect citizens’ rights and emphasized that the balance between Fundamental Rights and Directive Principles must be maintained.
Significance: This landmark judgment reinforced the basic structure doctrine, asserting that certain fundamental features of the Constitution are inviolable and cannot be amended by Parliament. It established the principle that the protection of Fundamental Rights is essential to maintaining democracy and the rule of law in India, and it underscored the judiciary’s role in safeguarding these rights against legislative overreach. The case remains a cornerstone in the discourse on constitutional law in India.
