Minerva Mills v. Union of India

Minerva Mills Ltd. v. Union of India (1980) is monumental judgment, playing a pivotal role in defining the scope of Parliament’s amending power and reaffirming Basic Structure Doctrine. Doctrine, which limits the extent to which Parliament can alter the Constitution of India, which was established in Kesavananda Bharati case, 1973. By this case Minerva Mills, Supreme Court strengthened this principle and ensured that the core values of the Constitution could not be undermined by amendments, particularly in relation to the balance between Directive Principles of State Policy (DPSPs)and theFundamental Rights.

Let us see the background of this case. Case originated from the government’s decision to nationalize Minerva Mills, a sick textile company based in Karnataka, under the Sick Textile Undertakings (Nationalization) Act, 1974. Mill’s ownerchallenged the constitutionality of this act, arguing that it violated their fundamental rights under Article 19(1)(g) of Constitution of India , which guarantees freedom to practice any profession or carry on any occupation, trade, or business.

42nd Amendment Act, 1976, at same time enacted during the Emergency (1975-1977), drastically altered the constitutional framework by expanding the powers of the Parliament and curtailing judicial review.

In this case mainly two specific provisions of 42^nd amendment were challenged, which are as follows:

1. Section 4 of the 42nd Amendment: This extended the protection of Article 31C, which originally applied to laws implementing certain DPSPs, to shield any law enacted to implement any DPSP from being challenged on the grounds of violating Articles 14 (Right to Equality) and 19 (Right to Freedom). This effectively subordinated Fundamental Rights to DPSPs.
   
2. Section 55 of the 42nd Amendment: This amended Article 368 to prevent any constitutional amendment from being challenged in court on any grounds, severely limiting the judiciary’s ability to review amendments made by Parliament.

Let us see the legal issues which are involved in this case; The central legal questions before Supreme Court were whether the amendments introduced by Sections 4 and 55 of 42^ndAmendment violated the Basic Structure of the Constitution and whether the Parliament had the power to amend the Constitution in a way that restricted judicial review and prioritized DPSPs over Fundamental Rights.

Now the impact and significance of this case, significantly strengthened the Kesavananda Bharati judgment and cemented the Basic Structure Doctrine as a permanent feature of Indian constitutional law. It also ensured that Parliament’s amending powerU/S 368 is not unlimited and any attempt to alter the fundamental framework of the Constitution would be subject to judicial scrutiny. Judgment also clarified relationship between Fundamental Rights and DPSPs, emphasizing that neither can override the other. DPSPs are guiding principles for state policy, but they cannot undermine the civil liberties guaranteed to individuals. The balanced approach allows for the pursuit of social and economic goals without sacrificing individual freedoms.

Let us conclude this case, which is a cornerstone of Indian constitutional jurisprudence, safeguarding the Constitution’s core values from excessive amendments. By reaffirming the importance of judicial review and maintaining the balance between Fundamental Rights and DPSPs, the Supreme Court ensured that the Constitution remains a living document, adaptable yet anchored in its basic principles. This case continues to guide Indian law, ensuring that democracy, justice, and individual liberties are protected for future generations.