The relationship between Fundamental Rights (Part III) and Directive Principles (Part IV) was marked by massive conflict, which was ultimately resolved through creative judicial balancing.
1. The History of Conflict
- Champakam Dorairajan v. State of Madras (1951): The Supreme Court held that DPSP cannot override Fundamental Rights. If a conflict occurs, Part III prevails; Part IV must run as a "subsidiary" to Part III.
- Doctrine of Harmonious Construction (Re Kerala Education Bill, 1958): The Court modified its view, holding that courts must try to interpret the Constitution in a way that gives effect to both parts, avoiding simple invalidation.
2. The Minerva Mills Settlement:Bedrock Balance
Parliament amended the Constitution to declare that all DPSP laws are immune from challenge under Articles 14 and 19. In the landmark case of Minerva Mills v. Union of India (1980), the Supreme Court struck down this amendment, establishing the ultimate standard of balance:
"The Indian Constitution is founded on the bedrock of the balance between Parts III and IV. To give absolute primacy to one over the other is to disturb the harmony of the Constitution, which is an essential feature of its basic structure." Part III and Part IV represent two wheels of a single chariot.
3. Fundamental Duties (Article 51-A)
Added by the 42nd Amendment, 1976 on the recommendation of the Swaran Singh Committee, Part IV-A contains 11 Fundamental Duties of citizens:
- Abide by the Constitution, respect the National Flag and National Anthem.
- Protect the sovereignty, unity, and integrity of India.
- Promote harmony and common brotherhood.
- The 11th Duty: Added by the 86th Amendment, 2002, placing a duty on parents/guardians to provide education to their child between the ages of 6 and 14 years.