Cases Related To Conflict Between Fundamental Rights And Directive Principles

In the Champakam Dorairajan case (1951), the Supreme Court ruled that in case of any conflict between the Fundamental Rights and the Directive Principles, the former would prevail. It declared that the Directive Principles have to conform to and run as subsidiary to the Fundamental Rights. But it also held that the Fundamental Rights could be amended by the Parliament by enacting constitutional amendment acts.

In Golaknath case (1967), the Supreme Court ruled that the Parliament cannot take away or abridge any of the Fundamental Rights, which are ‘sacrosanct’ in nature. In other words, the Court held that the Fundamental Rights cannot be amended for the implementation of the Directive Principles.
In the Minerva Mills case (1980), the Supreme Court also held that the Indian Constitution is founded on the bedrock of the balance between the Fundamental Rights and the Directive Principles. They together constitute the core of commitment to social revolution. They are like two wheels of a chariot, one no less than the other. To give absolute primacy to one over the other is to disturb the harmony of the Constitution. This harmony and balance between the two is an essential feature of the basic structure of the Constitution.

In the Shankari Prasad case (1951), the constitutional validity of the First Amendment Act (1951), which curtailed the right to property, was challenged. The Supreme Court ruled that the power of the Parliament to amend the Constitution under Article 368 also includes the power to amend Fundamental Rights.