Introduction
The Directive Principles of State Policy (DPSP) in Part IV (Articles 36-51) of the Indian Constitution serve as guidelines for the government to create a welfare state. Although not enforceable by the courts, DPSPs have played a crucial role in shaping legislations, policies, and judicial decisions in India. Over the years, several landmark cases have interpreted the relationship between Fundamental Rights and DPSPs, ensuring socio-economic justice and governance improvement.
This article explores major case studies related to DPSP, highlighting their impact on Indian laws and policies.
List of Important Case Studies Related to DPSP
- State of Madras v. Champakam Dorairajan (1951)
- Keshavananda Bharati v. State of Kerala (1973)
- Minerva Mills v. Union of India (1980)
- Unnikrishnan v. State of Andhra Pradesh (1993)
- Olga Tellis v. Bombay Municipal Corporation (1985)
- M.C. Mehta v. Union of India (1986)
- Dalmia Cement v. Union of India (1996)
- Ashok Kumar Thakur v. Union of India (2008)
- People’s Union for Civil Liberties (PUCL) v. Union of India (2001)
- Indira Sawhney v. Union of India (1992)
1. State of Madras v. Champakam Dorairajan (1951)
Background
- The Madras Government reserved seats in educational institutions for different communities based on caste.
- A Brahmin woman, Champakam Dorairajan, was denied admission due to these reservations.
- She challenged the reservation policy, arguing that it violated Article 15(1) (Right to Equality).
Judgment
- The Supreme Court ruled that Fundamental Rights (FRs) prevail over DPSP.
- The reservation policy violated Article 15(1) and was struck down.
- The case led to the First Constitutional Amendment (1951), which added Article 15(4) allowing reservation for socially and educationally backward classes.
Impact on DPSP
- The ruling highlighted conflicts between FRs and DPSP.
- Parliament responded by amending the Constitution, strengthening the DPSP objective of social justice (Article 46).
2. Keshavananda Bharati v. State of Kerala (1973)
Background
- The Kerala government attempted to acquire land from religious institutions for redistribution under land reform laws (based on DPSP).
- Swami Keshavananda Bharati challenged this, arguing that the government’s action violated his Fundamental Rights.
Judgment
- The Supreme Court established the Basic Structure Doctrine.
- It ruled that Parliament can amend Fundamental Rights but cannot destroy the basic structure of the Constitution.
- DPSPs and FRs must be harmonized, ensuring social justice while protecting fundamental rights.
Impact on DPSP
- Strengthened DPSPs related to economic equality and land reforms.
- Affirmed that DPSPs should not violate the basic structure of the Constitution.
3. Minerva Mills v. Union of India (1980)
Background
- The 42nd Amendment (1976) gave DPSPs primacy over Fundamental Rights.
- Minerva Mills challenged this amendment, arguing that it destroyed the basic structure of the Constitution.
Judgment
- The Supreme Court ruled that FRs and DPSPs should be balanced.
- It struck down provisions of the 42nd Amendment that gave DPSPs supremacy over FRs.
- Parliament cannot take away Fundamental Rights in the name of DPSP.
Impact on DPSP
- Reaffirmed the harmonization of FRs and DPSPs.
- Strengthened economic justice policies while maintaining individual rights.
4. Unnikrishnan v. State of Andhra Pradesh (1993)
Background
- The case questioned whether the Right to Education (Article 45 – DPSP) is enforceable.
Judgment
- The Supreme Court ruled that Right to Education is a fundamental right under Article 21 (Right to Life).
- Led to the 86th Constitutional Amendment (2002), adding Article 21A, making education a Fundamental Right.
Impact on DPSP
- Strengthened DPSPs related to education (Article 45, 46).
- The ruling transformed a DPSP into a Fundamental Right.
5. Olga Tellis v. Bombay Municipal Corporation (1985)
Background
- The Bombay Municipal Corporation evicted pavement dwellers, arguing that they were encroachers.
- Pavement dwellers challenged the eviction, claiming it violated their Right to Livelihood (Article 21).
Judgment
- The Supreme Court ruled that the Right to Livelihood is part of the Right to Life (Article 21).
- The government must consider socio-economic factors (DPSPs) before eviction.
Impact on DPSP
- Strengthened DPSPs related to social justice and housing policies.
- Led to rehabilitation policies for the urban poor.
6. M.C. Mehta v. Union of India (1986) – Environmental Protection
Background
- Environmental pollution and industrial hazards led to concerns over citizens’ health and safety.
Judgment
- The Supreme Court ruled that environmental protection is essential under Article 21.
- Directed the government to enforce DPSPs related to environment (Article 48A).
Impact on DPSP
- Strengthened environmental laws and sustainable development policies.
7. Dalmia Cement v. Union of India (1996) – Worker Welfare
Background
- Addressed labor rights and worker participation in industries.
Judgment
- Reinforced Article 43A (workers’ participation in industry management).
Impact on DPSP
- Encouraged pro-worker policies and industrial democracy.
8. Ashok Kumar Thakur v. Union of India (2008) – Reservation Policy
Background
- Challenged 27% reservation for OBCs in higher education.
Judgment
- Upheld reservation as a valid tool for social justice.
Impact on DPSP
- Strengthened Article 46 (upliftment of weaker sections).
9. People’s Union for Civil Liberties (PUCL) v. Union of India (2001) – Right to Food
Background
- Raised concerns over hunger and starvation deaths.
Judgment
- Directed the government to implement food security programs.
Impact on DPSP
- Led to the National Food Security Act (2013).
10. Indira Sawhney v. Union of India (1992) – Mandal Commission Case
Background
- Challenged reservation for OBCs in jobs.
Judgment
- Upheld 27% OBC reservation, with a 50% limit on total reservations.
Impact on DPSP
- Strengthened Article 46 (social justice and affirmative action).
Conclusion
DPSPs have played a vital role in shaping Indian laws and governance. Though not enforceable, courts have used DPSPs to interpret Fundamental Rights, leading to progressive laws ensuring social, economic, and political justice.
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