Minerva Mills Ltd. and Ors. vs Union of India and Ors.
Writ Petition (Civil) 356 of 1977
AIR 1980 SC 1789
Date of judgement: 03-07-1980
In this case law, you will learn about the facts, issues, arguments, and judgement of the Minerva Mills case in a nutshell.
One of the most contentious (likely to cause argument) issues in the history of independent India has been the doctrine of the basic structure of the Indian Constitution, as it doesn’t define the term explicitly.
The debate over whether or not Fundamental Rights can be amended resulted from the conflict between Article 13 and Article 368. The judiciary’s interpretation of the position of the basic structure, which cannot be amended, was greatly influenced by the judgement of Minerva Mills vs Union of India.
Not only did this case contribute to our knowledge of basic structure as a whole, but cases like Shankari Prasad vs Union of India, Sajjan Singh vs State of Rajasthan, Golaknath vs State of Punjab, and Kesavananda Bharati vs State of Kerala also made significant contributions. The doctrine of basic structure was again reaffirmed in cases like Indira Gandhi vs Raj Narain and Waman Rao vs Union of India.
Facts of the Minerva Mills Case
A textile business known by the name of Minerva Mills once stood in the state of Karnataka. The central government established a committee to investigate this company in 1970, in accordance with section 15 of the Industries (Development and Regulation) Act, 1951, after it saw a sharp decline in output levels.
Under section 18A of the Industries (Development and Regulation) Act, 1951, the National Textile Company was ordered to assume control of the company due to mismanagement of its affairs in accordance with the Sick Textile Undertakings (Nationalization) Act, 1974, and a court order authorising this action was also issued under this section. Minerva Mills challenged the takeover of the company in the High Court, but the motion was denied. Later, the corporation filed a writ petition with the Supreme Court under Article 32 of the Indian Constitution.
Issues Raised in the Minerva Mills Case
- Whether section 4 (amendment of Article 31C) and section 55 (amendment of Article 368) of the 42nd Amendment Act of the Indian Constitution destroy the basic structure.
- Whether Directive Principles of State Policy (DPSP) can lawfully overrule Fundamental Rights.
- Whether the amendment made to Article 31C is valid.
Arguments in the Minerva Mills Case
These were the arguments advanced by both petitioners and respondents.
Arguments Given by the Petitioner
The petitioner’s learned counsel claimed that several provisions of the 42nd Amendment violated the Indian Constitution, particularly sections 4 and 55, since they directly challenged the fundamental design (structure) of the Indian Constitution. Clauses (4) and (5) of Article 368 gave the Parliament the power to amend the Constitution, which eventually reduced the power of the judiciary. The learned counsel also said that the 42nd Amendment rendered it almost impossible for there to be any harmony between the Directive Principles of State Policy and the Fundamental Rights since it rendered it difficult for the Directive Principles to supersede the Fundamental Rights.
Arguments Given by the Respondent
The learned Attorney General argued for the state’s crucial role in advancing the public’s welfare. The Attorney General and the learned Solicitor General argued that the context must be taken into account while interpreting Article 31C of the Indian Constitution. The Attorney General came to the conclusion that the basic structure of the Constitution and legislation adopted in the public interest are consistent and that these laws should not have a negative impact on the basic structure of the Constitution.
In support of this claim, the Attorney General cited Article 38 of the Constitution, which states that the basic structure of the Constitution is based on principles of justice, society, politics, and economics. As a result, if a law complies with Article 38, it cannot supersede the Fundamental Rights and will not, therefore, undermine the basic structure of the Constitution.
The Supreme Court deemed clauses (4) and (5) of Article 368, which was added by the Constitution’s 42nd Amendment in 1976, to be unconstitutional and void, and thus overruled the Parliament’s ability to amend the Constitution. The court concluded that although the Parliament can change the Constitution, it cannot undermine or amend the basic structure of the Constitution.
The court ruled that, as it is a vital component of the Constitution’s framework, there must be congruence between Fundamental Rights and the Directive Principles of State Policy.
Additionally, it was determined that Article 31C is within the purview of the Parliament’s power to amend the Constitution and does not undermine its basic structure.
The Minerva Mills case stands out as one of the most notable cases in terms of independent India’s history. In this decision, the Supreme Court determined the constitutional significance of both the Directive Principles of State Policy and Fundamental Rights, guaranteeing a balance between the two.
The Supreme Court also upheld Article 368 clauses (4) and (5). The 42nd Amendment Act, on the other hand, served as a vehicle for the exploitation of the basic structure of the Constitution, notably sections 4 and 55 of the 42nd Amendment Act. Therefore, it was necessary for the Supreme Court to rule that the clauses were unconstitutional since they violated the basic structure, and the court wanted to stop further exploitation.
It should be noted that the Supreme Court and the petitioner’s learned counsel made significant and laudable efforts to protect the foundation of the Constitution.
This case is crucial because it paved the way for the Indian Constitution to become what it is today. This case not only served to preserve the basic structure of the Indian Constitution, but it also established a precedent for similar cases in the future. This important decision also aided in preventing attacks on Fundamental Rights and preserving the harmony between Part III and Part IV of the Indian Constitution, which are dedicated to Fundamental Rights and Directive Principles of State Policy, respectively. Although the idea of basic structure was not only in doubt in this case, it was unquestionably the first to provide guidance for interpreting and upholding the doctrine of basic structure.
Suggestions and Recommendations
It has been said that this ruling is one of the most historic, as it has been anticipated for a very long time. Even though it took the court a while to give the basic features the weight and persistence they needed, the wait was well worth it. I think the court made the right judgement because it took into account all of the arguments raised by the petitioner’s learned counsel and accorded basic features the importance they deserved. The petitioner’s counsel’s arguments were succinct and, in my opinion, contributed to the judges’ reaching this conclusion. I, too, think that eliminating the Parliament’s unrestricted authority is the best course of action.