Minerva Mills Case (1980)

Supreme Court Judgement:

• Invalidation of Clauses (4) and (5) of Article 368: The Supreme Court invalidated Clauses (4) and (5) of Article 368, which were inserted by the 42nd Amendment Act (1976).

• Unconstitutionality of the Amendment to Article 31G: The amendment made to Article 31G by the 42nd Amendment Act (1976) was also declared unconstitutional.

• Destruction of Basic Structure: The Court stated that the changes made by the 42nd Amendment Act (1976) destroyed the basic structure of the constitution.

• Basic Features Identified: The judgement identified the limited power of Parliament to amend the constitution, judicial review, and the harmony and balance between fundamental rights and directive principles as basic features of the constitution.

Impact of the Judgement:

• Nullification of 42nd Amendment Act's Attempt: The judgement nullified the 42nd Amendment Act (1976)'s attempt to dilute the doctrine of the basic structure.

• Unlimited Amending Power Rejected: The Supreme Court held that Parliament cannot confer upon itself unlimited and uncontrolled amending power under Article 368.

• Protection of the Constitution's Integrity: The Court ruled that Parliament cannot expand its amending power to repeal, abrogate, or destroy the constitution's basic features.

• Balance Between Rights and Principles: The judgement emphasized that anything disrupting the balance between fundamental rights and directive principles destroys an essential element of the constitution's basic structure.

• Directive Principles vs. Fundamental Rights: It held that giving precedence to directive principles over fundamental rights (Articles 14, 19, and 31) would inherently destroy this balance.