Conflicts Between Fundamental Rights & DPSP: Associated Cases
Champakam Dorairajan v the State of Madras (1951): In this case, 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 must conform to and run as subsidiary to the Fundamental Rights.
It also held that the Fundamental Rights could be amended by the Parliament by enacting constitutional amendment acts.
Golaknath v the State of Punjab (1967): In this case, the Supreme Court declared that Fundamental Rights could not be amended by the Parliament even for implementation of Directive Principles.
It was contradictory to its own judgement in the ‘Shankari Parsad case’.
Thus, the Right to Property (Article 31) was eliminated from the list of Fundamental Rights.
Minerva Mills v the Union of India (1980): In this case, the Supreme Court reiterated that Parliament can amend any part of the Constitution but it cannot change the “Basic Structure” of the Constitution.
