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In Minerva Mills v. Union of India (1980), the Supreme Court struck down parts of the 42nd Amendment that gave Directive Principles primacy over Fundamental Rights, holding that the balance between Part III and Part IV is part of the basic structure.
- True
- False
Answer: True
Minerva Mills (1980) FR-DPSP balance: (a) Context: 42nd Amendment (1976) inserted Article 31C giving DPSP primacy over FRs (Articles 14, 19), (b) Supreme Court holding (4:1): (i) Balance between Fundamental Rights (Part III) and Directive Principles (Part IV) is part of basic structure, (ii) Parliament cannot destroy this balance by giving absolute primacy to DPSP over FRs, (iii) Both are complementary: FRs provide means, DPSP provide ends for establishing egalitarian society, (c) Applications: (i) Subsequent amendments must maintain FR-DPSP balance, (ii) Judicial review ensures neither part destroyed, (iii) Harmonious construction: Courts interpret FRs, DPSP to give effect to both where possible, (d) Rationale: (i) FRs protect individual liberty against state excess, (ii) DPSP guide state policy towards social justice, (iii) Balance ensures neither individual rights nor collective welfare absolutely dominant, (e) Illustrates constitutional harmony: Basic structure doctrine preserves complementary relationship between rights, directive principles; neither can be destroyed without altering constitutional identity.