Introduction 

This landmark Supreme Court judgment, delivered by Chief Justice Y.V. Chandrachud on 31st July, 1980, addressed the critical constitutional question of the extent of Parliament's power to amend the Constitution under Article 368. The court ruled that the power of the parliament to amend the constitution is limited by the constitution. Hence the parliament cannot exercise this limited power to grant itself an unlimited power. The judgment held the basic structure doctrine established in Kesavananda Bharati case and struck down provisions of the 42nd Amendment that sought to give Parliament unlimited amending power, thereby protecting the constitutional balance between Fundamental Rights and Directive Principles of State Policy. 

Facts of the Case 

• In 1971, the Government of India acquired the Minerva Mills Company and nationalised the company.  
• The nationalization was carried out under various legislative acts. 
• Minerva Mills Ltd. and other petitioners filed a Writ Petition before the Supreme Court challenging the constitutional validity of their nationalization. 
• The case involved a challenge to the constitutional validity of Articles 31B and 31C of the Indian Constitution, and the 42nd Amendment (Article 368(4), 368(5). 
• The petitioners specifically challenged sections 4 and 55 of the Constitution (42nd Amendment) Act, 1976, which sought to give Parliament unlimited power to amend the Constitution. 
• Article 31B provided immunity to certain laws from judicial review, while Article 31C aimed to ensure the implementation of specific Directive Principles of State Policy (DPSPs). 
• The 42nd Amendment through Articles 368(4) and 368(5) attempted to place constitutional amendments beyond judicial review and declared that no amendment could be questioned in any court. 
• Minerva Mills Ltd. and other petitioners contended that these provisions infringed upon fundamental rights and violated the basic structure of the Constitution. 

Issues Involved 

• Whether Parliament under Article 368 has unlimited power to amend the Constitution or whether such power is subject to certain limitations. 
• Whether the amendments introduced by the 42nd Constitutional Amendment Act, 1976 violated the basic structure of the Constitution as established in Kesavananda Bharati case. 
• Whether Parliament could exclude judicial review of constitutional amendments through Articles 368(4) and 368(5) of the 42nd Amendment. 
• Whether Article 31C as amended gave absolute primacy to Directive Principles over Fundamental Rights, thereby disturbing the constitutional balance. 
• Whether the laws under which Minerva Mills was nationalized were constitutionally valid and protected under Article 31B. 

Court's Observations 

• Chief Justice Y.V. Chandrachud's Majority Judgment: 
  • Chandrachud, C.J., discerned the ratio of Keshavanada Bharti's case as 'Parliament has the right to make alterations in the Constitution so long as they are within its basic framework'. 
  • The Court held that the Constitution is founded on the bedrock of balance between Fundamental Rights and Directive Principles of State Policy, and neither can be given absolute primacy over the other. 
  • Parliament cannot, under Article 368, expand its amending power so as to acquire for itself the right to repeal or abrogate the Constitution or to destroy its basic and essential features. The donee of a limited power cannot by the exercise of that power convert the limited power into an unlimited one.' 
  • The Court emphasized that 'there are two essential features of the basic structure which would be violated, namely, the limited amending power of the Parliament and the power of judicial review with a view to examining whether any authority under the Constitution has exceeded the limits of its powers.' 
  • The Court noted that 'Our Constitution is a controlled constitution' and that removing judicial review would make it uncontrolled, which would damage its basic structure. 
• Key Constitutional Principles Established: 
  • The judgment identified that limited amending power of Parliament and judicial review are integral parts of the Constitution's basic structure that cannot be destroyed. 
  • The Court emphasized the need for harmonious interpretation between Fundamental Rights and Directive Principles, rejecting the notion that one should completely override the other. 
  • The judgment reinforced that the Constitution is supreme and even Parliament's constituent power is subject to constitutional limitations. 

Verdict  

• The Court declared Section 4 of the Constitution (42nd Amendment) Act, 1976 as unconstitutional and void, which had amended Article 31C to give primacy to all Directive Principles over Fundamental Rights. 
• The Court struck down Section 55 of the 42nd Amendment Act, which had inserted clauses (4) and (5) in Article 368, attempting to make constitutional amendments immune from judicial review. 
• The Court upheld the original Article 31C but struck down the amendments made by the 42nd Amendment that extended its scope beyond Articles 39(b) and (c). 
• The judgment reaffirmed and strengthened the basic structure doctrine, establishing clear boundaries on Parliament's amending power. 
• The Court established that judicial review of constitutional amendments is an essential feature of the Constitution that cannot be taken away. 

Conclusion 

The Minerva Mills case is 'a landmark decision of the Supreme Court of India that applied and evolved the basic structure doctrine of the Constitution of India.' The judgment established a robust framework for constitutional interpretation by reinforcing that Parliament's power to amend the Constitution under Article 368 is not unlimited and must respect the Constitution's basic structure. By striking down key provisions of the 42nd Amendment, the Court protected the independence of judiciary, preserved the balance between Fundamental Rights and Directive Principles, and ensured that India remains a constitutional democracy with effective checks and balances. This judgment continues to serve as a cornerstone of Indian constitutional jurisprudence, preventing any attempt to concentrate unlimited power in any single institution and maintaining the Constitution's character as the supreme law that binds even the Parliament.