Minerva Mills v/s Union of India

Minerva Mills v/s Union of India is a landmark case in Indian constitutional law. The Minerva Mills case revolved around the interpretation of Articles 14, 19, and 31 of the Constitution. The Land Acquisition Act, 1969 was also challenged in this case. This article will provide an overview of the Minerva Mills case, and discuss its impact on Indian constitutional law. In this case, Minerva Mills was the petitioner and the UOI was the respondent.

What is the background of Minerva Mills vs. the Union of India?

Minerva mills, a textile company in an area of Banglore which was running low on business. So, the government under S.15 of Industrial Development Regulations Act,1951 to inquire about the affairs of the committee appointed by Minerva Mills. The committee submitted its report to the Central Government, upon receiving the recommendation of the committee, the centre passed an order to take over the management of the company by National textile corporation limited. So, Minerva mills were nationalised, and subsequently, the Minerva mills and other petitioners challenged the decision of the government in the supreme court. To nullify the effect of the judgement of the supreme court, given in the case of Kesavanand Bharthi under Article 32 in which validity of the Land Acquisition Act, 1969 was challenged, the government passed an amendment in Article 368 clause 4 and 5 were added to it.

Petitioners Arguments

The petitioners in the case of Minerva Mills v/s Union of India was represented by Nani Palkivala and challenged the constitutional validity of the 42nd amendment act. The prime importance is given to Directive principles of State policies over fundamental rights given in part III of the constitution of India. It was argued that the said amendment prohibited or deprived them of their right to seek legal remedies as the concerned section barred the judicial review. It was also argued that the order of the supreme court in  Kesavananda Bharati under Article 32 dealing with Land Acquisition Act 1969 has been nullified by the legislature through this amendment. It was pressed in the court that the concept of Justice, Equality, and Liberty is deeply rooted in Articles 14 and 19 of the Constitution.

Respondent’s Arguments

The government was represented by A.G. L.N. Sinha and ASG KK Venugopal. They argued that Article 31C reinforced the concept of basic structure. It was argued that the process of implementing DPSP cannot be said to harm the basic structure of the Indian Constitution. The main focus of the argument of the respondent was on whether the said amendment deprived the fundamental rights of their status. It was also said that laws made to secure the objective of DPSP shall always be in the public interest. Any law fulfilling the directive Article 38 is incapable of abrogating the fundamental freedoms given by the constitution.

What was the issue involved in the case of Minerva Mills v/s Union of India?

The issue involved with the case was, whether the 42nd amendment act was passed beyond the right of parliament to amend the constitution in Article 368 and whether DPSP given in part IV can have primacy over part fundamental rights given in part III of the constitution.

Judgement

The 5 judges bench by 4:1 majority gave the decision and declared that sections 4 and 55 of the 42nd amendment act were ultra vires to the basic structure of the constitution. The court held that clauses 4 and 5 of article 368 inserted through the 42nd amendment act were unconstitutional as both the clauses transgressed the limitations on amending power of the parliament. Further, it was said that if courts were deprived of the power to review then other rights will appear dimming. The fundamental rights and Directive Principles of state policy as mentioned under Part III and IV fundamental are the soul of the constitution and act as a core for social change. The balance of both parts will only create harmony for development and shall create a conducive environment for the development of the nation. In a nutshell, it can be said that through this case, the decision of the court reflected a balance between the fundamental rights and directive principle of the state policy.

Conclusion

Minerva Mills v/s union of india is a landmark case in Indian constitutional law. It set important precedents with regards to the interpretation of the Constitution and the doctrine of separation of powers. This case was significant in that it affirmed the supremacy of Parliament over state legislatures, and also recognized judicial review as an essential part of our constitutional framework. It was said by the court in its judgement that to give effect to part IV by destroying the concept of part III is to downgrade the ethos of the basic feature of the constitution.  In this article, we have provided a comprehensive overview of the Minerva Mills case and its impact on Indian constitutional law. We hope our readers find this article informative and helpful in their studies. Do you have any questions or comments about this article? Please let us know in the comments section below.