Conflict Between Fundamental Rights and Directive Principles

Fundamental human rights (FR) are the rights of every individual that the Supreme Court has identified as necessitating a high level of security from governmental intrusion. Such rights are either explicitly stated in the Constitution or discovered through Judicial Oversight.

The goal of the Directive Principles of State Policy (DPSP) is to establish socioeconomic conditions that allow individuals to live happy lives. They also focus on a social benefit system to achieve cultural-financial democracy.

Considering the relevance of both FRs & DPSPs, there is indeed a contradiction between the two, mostly when one is subject to judicial review and the other is not.

Case 1: Kerala Education Bill (1957): Doctrine of Harmonious Construction

Concerning the Kerala Education Bill (1957), the Supreme Court declared the Doctrine of Harmonious Interpretation to resolve differences between DPSPs with Fundamental Rights. According to the Supreme Court doctrine, there is no obvious difference between FRs and DPSPs, and courts must aim to prioritise both as much as feasible. In the rare instance that a law can be interpreted in only one way, the court would prefer the fundamental rights over the DPSPs.

Case 2: Champakam Dorairajan Case (1952)

Smt. Champakam Dorairajan, hailing from Tamil Nadu, was refused entrance to a veterinary institution in 1951 due to a Communal Government Order that granted caste-based quotas in government jobs and educational institutions. 

The Champakam Dorairajan judgment was the first time the Supreme Court ruled that Fundamental Rights hold more value than DPSPs. It was the Apex Court’s first important judgment on reservations. The Court ruled that DPSPs could not be enforced by law the way Fundamental Rights could be. This long-drawn case was similar to the Sajjan Singh V/s State of Rajasthan and Qureshi v/S State of Bihar cases.

Case 3: Golak Nath Case (1967) 

In the Golak Nath vs Punjab State case in 1967, the Supreme Court had to form a committee of eleven judges. They were forced to come together and make changes to the constitution. The amendment of articles 13 and 368 made it obvious that the Parliament had every right to make changes to the constitution for the betterment of the citizens of India.

Conclusion

Whenever the Fundamental Rights and the Directive Principles have seen conflict, Jawahar Lal Nehru considered that Legal Provisions must be prioritised. When we look at the two’s judicial ‘natures,’ we see that the Supreme Court would support the Fundamental Human rights since they are safeguarded by that of the Constitution and so justified.