In which of the following cases did the Supreme Court of India declare the prevalence of Fundamental Rights over Directive Principles of the State Policy in case of conflict between the two?
- (a)Golaknath v. State of Punjab (1967)
- (b)The State of Madras v. Champakam Dorairajan (1951)
- (c)Kesavananda Bharati v. the State of Kerala (1973)
- (d)Minerva Mills v. the Union of India (1980)
Correct — B, The State of Madras v. Champakam Dorairajan (1951). This was the first major Supreme Court case on the relationship between the two parts of the Constitution: the Court struck down a caste-based reservation order in college admissions and held that Directive Principles must conform to and run subsidiary to Fundamental Rights — Fundamental Rights prevail wherever the two conflict. The judgment prompted Parliament to enact the First Constitutional Amendment (1951), inserting Article 15(4) to permit reservations for socially and educationally backward classes.
- (a)Golaknath v. State of Punjab (1967) — This case held that Parliament has no power under Article 368 to abridge or take away Fundamental Rights by ordinary constitutional amendment — it is about the amendability of Fundamental Rights, not about resolving a conflict between Fundamental Rights and Directive Principles.
- (c)Kesavananda Bharati v. the State of Kerala (1973) — This case propounded the 'basic structure' doctrine — that Parliament can amend Fundamental Rights but not the Constitution's basic structure — and partly overruled Golaknath; it is not the case that first declared Fundamental Rights prevail over Directive Principles.
- (d)Minerva Mills v. the Union of India (1980) — This later case struck down the 42nd Amendment's attempt to give Directive Principles overriding effect over Fundamental Rights (via Article 31C) and restored balance between the two — it responds to a subsequent controversy, not the original 1951 declaration.
The Constitution places Fundamental Rights (Part III, justiciable) and Directive Principles of State Policy (Part IV, non-justiciable) side by side, and their relationship — which prevails when they conflict — has been shaped by a sequence of Supreme Court judgments rather than a single constitutional clause.
Exams test this as a case-to-principle chain: which case first said what. Champakam Dorairajan (1951) is the earliest and most direct declaration that Fundamental Rights prevail over Directive Principles in a conflict; students often confuse it with the more famous later cases (Golaknath, Kesavananda Bharati, Minerva Mills) that deal with related but distinct questions.
- Champakam Dorairajan (1951): SC held DPSPs must conform to and run subsidiary to Fundamental Rights; struck down a caste-based reservation order.
- The judgment led directly to the First Constitutional Amendment (1951), which added Article 15(4).
- Golaknath (1967) is about whether Parliament can amend Fundamental Rights at all, not FR-vs-DPSP precedence.
- Minerva Mills (1980) later restored FR-DPSP balance after the 42nd Amendment tried to give DPSPs overriding effect.
Champakam Dorairajan (1951) is the earliest case to declare Fundamental Rights prevail over Directive Principles — keep it apart from the later, more famous cases.
- Confusing Golaknath (amendability of Fundamental Rights) with Champakam Dorairajan (FR-vs-DPSP precedence)
- Assuming Kesavananda Bharati is mainly about DPSP-FR conflict — it is primarily the basic structure case
MPPSC/UPSC like testing which landmark case established which specific principle — build a case-to-principle chain rather than memorising case names in isolation.
No directly related past PYQ was found.
- practice — not a real PYQ
The 'basic structure' doctrine of the Indian Constitution was propounded by the Supreme Court in which case?
- (a)State of Madras v. Champakam Dorairajan
- (b)Golaknath v. State of Punjab
- (c)Kesavananda Bharati v. State of Kerala
- (d)Minerva Mills v. Union of India
Answer(c) Kesavananda Bharati v. State of Kerala (1973).
- practice — not a real PYQ
Which Constitutional Amendment inserted Article 15(4), enabling reservations for socially and educationally backward classes, in response to the Champakam Dorairajan judgment?
- (a)First Amendment Act, 1951
- (b)Seventh Amendment Act, 1956
- (c)Twenty-fourth Amendment Act, 1971
- (d)Forty-second Amendment Act, 1976
Answer(a) First Amendment Act, 1951.