मिनर्वा मिल्स बनाम भारत संघ
| Citation | AIR 1980 SC 1789, (1980) 3 SCC 625 |
| Court | Supreme Court of India (Constitution Bench) |
| Date | 31 July 1980 |
| Year | 1980 |
| Bench | Y.V. Chandrachud CJI, P.N. Bhagwati, A.C. Gupta, N.L. Untwalia, P.S. Kailasam JJ. |
| Acts/Articles | Article 31C, Article 368, 42nd Amendment |
| Category | Constitutional Law |
Key Principle Established
The 42nd Amendment provisions giving Parliament unlimited amending power and excluding judicial review are unconstitutional. Balance between Fundamental Rights and Directive Principles is part of basic structure.
Minerva Mills challenged the nationalization of their textile undertaking. The broader question was the validity of Sections 4 and 55 of the Constitution (42nd Amendment) Act, 1976 — which expanded Article 31C to give Directive Principles primacy over all Fundamental Rights and removed limits on Parliament’s amending power.
The Constitution Bench struck down both provisions:
Minerva Mills saved Indian democracy from the Emergency-era constitutional amendments. It reinforced and strengthened the Kesavananda basic structure doctrine, established that there are limits to amending power even in a democracy, and preserved judicial review as a basic feature. Justice Chandrachud’s observation — “if the amending power is unlimited, the Constitution is a conceit” — remains one of the most powerful statements in Indian constitutional law.
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Read AnalysisThis judgment summary is for educational and research purposes. While care has been taken to accurately represent the ratio and findings, for authoritative reference always consult the original judgment text from official sources (SCC Online, AIR, Manupatra, or court websites).
22+ years of practice before Punjab & Haryana High Court and Supreme Court of India.