The Minerva Mills Case (1980) was a crucial Supreme Court ruling that strengthened the Basic Structure Doctrine and further limited Parliament’s power to amend the Constitution. The case struck down parts of the 42nd Amendment (1976), which had given Parliament unlimited power to amend the Constitution, including Fundamental Rights.
1. Background of the Minerva Mills Case
🔹 Minerva Mills Ltd. was a textile company in Karnataka that was nationalized by the government under the Sick Textile Undertakings (Nationalization) Act, 1974.
🔹 The company challenged this law, arguing that it violated Fundamental Rights (Article 14 & 19).
🔹 The government defended its action using Article 368, claiming Parliament had unlimited power to amend the Constitution after the 42nd Amendment (1976).
🔹 The main issue was:
- Does Parliament have unlimited power to amend the Constitution, including Fundamental Rights?
2. Constitutional Provisions Involved
| Article | Provision |
|---|---|
| Article 14 | Right to Equality |
| Article 19 | Right to Freedom of Speech & Expression |
| Article 21 | Right to Life and Personal Liberty |
| Article 31C | Allowed Parliament to make laws overriding Fundamental Rights to implement Directive Principles of State Policy (DPSP) |
| Article 368 | Power of Parliament to amend the Constitution |
3. Supreme Court Judgment in Minerva Mills Case
🟢 Judgment Date: July 31, 1980
🟢 Bench Strength: 5 Judges
🟢 Majority Decision: 4:1
The Supreme Court ruled that:
✅ Parliament cannot amend the Constitution in a way that destroys its Basic Structure.
✅ Article 368 does not give unlimited power to amend the Constitution.
✅ The balance between Fundamental Rights and Directive Principles of State Policy (DPSP) must be maintained.
✅ Struck down parts of the 42nd Amendment (1976), which gave Parliament unlimited amending power.
This ruling reaffirmed the Kesavananda Bharati Case (1973) and strengthened the Basic Structure Doctrine.
4. What Parts of the 42nd Amendment Were Struck Down?
The Supreme Court declared two provisions of the 42nd Amendment unconstitutional:
🔹 Section 4 of the 42nd Amendment – Expanded Article 31C, which stated that laws made to implement DPSPs cannot be challenged in court, even if they violate Fundamental Rights.
🔹 Section 55 of the 42nd Amendment – Made Parliament’s power to amend the Constitution unlimited under Article 368.
By striking these down, the Supreme Court restored the balance between Fundamental Rights and DPSPs.
5. Impact of the Minerva Mills Case
🔹 Strengthened the Basic Structure Doctrine – Parliament’s power to amend the Constitution is limited.
🔹 Restored Judicial Review – Courts can strike down unconstitutional amendments.
🔹 Re-established the Balance Between Fundamental Rights & DPSPs – Parliament cannot use DPSPs to take away Fundamental Rights.
🔹 Reduced Parliament’s power from the 42nd Amendment – Ensured that democracy remains protected.
6. Related Supreme Court Cases
| Case | Year | Significance |
|---|---|---|
| Shankari Prasad Case | 1951 | Parliament can amend Fundamental Rights. |
| Golaknath Case | 1967 | Parliament cannot amend Fundamental Rights. |
| Kesavananda Bharati Case | 1973 | Established Basic Structure Doctrine. |
| Indira Gandhi Case | 1975 | Used Basic Structure Doctrine to strike down 39th Amendment. |
| Minerva Mills Case | 1980 | Limited Parliament’s power & struck down parts of the 42nd Amendment. |
7. Important Articles Related to the Minerva Mills Case
| Article | Provision |
|---|---|
| Article 14 | Right to Equality |
| Article 19 | Right to Freedom |
| Article 21 | Right to Life and Personal Liberty |
| Article 31C | Laws to implement DPSPs cannot violate Fundamental Rights (Struck down in Minerva Mills Case). |
| Article 368 | Power of Parliament to amend the Constitution. |
| 42nd Amendment (1976) | Gave unlimited amending power to Parliament (Struck down in Minerva Mills Case). |
8. MCQs on Minerva Mills Case
1. What was the main issue in the Minerva Mills Case?
a) Reservation policy
b) Parliament’s power to amend the Constitution
c) Right to Education
d) Presidential Elections
✅ Answer: b) Parliament’s power to amend the Constitution
2. In which year was the Minerva Mills judgment delivered?
a) 1973
b) 1976
c) 1980
d) 1985
✅ Answer: c) 1980
3. Which amendment was partially struck down in the Minerva Mills Case?
a) 24th Amendment
b) 39th Amendment
c) 42nd Amendment
d) 44th Amendment
✅ Answer: c) 42nd Amendment
4. What was the Supreme Court’s ruling in the Minerva Mills Case?
a) Parliament has unlimited power to amend the Constitution
b) Parliament’s amending power is limited by the Basic Structure Doctrine
c) DPSPs are superior to Fundamental Rights
d) The President has the power to amend the Constitution
✅ Answer: b) Parliament’s amending power is limited by the Basic Structure Doctrine
5. How many judges were on the Supreme Court bench in the Minerva Mills Case?
a) 5
b) 7
c) 9
d) 11
✅ Answer: a) 5
6. Which article deals with the amendment process in the Indian Constitution?
a) Article 13
b) Article 19
c) Article 32
d) Article 368
✅ Answer: d) Article 368
7. Which case introduced the Basic Structure Doctrine, later strengthened by the Minerva Mills Case?
a) Golaknath Case
b) Kesavananda Bharati Case
c) Indira Gandhi Case
d) SR Bommai Case
✅ Answer: b) Kesavananda Bharati Case
8. Which part of the 42nd Amendment was struck down in the Minerva Mills Case?
a) Section 2
b) Section 4
c) Section 5
d) Sections 4 & 55
✅ Answer: d) Sections 4 & 55
9. Conclusion
The Minerva Mills Case (1980) was a historic Supreme Court judgment that limited Parliament’s power to amend the Constitution and reaffirmed the Basic Structure Doctrine. It protected Fundamental Rights, restored Judicial Review, and struck down parts of the 42nd Amendment.
For competitive exams, understanding the verdict, impact, and related cases is crucial. Stay updated with recent constitutional amendments and Supreme Court rulings to strengthen your preparation! ✅📚
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