In which of the following cases did the Supreme court of India give a ruling that, 'in case of any conflict between the fundamental rights and the directive principles, the former would prevail'?

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  1. Champakam Doraijan Case, 1951
  2. Keshvananda Bharti Case, 1973
  3. Golaknath Case. 1967
  4. Minerva Mills Case, 1980

Answer (Detailed Solution Below)

Option 1 : Champakam Doraijan Case, 1951
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The correct answer is Champakam Dorairajan Case, 1951.

Key Points

  • The Supreme Court of India ruled in the Champakam Dorairajan Case, 1951, that fundamental rights have supremacy over directive principles in case of any conflict between the two.
  • This landmark judgment emphasized the importance of fundamental rights as enshrined in Part III of the Indian Constitution.
  • The case involved the challenge against a communal Government Order of Madras that provided caste-based reservations in educational institutions.
  • The Supreme Court held that such reservations violated the fundamental right to equality guaranteed under Article 15(1).
  • Consequently, this ruling led to the First Amendment of the Constitution in 1951, allowing the state to make special provisions for socially and educationally backward classes.

Additional Information

  • Fundamental Rights
    • Fundamental Rights are the basic human rights guaranteed to all citizens by the Constitution of India.
    • They are enshrined in Part III of the Constitution and include rights such as the right to equality, freedom of speech, and protection against exploitation.
    • These rights are enforceable by the courts, subject to specific restrictions.
  • Directive Principles of State Policy (DPSP)
    • DPSPs are guidelines for the framing of laws by the government, outlined in Part IV of the Indian Constitution.
    • They are not enforceable by any court but are considered fundamental in the governance of the country.
    • DPSPs aim to create social and economic conditions under which citizens can lead a good life.
  • First Amendment of the Indian Constitution
    • It was enacted in 1951 to address judicial decisions and public criticism of certain provisions of the Constitution.
    • The amendment added Article 15(4) to allow the state to make special provisions for the advancement of any socially and educationally backward classes of citizens or for the Scheduled Castes and the Scheduled Tribes.
    • It also added Articles 31A and 31B to protect laws providing for the acquisition of estates, etc., from being challenged on the ground that they contravened the fundamental rights.
  • Article 15 of the Indian Constitution
    • It prohibits discrimination on grounds of religion, race, caste, sex, or place of birth.
    • Article 15(1) ensures that no citizen shall be discriminated against on these grounds in matters of access to public places.
    • Article 15(4) allows the state to make special provisions for the advancement of any socially and educationally backward classes of citizens or for the Scheduled Castes and the Scheduled Tribes.
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