Q. Examine how the Indian Constitution balances Fundamental Rights with Directive Principles to promote the ideal of a Welfare State. How has the judiciary interpreted this balance in landmark cases?

Introduction:
The concept of a Welfare State is deeply rooted in the Directive Principles of State Policy, which guide the State toward distributive justice. Though non-justiciable, Article 37 declares them fundamental to the governance of the country, prompting judicial interventions—notably in the Kesavananda Bharati and Minerva Mills cases—which harmonized them with Fundamental Rights to uphold the constitutional balance and transformative vision.

Body:
Constitutional Provisions Balancing FRs and DPSPs to Promote a Welfare State:
1. Article 37 – DPSPs as non-justiciable but Fundamental
-Although not enforceable in courts, Article 37 mandates that DPSPs guide lawmaking.
-This ensures that policy goals like health (Art. 47), education (Art. 45), and equal pay (Art. 39(d)) remain integral to the State’s duties.
-Example: National Food Security Act (2013) reflects Art. 47 (nutrition) and supports Right to Life (Art. 21).

2. Article 21 – Transforming FRs through DPSP Values
-The Supreme Court has expanded the scope of Article 21 by integrating socio-economic rights inspired by DPSPs like Articles 39, 47, and 48A, ensuring a welfare-oriented constitutional interpretation.
-Example: M.C. Mehta v. Union of India (1988) – In the Ganga Pollution case, the Supreme Court held that the Right to a Wholesome Environment is part of the Right to Life under Article 21.
-This interpretation drew strength from Article 47 (public health) and Article 48A (protection of environment), reinforcing environmental protection as a constitutional obligation of the State.

3. Article 31C – Enabling Socio-Economic Legislation
-Laws made to implement Art. 39(b) & 39(c) (equitable distribution & prevention of wealth concentration) are protected even if they violate Art. 14 or 19.
-Example: The land ceiling laws aimed at redistribution were shielded under Art. 31C.

4. Preamble – Guiding Spirit for a Welfare State
-The Preamble commits to “Justice—social, economic and political” and “Equality of opportunity”, reflecting DPSPs and FRs together.
-Example: MGNREGA fulfills Art. 41 (right to work) and aligns with the Preamble’s socio-economic justice vision.

5. Articles 15(3) & 46 – Enabling Affirmative Action for Weaker Sections
-Art. 15(3) empowers the State to make special provisions for women and children, even within the equality framework.
-Art. 46 directs the State to promote the welfare of SCs, STs, and weaker sections.
-Example: Reservation policies under Art. 16(4) and educational scholarships fulfill both equality and upliftment mandates.

Judicial Interpretation: Balancing Fundamental Rights and Directive Principles:

1. Champakam Dorairajan v. State of Madras (1951)
a. The Supreme Court upheld the primacy of Fundamental Rights over DPSPs by striking down caste-based reservations in educational institutions as violative of Article 29(2).
b. This led to the First Constitutional Amendment (1951), introducing Article 15(4) to enable protective discrimination.

2. Golak Nath v. State of Punjab (1967)
a. The Court ruled that Parliament cannot amend Fundamental Rights, even to implement DPSPs, as FRs were considered immutable and transcendental.
b. Triggered the 24th Constitutional Amendment (1971) restoring Parliament’s power to amend any part of the Constitution, including FRs.

3. Kesavananda Bharati v. State of Kerala (1973)
a. The Court allowed amendment of Fundamental Rights, but ruled that the Basic Structure of the Constitution (which includes harmony between FRs and DPSPs) cannot be violated.
b. Established the Basic Structure Doctrine, ensuring FRs and DPSPs are co-equal components of constitutional governance.

4. Minerva Mills v. Union of India (1980)
a. In this landmark judgment, the Supreme Court struck down Section 4 of the 42nd Constitutional Amendment, which attempted to give absolute primacy to Directive Principles of State Policy (DPSPs) over Fundamental Rights (FRs). The Court ruled that such an override would damage the Basic Structure of the Constitution.

b. The Court firmly held that neither FRs nor DPSPs are superior, and both are integral to achieving the constitutional goal of a Welfare State. They must be seen as complementary and not contradictory, like the “two wheels of a chariot” that must move together to ensure social and economic justice.

c. This judgment reaffirmed the Basic Structure Doctrine laid down in Kesavananda Bharati and ensured that individual liberties are not sacrificed in the name of social welfare, while also giving due weight to State obligations under DPSPs.

d. This case became a cornerstone in constitutional jurisprudence, emphasizing that the harmony between FRs and DPSPs is itself a part of the Basic Structure, and neither can be sacrificed for the other.

Conclusion:
Granville Austin, in his seminal work on the Constitution of India, has described Fundamental Rights and DPSPs as “the conscience of the Constitution which connects India’s future, present, and past by giving strength to the pursuit of social revolution in India”.