7 Paper 14

Multi Disciplinary Edu Global Quest (Quarterly), Volume 2, Issue 3 #7, July 2013

A JOURNEY TOWARDS IMPLEMENTING DIRECTIVE
PRINCIPLES OF STATE POLICY AN ANALYSIS OF
LANDMARK CASES
Bhupal Bhattacharya
B.com (H), LL.M., PGDCA
Lecturer in Law, Law College Durgapur, Mob. [phone]; [e-mail] Bineet Kedia
B.Com, LL.M., UGC-NET
Lecturer in Law , Amity University, Jaipur, Rajasthan, Mob. [phone]; [e-mail] ABSTRACT:
Directive Principles are essential in the governance of the country and the state must and is bound to take positive actions in the implementation of the same in order to secure the concept of
“Welfare State” as laid down by the founding fathers of the Constitution. These principles as rightly pointed out by Amartya Sen can be coined as “social rights” which are very indispensable to achieve the socio economic needs of the society. Hence, such principles should and must be implemented under every circumstance and the obligation to secure the same lies on the State.
Secondly, the Court is required to take judicial notice of the said principles in times of any kind of conflict with the other provisions of the Constitution.
Constitution of India is the lengthiest written Constitution in the world. Amongst all the salient features, a very innovative feature has been incorporated from Irish Constitution in the name of
Directive Principles of State Policy in the Part IV of the Indian Constitution. In the view of John
Austin, the Indian Constitution is first and foremost a social document with an aim either directly or indirectly attains the goals of social revolution. Austin was of the view that rights and principles were included in the constitution by the constituent Assembly with an expectation to flourish India giving strength to the pursuit of social revolution in the country. Many Jurists at the time of its incorporation was of the view that the idea of welfare state can be only achieved if the state makes endless endeavour to implement these directives with a high sense of moral duty.
The Directive Principles lay down certain economic and social policies to be followed by the government of each state in certain directions in order to promote welfare of the people and achieve economic democracy. In this research paper, the researcher seeks to discuss on the nature and object of directive principles and analyse the significance of the directives in the governance of the country in the light of few landmark case laws.
Keywords: Directive Principles, Constitution of India, Justifiability, Rulings of Supreme Court.

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INTRODUCTION:
India is the largest democratic country in the world, regulated by the Indian Constitution which is considered as the mother of all the laws and statutes. One of the salient features of the Indian
Constitution is that it is the world‟s largest written and bulkiest constitution in the world. India by its nature is federal but unitary in nature. Part IV of it provides Directive Principles of State
Policy which is in the form of Directives to all the State Governments to proceed towards achieving socio- economic rights to the citizens of that particular state. Directive Principles of
State Policy cannot be justified before the courts of law, means if any state fails to achieve the desired ends of the provisions of the Part IV of the Constitution of India, it cannot be held responsible for its failure.
SCOPE OF THE STUDY
This study tries to arrive to a certain conclusion from various secondary information like judgments of different High Courts and Supreme Court of India; and also various laws and enactments and provisions of Constitution of India as to find out how far still Directive Principles are viewed as justiciable in India.
OBJECTIVES OF THE STUDY
To find out the significance of the directives principles of state policy.
To find out how far the social policies enshrined in Constitution of India in the shape of DPSP can be promoted by a State government to achieve economic democracy.
METHODOLOGY
This study is based on secondary data, in the light of few landmark case laws, various enactments, Constitution of India. In this research paper, the researcher seeks to discuss on the nature and object of directive principles and analyse the significance of the directives in the governance of the country.
NATURE AND OBJECT:
Today we are living in an era of welfare state which seeks to promote the prosperity and wellbeing of the people through Articles 36-51. The Directives are designed to achieve socioeconomic democracy in the country, where these principles obligate the state to take positive action in certain directions in order to promote the welfare of the people.
In a number of pronouncements, the Supreme Court itself insisted that these Directive Principles seek to introduce the concept of a welfare state in the country. The Supreme Court of India in

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Paschim Banga Khel Mazdoor Samity v. State of West Bengal observed that “In a welfare state the primary duty of the Government is to secure the welfare of the people”1.
The Directives lay down the lines on which the state of India should work under this constitution.
It has been divided into the following groups: (1) certain ideals, particularly economic, which the framers of the Constitution wished that the State should strive for. (2) Certain directions to the future Legislature and the future Executive to show in what manner they should exercise their executive and legislative power. (3) Certain rights of the citizens shall not be enforceable by the courts like the fundamental rights but which the state shall aim at securing by regulation of its legislative and administrative policy.
The constitution makers while drafting the provisions of Constitution had acted with humanitarian socialist aspirations of the people and declared it as a fundamental in the governance of the country. If the preamble is the key to understand the constitution or to open the mind of its makers, the Directive Principles of the State Policy as enshrined in Part IV are its basic ideal.2
In Keshavananda Bharti v. State of Kerala,3the nature and object of Directive Principles is stated as: “The Directive Principles of State Policy set forth the humanitarian socialist precepts that were the aims of the Indian social revolution. It was also held in D.S. Nakara v. Union of India,4 that the Directive Principles are obligations of the State towards fulfilment of which every state action must be directed and interpreted
While drafting the provisions of Constitution, Dr. B. R. Ambedkar in Constituent Assembly, had expressed that a ruling party which fails to implement the Directive principles would stand to lose in the next election.5
In the words of Sri G.N.Joshi, “They constitute a very comprehensive political, social and economic objective of a welfare state.”6
IMPORTANCE OF DIRECTIVE PRINCIPLES:
The Directive Principles of State Policies are an amalgam of diverse subjects embracing the life of the nation and include principles which are general statements of social policy, principles of
1

Paschim Banga Khel Mazdoor Samity v. State of West Bengal, (1996)4, SCC 37,AIR 1996 SC 2426 th Durga Das Basu, Commentary on the Constitution of India, Lexis Nexis Butterworths Wadhwa Nagpur, 8 edition, 2008, p.4017
3
AIR 1973 SC 1461; (1973)4 SC 2426.
4
AIR 1983 SC 130
5
th
M.P. Jain, Indian Constitutional Law, Wadhwa Nagpur, 5 edition, 2008, p.1364
6
J.N.Pandey, Constitutional Law of India, Central Law Agency,p.385
2

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Multi Disciplinary Edu Global Quest (Quarterly), Volume 2, Issue 3 #7, July 2013 administrative policy, socio economic rights and a statement of the international policy of the country.7 In the views of John Austin, Directive Principles are not justifiable, but they are to be nevertheless fundamental in the governance of the country. To foster the goal of the Directive
Principles, every State is required to ensure that the citizens should have adequate means of livelihood, ownership to the common good, education and a healthy environment be guaranteed to all.
The Scheme of the Constitution generally discloses that the principles of social Justice are placed above individual rights and whenever or wherever it is considered necessary, individual rights have been subordinated to give effect to the principle of social justice which means various concepts that are evolved in the Directive Principles of the State Policy. Moreover, non justifiability does not mean non judicial cognizibility because enforcement of any provision by a court is not the real test of law. Therefore, it is the duty of the court to take judicial cognizance of any of these principles on being violated.
According to Mathew J. Fundamental Rights are the ends of endeavour of the Indian people for which the Directive Principles provided the guidelines, which goes to mean that fundamental rights cannot be peacefully enjoyed without proper and effective realisation of the Directive
Principles. And the basic object of conferring fundamental freedoms on individuals is the ultimate achievement of the ideals set out in Part IV. However, it cannot be ignored that the
Directive Principles are fundamental in the governance of the country. And what is fundamental in the governance of the country cannot be of any less significance than what is fundamental in the life of an individual because life of an individual cannot be safeguarded in absence of the instrumentality of state action which regulates the life of each individual.
It was held in Golak Nath v. State of Punjab,8 that the Directive Principles of State Policy directs to work for an egalitarian society, where there is no concentration of wealth, where there is plenty, where there is equal opportunity for all, to educate, to work, to livelihood and where there is social justice.
It emphasises in amplification of the preamble, that the goal of the Indian policy is not laissez faire but rather a welfare state, where the State has a positive duty to ensure its citizens social and

7

th

Durga Das Basu, Commentary on the Constitution of India, Lexis Nexis Butterworths Wadhwa,8 edition
2008, p.4018.
8
AIR 1967 SC1643

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Multi Disciplinary Edu Global Quest (Quarterly), Volume 2, Issue 3 #7, July 2013 economic justice and dignity of the individual. It would serve as an instrument of instruction upon all future governments regardless of their party creed.9
In G.B. Pant University of Agriculture & Technology v. State of U.P.10 the Supreme Court held an opinion that Part IV of the Constitution aims to end poverty, ignorance, disease and inequality of opportunity. It further held that though the provisions of Part IV are not enforceable by the courts, the principles laid therein are nevertheless fundamental in the governance of the country. And it shall be the duty of the State to apply these principles in making laws. Fundamental Rights and the Directive Principles constitute “Conscience of the Constitution”, and the Constitution aims at bringing about a synthesis between Fundamental rights and the Directive Principles by giving former a place of pride and to the latter a place of permanence, together they form the core of the
Constitution.
In Ashok Smokeless Coal India(P) Ltd. V. Union of India11 the importance of Directive Principles of State Policy was felt by the Apex Court in the following words:
Whenever action is taken by the State in consonance with the provisions laid down in the
Directive Principles, as envisaged in the Part IV of the Constitution, the same is considered to be reasonable an action. However, this does not amount to saying that any action which is not in consonance with the provision of Part IV would be ultra vires. There cannot be any doubt whatsoever that the principles contained in Part IV would form a relevant consideration for determining a question in regard to price fixation of an essential commodity. They provide for a guideline to the interpretation of fundamental rights of a citizen as also the statutory rights.
The very design of the Article 37 which contains the word “shall” indicates a clear mandate of state observance of the said provision and effective implementation of the directive principles for the proper governance of the nation. If the government, irrespective of its party creed, pursues a policy which is in accordance with the principles enunciated in the Constitution and caters to their sense of justice, the electorate will endorse its policy and allow it to continue in office; otherwise they will repose their confidence in another party. This system of alteration in power system is very peculiar to a parliamentary form of government and the vigilance of public opinion is the sanction behind it. This is the main reason for the deliberate incorporation of the language of the
Directive Principles in the Constitution. 12

9

Bhim Singh v. Union of India, AIR 1981 SC 234
AIR 2000 SC 2695
11
2007(2) SCC 640
12
th
Select Constitution by Anup Chand Kapur and KK Mishra, 16 edition, 2006, p.117
10

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The word “fundamental” used in Article 37 means basic or essential but it is used in the normative sense of setting before the State goals which it should endeavour to achieve. As fundamental rights are backed by legal sanction, these Directive Principles are left to the government as a sense of duty imposed as a moral duty for the governance of the nation. This follows from the fact that the duty imposed on the state by the Fundamental Rights is a legally enforceable duty and the duty imposed by the Directive Principles of the State Policy is a “moral duty.” But talking about law which is purposive we maintain that it is minimum morality.
Therefore, the moral duty imposed on state should also be considered in the same sense, i.e. duty which also should be legally enforceable.
In an early decision of the Allahabad High court in the case Balwant Raj v. Union of India13, it is held that the expression “making of laws” is wide enough to include their interpretation and therefore, in interpreting laws the courts must have regard to the Directive Principles and the same principle as affirmed by the Supreme Court in various subsequent cases.14
The main object of the Directive Principle of State Policy is to fix a certain social and economic goals for the immediate attainment by bringing about a non violent social revolution. Through such a revolution the constitution seeks to fulfil the basic needs of the common masses. 15
So far as the end of the state is concerned, it is clearly that of a welfare state, which aims at social welfare and common good of all citizens and to secure to all citizens of economic and social justice as declared in the preamble to the Constitution which aims for a socialistic pattern of society, can be achieved only with complete realisation of the Directive Principles by the State.
DIRECTIVE PRINCIPLES AS AN AID FOR INTERPRETATION
It cannot be denied that the Directives are not an essential part of the Constitution. Therefore, it follows that the rule of harmonious construction must be read along with all the other provisions of the Constitution especially that with the Fundamental Rights. The Court cannot ignore the
Directive Principles in deciding any case relating any other provisions of the Constitution. To consider the reasonableness of restrictions on the fundamental rights by any legislation, especially the rights guaranteed under Article 14, 19 and 21, the Directive Principles of State Policy would serve as standard for testing the same.16 As held by the Apex Court in Akhil Bhartiya Soshit

13

AIR 1968 SC14.

15

Keshavananda Bharti v. State of Kerala, AIR 1973 SC 1461, PM Ashwathnarayan Setty v. State of Karnataka
AIR 1989 SC 100
16
Kasturi Lal v. State of State of J&K, AIR 1980 SC 1992

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Karamchari Sangh v.Union of India17 that the Directives should serve the courts as code of interpretation and most of the conflicted fundamental rights should be interpreted in the light of the Directive Principles and the same should be read into the fundamental rights.
Also as a result of much debate, free legal aid for the disabled was adopted through an amendment in 1976 and Article 39A was inserted, when it was not declared as a fundamental right. But it was eventually made a fundamental right under Article 21 in the light of Article 39A after the case of M.S.Hoskot v. State of Maharashtra18
In Minerva Mills case19 it was held that the Fundamental Rights are not the end in itself but are the means to an end and the end is specified in the Directive Principles of the State Policy. This position was summed up by Chinnappa Reddy, J in the case of Akhil Bhartiya Soshit Karamchari
Sangh v. Union of India20 by stating that- “The Directive Principles should serve the courts as a code of interpretation....Every law attacked on the ground of infringement of the fundamental rights should among other considerations, be examined to find out if it does not advance one or other Directive Principles”
CAN DIRECTIVE PRINCIPLES BE IMPLEMENTED BY THE GOVERNMENT
WITHOUT LEGISLATION?
Broadly speaking, the executive power of the government is co-extensive with the legislative power of the state and the government can therefore without legislation do by taking administrative action what could be done by legislation subject to certain conditions viz. When there is a law relating to the matter, the executive action must not be inconsistent with such law.
Again there are certain provisions in the constitution which says that a thing may be done only by a legislation e.g. imposing restriction etc. Hence in such case the government cannot implement the Directives without a law by way of administrative actions. But in case where a particular act for e.g. carrying out a business such as liquor, which is not a fundamental right, it is open to the government to implement the directive principle in article 47 by an executive action. Therefore from this point of view an implementation of the essential Directives is inevitable in the proper governance of the country, even without legislation subject to the prescribed conditions.
It cannot and perhaps be permitted to overlook the Directives altogether, while the court cannot directly enforce them against the state, or compel the state to observe and abide by them in

17

AIR 1981 SC 298
AIR 1978 SC 1548.
19
Minerva Mill Ltd. V. Union of India, AIR 1980 SC 1789
20
AIR 1981 SC 298: (1981)2 SCR 185
18

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Multi Disciplinary Edu Global Quest (Quarterly), Volume 2, Issue 3 #7, July 2013 making laws, the courts are bound to evolve and affirm and in fact adopt principles of interpretation of the constitution and the laws made by the State, as will further and not hinder the goals set out in the Directive Principles.21
Again, in Bandhua Mukti Morcha v. Union of India22 the court held that it cannot direct the legislature or execute to enforce the Directives, but once legislation is passed in pursuance of
Directive Policies, the court can order the State to enforce the law, particularly when non enforcement of law leads to denial of fundamental rights. Likewise, where land was granted by the government to construct a housing society for the dalits and non- dalits, in the ratio 80:20, the court can compel the authorities to implement the scheme in accordance with the bye laws and according to the ratio fixed. Here the authority cannot allot extra land to the favour of the nondalits because such a scheme was fixed in implantation of the obligation under Article 38 and 39.
The implementation of the Directive Principles depends upon the felt necessities of the time and court should take into consideration the principles in resolving many disputes relating to many other provisions of the Constitution and it should also not fail to take judicial cognizance of the
Directives because this might help in the proper governance of the country and also to achieve the ideals of a Welfare state.
In an article of Sri B.N. Rau in „The Hindu‟, he gave an answer to the question of importance of
Directive Principles of State Policy by saying that “such moral precepts had an educative value even though not enforceable.” He further maintained that “it may be occasionally necessary for the state to invade private rights to discharge one of its positive duty to raise the nation‟s standard of health, of living.”23
DIRECTIVE PRINCIPLES VIS-A-VIS FUNDAMENTAL RIGHTS
The Supreme Court in it numerous rulings had shown a difference of opinion in this regard. But in its later development it has tried to avoid any kind of conflict between the two by following the rule of harmonious construction. Previously, the Court did give primacy to Directive Principles on few occasions and to Fundamental Rights on few occasions. But after rendering the judgment of the Keshavananda Bharti case, the Supreme Court is consisting holding the view that both
Directive Principles and the Fundamental Rights aim at the same goal of bringing about a social revolution and establishment if a welfare state and they can be interpreted and applied together.
However, in many cases the Supreme Court was emphatic that the Directives have to conform to
21

UPSE Board v. Hari Shankar, AIR 1979 SC 65, D.S.Nakara v. Union of India, AIR 1983130
AIR 1984 SC 802
23
Reprint in Rau’s “ India’s Constitution”, pp. 364-65
22

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Multi Disciplinary Edu Global Quest (Quarterly), Volume 2, Issue 3 #7, July 2013 and run subsidiary to the Chapter on Fundamental Rights. One of such case was State of Madras
v. Champakkam Dorairajan24 In this case the Court, applying this theory, invalidated an order which provided for reservation of seats for admission into a State educational institution, on the ground that it offended against Art.29(2), even though it might have been inspired by the
Directive in the Art.46
Again in another case, In re Kerala Education Bill25 the Court held that a law which sought to compel minority educational institutions for children not to charge fees would contravene the fundamental right guaranteed to such institution by Art. 30, even though the State was enjoined by Art.45 to provide free education for children below 14 years.
But it is however desired that there should not be any more conflict between the two provisions because of having the common goal and objective. Therefore, the only way to satiate the working of both the provisions is to read one in the light of the other because Fundamental Rights cannot be enjoyed by violating the Directive Principles because the coronation and crucification of the
Constitution depends upon the implementation of the Directive Principles.
In Chandra Bhawan Boarding v. State of Mysore26 the Supreme Court held that the ambit of freedom of business guaranteed by Article 19(1) (g) should be determined in the light of the
Directives under Article 43 which directs the State to secure to all workers a living wage, conditions of work ensuring a decent standard of life and full enjoyment of leisure and sociocultural opportunities.27
Therefore, this new trend and decision shows that it is being increasingly difficult to draw a line between the fundamental rights and the directive principles when courts are exercising the power of judicial review. These decisions indicate that at least in some areas of directive principles the rights of citizens are vitally connected with fundamental rights and failure to discharge such obligations will involve the invalidation of legislation or executive action at the instance of the people. Hence, the government is bound to implement the Directive Principles.
DIRECTIVE PRINCIPLES: FROM DIRECTION TO DEED
The Directive Principles of State Policy in Part IV of the Constitution is a Nation Manisfesto. The founding fathers of the constitution bore in mind their aspirations and ideals. They had undergone numerous problems like poverty, ill- fed, ill- clothed etc. And this incited them to initiate a
24

AIR 1951 SC226
AIR I958 SC 956
26
AIR 1970 SC 2042
27
Article 43 of the Constitution of India.
25

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Multi Disciplinary Edu Global Quest (Quarterly), Volume 2, Issue 3 #7, July 2013 revolution towards reforming the economic and the social system that was prevalent during those days. This led to the incorporation of the Directive Principles in the Constitution. And these
Directives are like mandates which cannot be ignored. But even though these principles are made mandatory, they do not bear a legal force, which means therefore, that they are not judiciously non enforceable. This problem of non enforceability as enshrined in the Constitution has assumed a new dimension in the view of present day political scenario. There is no positive policy framed for the implementation of these principles.
One important question which all of us should ask ourselves is that in what way and how much have we been able to achieve the objectives and realize the goals as set in the Constitution?
66 years after independence, we learn that it is the judiciary that has played a pivotal role in the implementation and in actual realisation of the Directive Principles rather than the executive. The post constitutional decision of the Apex Court clearly indicates that it is the judiciary that was responsible to make the directives from mere directions to deeds.
This we can exemplify in the light of few landmark judgment in the avenue of Directive
Principles. In recent case, even though the Directives per se cannot be enforced by the neither court nor can the court compel the State to legislate on the mandatory implementation of the
Directive Principles, the Supreme Court has taken initiative to remove the grievances which have been caused by non implementation of the same by way of issuing directions. In Randhir Singh v.
Union of India28 the concept of equal pay for equal work under Article 39(d) has been positively interpreted as a part of right to live with basic human dignity which was incorporated under Part
III of the Constitution. Again, in the case of Rural Litigation and Education Kendra29,
M.C.Mehta v. Union of India30 the Apex Court, relying on Article 48-A gave directions to the central and the state governments and various local bodies to take appropriate steps for the prevention and control of pollution of water thereby fostering one of the principles enshrined under the above Article. It was thus made one of the rights under Article 21 of the Constitution.
Furthermore, right to education has been recognised as a fundamental right in Mohini Jain 31 and
Unni Krishnan J.P. v. State of A.P.32 case. While doing so, the Supreme Court relied upon the
Directive Principles enunciated in the Article 41 and 45 of the Constitution. However, it must be

28

AIR 1982 SC 879
AIR 1985 SC 431
30
1988(2) SCC 471
31
Mohini Jain v. State of Karnataka, AIR 1992 SC 1858
32
AIR 1993 SC 2178
29

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Multi Disciplinary Edu Global Quest (Quarterly), Volume 2, Issue 3 #7, July 2013 noted that the Article 45 confers only a limited right to Education to all children by directing the
State to provide for free and compulsory education until the completion of 14 years.
So far seems to be no evidence of its accomplishment by the legislative efforts to make it a reality. But on the other hand the Supreme Court has recently held that the right to education is a part and parcel of the right to live with basic human dignity as protected by Article 21 in two above landmark cases. Similarly, many of such Directive Principles were transmitted into the chapter on Fundamental Rights to give effect to such principles, with the initiative of our judiciary. Thus, in that view, Directive Principles have been given added value and effect by our highest
Judiciary, nonetheless the legislature and the executive failed to fulfil the object laid down by our founding fathers of the constitution in the Chapter of Directive Principles of State Policy.
CONCLUSION
We have entered into the 21st century and for the past many years we have been talking of preparing ourselves for this century but when we were only at the threshold of this century, we started hearing the cries of the farmers, the workers and the Indian employers and all the deprived sections of our society. When we desperately waited for this millennium we also cultivated a hope of long term welfare of the country with its masses through the instrumentality of the State, but in vain, as our renowned economists provided us a very poor figure of economic growth of our country. This very hope culminates into a tragic despair.
It is not that our Constitution, which is considered as the Superior Law of Fundamental
Obligation has not provided us a solution for justifiability of Directive Principles of State Policy.
In reality, a very lucid provision on the implementation of the concept of a “Welfare State” has been made, but our political leaders have repeatedly failed to take steps to accelerate the economic growth of our nation and thereby securing a welfare state to itself.
Our Constitution enumerates a chapter on Directive Principles of State Policy which finds its respectable place in Part IV of the said constitution. These directives have ever been a point of discussion in the Indian legal circle on the very subject of its enforceability. Since the problem of non enforceability has always been addressed without a pragmatic answer and for which these
Directives still remains unenforced by the Government, which conveniently finds its escape route from its positive burden of endeavouring towards social and economic upliftment of the nation at large, and this is a peak time to revise the Constitution to make these directives judicially enforceable which would then be successful in practically compelling the government to take

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Multi Disciplinary Edu Global Quest (Quarterly), Volume 2, Issue 3 #7, July 2013 compulsory actions to implement these directives. May be then we can yet again hope for a
“welfare sate” under the guidelines set forth in these directives.
No doubt there have been some achievements made in this field which is evident from many
Supreme Court pronouncements till date, yet the same are inadequate. It is therefore, essential that a deep thought is given to the relevance of the Directives in the present day politicoeconomic situation of India.
BIBLIOGRAPHY
Books Referred
1. Basu, Durga Das, Commentary on the Constitution of India, Lexis Nexis butterworth
Wadha,8th edition,2008.
2. Granville, Austin, The Indian Constitution- Cornerstone of a Nation, Oxford India
Paperbacks, 1999.
3. Jain, M.P., Indian Constitutional Law, Wadhwa Nagpur, 5th edition,2005
4. Kapur, Anup Chand, Select Constitution, S Chand & Co., 1999.
5. Pandey, J.N., Constitutional Law of India, Central Law Agency, 44th edition,2007
6. Seervai, H.M., Constitution of India, Universal Law Publishing Co., 4th edition, 2008.
7. Shukla, V.N., Constitution of India, Eastern Book Company, 9th edition, 1994
Articles Referred
1. Subhash Chandra Sharma, “Directive Principles of State Policy:Has the time come to make it Enforceable” All India Reporter, Vol. 88(6), 2001
2. Zafar Ahmed Siddique Khan, “50 years of Independence of Directive Principles of State Policy”, Supreme Court Journal, Vol. 1, 2000.
3. T. Devidas, “Directive Principles: Sentiment or Sense”, Journal of Indian Law
Institute, 1975.
Cases Referred
1. Paschim Banga Khel Mazdoor Samity v. State of West Bengal, (1996)4, SCC 37,AIR
1996 SC 2426.
2.

Keshavananda Bharti v. State of Kerala, AIR 1973 SC 1461; (1973)4 SC 2426.

3.

D.S. Nakara v.Union of India, AIR 1983 SC 130.

4.

Golak Nath v. State of Punjab, AIR 1963 SC 1643.

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5.

G.B. Pant University of Agriculture & Technology v. State of U.P, AIR 2000, SC 2695.

6. Bhim Singh v. Union of India, AIR 1981 SC 234.
7. V. Markendeya v. State of A.P., AIR 1989 SC 1308.
8. Ashok Smokeless Coal India (P) Ltd. V. Union of India, 2007(3), SCC 640.
9. Balwant Raj v. Union of India, AIR 1968 SC 14.
10. PM Ashwathnarayan Setty v. State of Karnataka, AIR 1989 SC 100.
11. Akhil Bhartiya Soshit Karamchari Sangh v.Union of India, AIR 1981 SC 298.
12. State of Karnataka v. Appa Balu Ingale, AIR 1993 SC 1126.
13. M.S.Hoskot v. State of Maharashtra, AIR 1978 SC 1548.
14. Kasturi Lal v. State of State of J&K, AIR 1980 SC 1992.
15. Minerva Mill Ltd. V. Union of India, AIR 1980 SC 1789.
16. Akhil Bhartiya Soshit Karamchari Sangh v. Union of India, AIR 1981 SC 298.
17. Bandhua Mukti Morcha v. Union of India, AIR 1984 SC 802.
18. State of Madras v. Champakkam Dorairajan, AIR 1951 SC 226.
19. In re Kerala Education Bill, AIR 1958 SC 956.
20. Chandra Bhawan Boarding v. State of Mysore, AIR 1970 SC 2042.
21. Randhir Singh v. Union of India, AIR 1982 SC 879.
22. M.C.Mehta v. Union of India, 1988 (2) SC 471.
23. Mohini Jain v. State of Karnataka, AIR 1992 SC 1858.
24. Unni Krishnan J.P. v. State of A.P, AIR 1993 SC 2178.

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Bibliography: 2. Granville, Austin, The Indian Constitution- Cornerstone of a Nation, Oxford India Paperbacks, 1999. 7. Shukla, V.N., Constitution of India, Eastern Book Company, 9th edition, 1994 Articles Referred 3. T. Devidas, “Directive Principles: Sentiment or Sense”, Journal of Indian Law Institute, 1975. Keshavananda Bharti v. State of Kerala, AIR 1973 SC 1461; (1973)4 SC 2426. 8. Ashok Smokeless Coal India (P) Ltd. V. Union of India, 2007(3), SCC 640. 22. M.C.Mehta v. Union of India, 1988 (2) SC 471.