Minerva Mills Ltd. v. Union of India (1980)

Minerva Mills Ltd. v. Union of India (1980)

Background

The landmark case of *Minerva Mills Ltd. v. Union of India* (1980) is pivotal in the context of Indian constitutional law. The case dealt with the limits of parliamentary power in amending the Constitution. It reinforced the doctrine of the basic structure of the Constitution.

Facts

Minerva Mills, a textile company, challenged the constitutional validity of the amendments made to the Constitution of India. These amendments included the 42nd Amendment Act of 1976. This act had introduced significant changes to the Constitution. The company argued that these amendments undermined the fundamental rights and the basic structure of the Constitution.

Issue

The primary issue in this case was whether Parliament had the power to alter or amend the Constitution. This destroy or alter its basic structure.

Judgment
The Supreme Court of India, in a unanimous judgment delivered by Chief Justice Y.V. Chandrachud, reaffirmed the basic structure doctrine established in *Kesavananda Bharati v. State of Kerala* (1973). The Court held that the basic structure of the Constitution can not be altered or destroyed through amendments. This doctrine limits the amending power of Parliament, ensuring that certain fundamental features of the Constitution stay inviolable.

The Court declared that while Parliament has the power to amend the Constitution, such power is not absolute. The amendments must not infringe upon or destroy the Constitution’s basic structure. This includes elements such as the supremacy of the Constitution, the rule of law, separation of powers, and the federal structure.

The Court invalidated certain provisions of the 42nd Amendment that were found to be in conflict with the basic structure doctrine. This reaffirmation ensured that the power to amend the Constitution was not used to undermine its fundamental principles.

Impact
The decision in *Minerva Mills* is significant because it reinforced the balance between the need for constitutional flexibility and the protection of essential constitutional principles. By limiting the amending power of Parliament, the case ensured that fundamental values enshrined in the Constitution are preserved against potential majoritarian excesses.

Citation
Minerva Mills Ltd. v. Union of India, AIR 1980 SC 1789, [Link to the judgment](https://indiankanoon.org/doc/1062601/).