Directive Principles and administrative functions
🇮🇳 Directive Principles of State Policy and Administrative Functions
📘 Introduction: What Are Directive Principles?
The Directive Principles of State Policy (DPSPs) are guidelines for the State (which includes all branches of government, especially the executive/administration) to ensure social justice, economic welfare, and democratic governance in India.
Enshrined in Part IV of the Constitution (Articles 36–51).
Not enforceable by courts (Article 37), but fundamental in governance.
They are a constitutional directive for administrative functions, policy-making, and legislation.
⚖️ Relationship Between DPSPs and Administrative Functions
While DPSPs are non-justiciable, they guide administrative action in areas like:
| DPSP Article | Administrative Responsibility |
|---|---|
| Article 39 | Fair distribution of resources; prevent concentration of wealth |
| Article 41 | Provide public employment and education |
| Article 42 | Ensure humane working conditions |
| Article 47 | Raise nutrition and public health standards |
| Article 48A | Protect and improve the environment |
| Article 44 | Strive for Uniform Civil Code |
| Article 46 | Promote educational and economic interests of SC/STs |
The administration, through policies, schemes, welfare measures, and regulatory actions, is expected to fulfill these objectives.
🏛️ Detailed Case Law Analysis (More Than Five Cases)
1. State of Madras v. Champakam Dorairajan (1951)
Citation: AIR 1951 SC 226
Facts: The State of Madras reserved seats in educational institutions based on caste.
Issue: Was such reservation valid under DPSPs?
Held: Supreme Court held that Fundamental Rights override DPSPs in case of conflict.
Significance: Initially established that DPSPs cannot violate fundamental rights, but later jurisprudence evolved to balance both.
2. Kesavananda Bharati v. State of Kerala (1973)
Citation: AIR 1973 SC 1461
Facts: Challenge to constitutional amendments that sought to implement land reform laws under DPSPs.
Held: DPSPs form part of the basic structure of the Constitution.
Significance: Reinforced that the State (including administration) must strive to implement DPSPs without destroying fundamental rights. It paved the way for balancing rights and social justice.
3. Minerva Mills Ltd. v. Union of India (1980)
Citation: AIR 1980 SC 1789
Facts: Challenge to an amendment that gave unlimited power to Parliament to amend the Constitution to implement DPSPs.
Held: The Court held that harmony between Fundamental Rights and DPSPs is part of the basic structure.
Significance: The administration must balance economic goals (DPSPs) with civil liberties (FRs), ensuring neither is ignored.
4. Unni Krishnan v. State of Andhra Pradesh (1993)
Citation: AIR 1993 SC 2178
Facts: Dealt with the issue of right to education under Article 21.
Held: Supreme Court held that Right to Education is implicit under Article 21, and it correlates with Article 45 (DPSP).
Significance: Administrative obligation to implement educational schemes like Sarva Shiksha Abhiyan arises from this case.
5. Paschim Banga Khet Mazdoor Samity v. State of West Bengal (1996)
Citation: AIR 1996 SC 2426
Facts: A labourer was denied emergency treatment in several hospitals.
Held: The Court held that the State is duty-bound to provide adequate medical facilities, citing Article 47 (public health).
Significance: Administrative failure to provide healthcare can be a violation of Article 21, and DPSPs guide the scope of State obligations.
6. Olga Tellis v. Bombay Municipal Corporation (1985)
Citation: AIR 1986 SC 180
Facts: Pavement dwellers were being evicted without rehabilitation.
Held: Right to livelihood is part of Right to Life under Article 21, which is reinforced by Article 39(a).
Significance: Administrative eviction orders must consider right to livelihood and provide humane solutions.
7. Dalmia Cement (Bharat) Ltd. v. Union of India (1996)
Citation: AIR 1996 SC 3945
Facts: Challenge to price control and distribution of cement.
Held: State has power to regulate trade in public interest under Article 39(b) (distribution of material resources).
Significance: Justifies administrative regulation in resource allocation, price control, and public interest.
8. MC Mehta v. Union of India (1987–2000)
Facts: Multiple environmental PILs including Ganga pollution, vehicle emissions, and industrial pollution.
Held: The Court invoked Article 48A (DPSP) and Article 21 to direct administrative action for environmental protection.
Significance: Administrative authorities were compelled to enforce pollution norms, close factories, and regulate vehicles, all in line with DPSPs.
🧠 Principles Emerging from the Case Law
| Principle | Explanation |
|---|---|
| Harmonious Construction | Fundamental Rights and DPSPs must be interpreted together. |
| Positive Obligations | DPSPs impose affirmative duties on the State and administrative machinery. |
| Policy Guidance | DPSPs guide legislation, budgeting, and policy implementation. |
| Enforceability via Article 21 | Though not directly enforceable, many DPSPs are judicially enforced through Article 21. |
| Welfare State Objective | DPSPs underpin the idea of a welfare and social justice-oriented administration. |
🛠️ Implementation through Administrative Mechanisms
| DPSP Article | Administrative Action |
|---|---|
| Article 39(b) | Public Distribution System, land reform |
| Article 41 & 43 | MGNREGA, Skill India Mission |
| Article 42 | Labour laws, maternity benefits, factory regulations |
| Article 47 | National Health Mission, Ayushman Bharat |
| Article 48A | Forest conservation, Pollution Control Boards |
| Article 46 | Reservation policies, scholarships, welfare boards |
📝 DPSPs and Administrative Legislation
Right to Education Act, 2009: Implements Article 45.
National Food Security Act, 2013: Inspired by Articles 39(b) and 47.
Environment Protection Act, 1986: Related to Article 48A.
Maternity Benefit (Amendment) Act, 2017: Linked with Article 42.
✅ Conclusion
The Directive Principles of State Policy, while non-enforceable, act as a constitutional compass for administrative authorities. Over the years, Indian courts have interpreted administrative inaction or policy failure as violations of Article 21, thereby indirectly enforcing DPSPs.
The administrative machinery—through legislation, schemes, executive orders, and welfare programs—carries the primary burden of realizing these principles and building an inclusive, welfare-oriented State.
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