Directive Principles of State Policy (DPSP) — Part IV

Overview

The Directive Principles of State Policy (DPSP) are contained in Part IV (Articles 36–51) of the Indian Constitution. Inspired by the Irish Constitution (which borrowed from the Spanish Constitution), DPSPs are guidelines for the state to follow while framing laws and policies.

Key Features

• Non-justiciable — cannot be enforced by courts (Article 37)
• Fundamental in governance — it is the duty of the state to apply these principles in making laws
• They represent the socio-economic goals of Indian democracy
• They complement Fundamental Rights — Rights provide political democracy, DPSPs aim for social and economic democracy

Article 37: "The provisions contained in this Part shall not be enforceable by any court, but the principles therein laid down 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."

Classification of DPSPs

The Constitution does not classify DPSPs. The following classification is based on the ideological basis and content of the directives:

Socialist Principles (Social & Economic Justice)

Gandhian Principles (Village Upliftment)

Liberal-Intellectual Principles

Common Mistake: Many aspirants believe FRs always prevail over DPSPs. This was true only until 1980. After Minerva Mills v. Union of India (1980), the Supreme Court held that harmony between FRs and DPSPs is itself part of the Basic Structure. Neither can destroy the other. This is the settled position and a frequent Mains question.

Mnemonic: To remember Gandhian DPSPs, think "PVCC" — Panchayats (Art 40), Village/cottage industries (Art 43), Cow protection (Art 48), Cooperatives (Art 43B). These reflect Gandhi's vision of self-sufficient village republics.

DPSPs Added by Constitutional Amendments

DPSP vs. Fundamental Rights: The Conflict

This is one of the most frequently tested areas in UPSC.

Evolution Through Landmark Cases

The Article 31C Story — Essential for Mains

Exam Tip: The Article 31C evolution is one of the most complex — and most tested — topics in Polity. The key point: Article 31C exists today but only protects laws implementing Articles 39(b) and 39(c), not all DPSPs. The 42nd Amendment's expansion was struck down in Minerva Mills.

Current Position

• FRs and DPSPs are complementary, not conflicting — "two wheels of a chariot"
• Courts use DPSPs to interpret the scope of Fundamental Rights
• Parliament can curtail FRs to implement DPSPs, provided the Basic Structure is not violated
• Several DPSPs have been converted into FRs or laws: education (Art. 21A), legal aid (NALSA), environment (EPA 1986)
• Courts have progressively read DPSPs into Article 21: right to education (Art. 45 DPSP → Art. 21A FR), right to clean environment (Art. 48A DPSP → Art. 21), right to livelihood (Arts. 39/41 DPSP → Art. 21)

DPSPs That Have Been Implemented

Right to Property — From FR to Constitutional Right

The 44th Amendment (1978) made a landmark change directly connected to the DPSP-FR conflict:

Why this matters for DPSP: The removal was motivated by the conflict between property rights (FR) and land reform DPSPs (Arts. 39(b)/(c)). The 44th Amendment also added Art. 38(2) (minimise inequalities in income, status, and opportunities).

Fundamental Rights vs. DPSPs vs. Fundamental Duties: Quick Comparison

Article 44 — Uniform Civil Code: Current Status

The UCC is the most debated DPSP. Recent developments have made it a live exam topic:

UCC — Key Case Law

Law Commission on UCC

• 21st Law Commission (2018): Concluded "UCC is neither necessary nor desirable at this stage" — recommended reforming personal laws from within
• 22nd Law Commission (2023–ongoing): Solicited fresh public views from June 2023; no final report as of March 2026

Key distinction: Article 44 directs a UCC "throughout the territory of India" — i.e., a national code. State-level UCCs are a new approach. The question of whether a state can enact UCC under its legislative competence (Entry 5, Concurrent List — "Marriage and divorce") vs. the need for a Central law is an evolving constitutional question. Expect this in Mains 2026.

Important for UPSC

Prelims Focus

• Article numbers for key DPSPs (39, 40, 44, 45, 48A, 50, 51)
• Which amendments added which DPSPs (42nd, 44th, 86th, 97th)
• Classification: Socialist vs. Gandhian vs. Liberal (frequent MCQ topic)
• DPSPs inspired by Irish Constitution
• Article 37 — non-justiciable but fundamental in governance

Mains GS-2 Dimensions

• "DPSPs are the conscience of the Constitution" — Discuss
• Is the Uniform Civil Code (Article 44) desirable in a diverse India?
• How have courts resolved the FR vs. DPSP conflict? (Minerva Mills is the key case)
• Implementation gap — which DPSPs remain unimplemented and why?
• Role of DPSPs in building a welfare state

Interview Angles

• "If you were a policymaker, which unimplemented DPSP would you prioritise?"
• "Can DPSPs be made justiciable? Should they be?"
• "Is the prohibition directive (Article 47) practical in modern India?"

Recent Developments (2024–2026)

Article 39(b) and Community Resources — Nine-Judge Bench Verdict (2024)

In Property Owners' Association v. State of Maharashtra (2024), a nine-judge Constitution Bench of the Supreme Court (8:1 majority) ruled on the scope of Article 39(b) — the DPSP directing the State to distribute material resources of the community so as best to subserve the common good. The bench held that not every privately owned resource constitutes a "material resource of the community" that the State can acquire. Chief Justice D.Y. Chandrachud, writing for the majority, overruled the expansive reading given by Justice V.R. Krishna Iyer in State of Karnataka v. Ranganatha Reddy (1977), which had suggested all private wealth could qualify.

The judgment significantly limits the State's power to nationalise private property under Article 39(b), while confirming that Article 31C — which protects laws implementing Articles 39(b) and 39(c) from challenges under Articles 14 and 19 — remains valid in its original (post-Minerva Mills) form.

UPSC angle: Prelims — nine-judge bench, 8:1 majority, 2024; Article 39(b); Article 31C valid. Mains — critically analyse the impact of the Property Owners' Association verdict on DPSP implementation; does it shift the FR–DPSP balance toward property rights?

Uniform Civil Code Debate Intensifies — Uttarakhand Leads (2024)

Uttarakhand enacted the Uniform Civil Code, 2024, becoming the first state to do so after the Constitution's commencement. The UCC codifies civil laws on marriage, divorce, inheritance, and adoption uniformly for all citizens regardless of religion, directly implementing Article 44 (Uniform Civil Code) of the DPSP.

The Law Commission of India (22nd Law Commission) sought public consultations on UCC in 2023–24, and the debate about a national UCC remains active as a core DPSP-versus-personal-law question.

UPSC angle: Prelims — Uttarakhand UCC 2024; Article 44; 22nd Law Commission. Mains — evaluate the constitutional imperatives and practical challenges in implementing a Uniform Civil Code; balance Article 44 against Articles 25-28 (religious freedom).

National Food Security, MGNREGS and DPSP Implementation (2024–2025)

The Union Budget 2025-26 continued funding the National Food Security Act, 2013 (implementing Articles 39(a) and 47) with allocation for free foodgrains to approximately 81.35 crore beneficiaries under PM Garib Kalyan Anna Yojana (PMGKAY). MGNREGS (implementing Articles 39, 41, 43) received ₹86,000 crore in the Union Budget 2025-26. The Ayushman Bharat – PM Jan Arogya Yojana (AB-PMJAY) was expanded in 2024 to cover senior citizens above 70 years of age regardless of income, implementing Articles 38 and 47 (right to an adequate level of living and improvement of public health).

UPSC angle: Prelims — PMGKAY, MGNREGS Budget 2025-26 allocation, AB-PMJAY expansion (2024) to 70+ seniors. Mains — map DPSPs to flagship welfare programmes; evaluate progress in converting non-justiciable DPSPs into enforceable rights through legislation and judicial interpretation.

SC on Right to Clean Environment and Climate Change (2024)

In M.K. Ranjitsinh v. Union of India (2024), the Supreme Court recognised the right against adverse effects of climate change as part of Article 21 (right to life), drawing support from DPSP Article 48A (protection and improvement of the environment). The bench directed that the duty to protect the environment under Article 48A and Fundamental Duty 51A(g) must be read together to create enforceable state obligations in matters of climate resilience and ecological preservation.

UPSC angle: Prelims — M.K. Ranjitsinh v. Union of India (2024); Article 48A; right against climate change. Mains — has the DPSP under Article 48A become justiciable through Article 21? Evaluate the SC's approach to environmental DPSPs.

Vocabulary

Welfare State

• Pronunciation: /ˈwɛl.fɛər steɪt/
• Definition: A system of government in which the state protects and promotes the economic and social well-being of its citizens through policies based on equal opportunity, equitable distribution of wealth, and public responsibility for those unable to provide for themselves.
• Origin: From Middle English wel fare ("condition of doing well") + state; the compound was popularised during World War II by Anglican Archbishop William Temple (1942), contrasting Britain's goals with the Nazis' "warfare state."

Gandhian

• Pronunciation: /ˈɡɑːn.di.ən/
• Definition: Of or relating to the ideas and philosophy of Mahatma Gandhi, especially his principles of non-violence, village self-sufficiency, and decentralised governance.
• Origin: From the proper name Gandhi + the suffix -ian; earliest recorded use in the 1920s (OED's first evidence from 1921, Daily Telegraph).

Socialistic

• Pronunciation: /ˌsəʊ.ʃəˈlɪs.tɪk/
• Definition: Having the characteristics of or tending towards socialism, particularly the advocacy of collective or state ownership and equitable distribution of resources.
• Origin: From French socialiste (from Latin sociālis, "of companionship") + the suffix -ic; earliest known use in the 1840s (OED's first evidence from 1848, The Times, London).

Key Terms

Minerva Mills Case

• Pronunciation: /mɪˈnɜːr.və mɪlz keɪs/
• Definition: The landmark 1980 Supreme Court judgment (Minerva Mills Ltd. v. Union of India, AIR 1980 SC 1789) that struck down Section 4 of the 42nd Amendment (which had expanded Article 31C to give all DPSPs primacy over Fundamental Rights under Articles 14 and 19) and Section 55 (which had granted Parliament unlimited amending power under Article 368), reaffirming that harmony between Fundamental Rights and Directive Principles is itself a part of the Basic Structure that Parliament cannot destroy.
• Context: Named after Minerva Mills Ltd., a nationalised textile company in Karnataka whose challenge to the 42nd Amendment's expansion of Article 31C led to this constitutional ruling. The 5-judge bench comprised Chief Justice Y.V. Chandrachud, Justices P.N. Bhagwati, A.C. Gupta, N.L. Untwalia, and P.S. Kailasam; the verdict was 4:1 with Justice Bhagwati dissenting. The Court held that Parliament's power to amend is not a power to destroy — "a limited power cannot be used to grant itself unlimited power." The case forms the third pillar in the FR-DPSP conflict trilogy: Champakam Dorairajan (1951, FRs prevail over DPSPs) to Kesavananda Bharati (1973, basic structure limits amending power) to Minerva Mills (1980, harmony between FRs and DPSPs is basic structure). Article 31C reverted to its original form — protecting only laws implementing Articles 39(b) and 39(c). The Property Owners Association v. State of Maharashtra (2024, 9-judge bench, 8:1) unanimously confirmed that Article 31C survives in this original form.
• UPSC Relevance: GS2 Polity — Prelims: year (1980), citation (AIR 1980 SC 1789), what was struck down (Sections 4 and 55 of 42nd Amendment), bench (5 judges, 4:1, Bhagwati dissenting), Granville Austin's "two wheels of a chariot" metaphor for FRs and DPSPs, Article 31C's current scope (only Arts 39(b)/(c)); Mains: trace the FR vs DPSP conflict from Champakam (1951) to Golaknath (1967) to Kesavananda (1973) to Minerva Mills (1980), analyse whether the balance has been maintained in practice, Article 31C's current status after Property Owners Assn (2024, 9-judge bench), evaluate whether DPSPs have been strengthened or weakened since 1980.

Non-Justiciable

• Pronunciation: /ˌnɒn.dʒʌˈstɪʃ.ə.bəl/
• Definition: Not capable of being adjudicated or directly enforced by a court of law; in the Indian Constitution, Article 37 explicitly states that the Directive Principles contained in Part IV "shall not be enforceable by any court, but the principles therein laid down 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." This means no citizen can sue the government for failing to implement a DPSP, but the state has a moral and constitutional obligation to strive towards their realisation.
• Origin: From the prefix non- + justiciable, derived from Middle French justiciable (from justice + -able), ultimately from Latin jūstitia ("justice").
• UPSC Relevance: GS2 Polity — Prelims: Article 37 (non-justiciable but fundamental in governance), DPSPs borrowed from the Irish Constitution of 1937 (Article 45), which DPSPs have been converted into justiciable rights through legislation or judicial interpretation (Art. 21A — right to education from DPSP Art. 45; right to clean environment from Art. 48A read with Art. 21; right to livelihood from Arts. 39/41 read with Art. 21); Mains: should DPSPs be made justiciable (evaluate arguments — would overburden courts vs would give teeth to socio-economic rights), how courts have indirectly enforced DPSPs through Article 21 interpretation (Unnikrishnan 1993, Olga Tellis 1985, Subhash Kumar 1991), contrast with South Africa where socio-economic rights are directly justiciable under the 1996 Constitution.

Current Affairs Connect

Link these static concepts with live developments:

Exam tip: For every government welfare scheme, identify which DPSP it fulfils. Read Ujiyari daily coverage to find real-world examples that make your Mains answers analytical.

Sources: Constitution of India, National Portal