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Checking relevance for Property Owners Association VS State of Maharashtra...
2024 8 Supreme 387 : In Minerva Mills the Supreme Court struck down Section 4 of the Forty‑Second Amendment, holding that the amendment’s attempt to give absolute primacy to Directive Principles (including Article 31‑C) over Fundamental Rights (Article 14) was unconstitutional; thus it limited the scope of Article 31‑C and reaffirmed the balance between fundamental rights and directive principles. By contrast, in Sanjeev Coke the Court, while noting concerns about the reasoning in Minerva Mills, proceeded on the basis that Article 31‑C (as it stood before the Forty‑Second Amendment) remained operative and held that once a law is protected by Article 31‑C, Article 14 cannot be invoked against it. Hence, Sanjeev Coke treats Article 31‑C as a shield against Article 14 challenges, whereas Minerva Mills curtails that shield by restoring the supremacy of fundamental rights.Checking relevance for Property Owners Association VS State Of Maharashtra...
1996 4 Supreme 223 : Minerva Mills upheld the revival of Article 31C (as it stood after the Kesavananda Bharati decision) and struck down Section 4 of the 42nd Amendment, thereby confirming that Article 31C remained valid. Sanjeev Coke, while also proceeding on the premise that Article 31C was revived, criticised the majority opinion in Minerva Mills and expressed agreement with Justice Bhagwati’s dissenting view, yet it did not overturn the Minerva Mills holding and continued to apply the revived Article 31C.Checking relevance for Union of India VS Tarsem Singh...
2019 0 Supreme(SC) 1041 : In Minerva Mills v. Union of India (1981) the Supreme Court declared the amended Article 31‑C unconstitutional, effectively rendering Article 31‑C a dead letter. By contrast, in Sanjeev Coke Manufacturing Co. v. Bharat Coking Coal Ltd. (1983) the Court interpreted the phrase material resources of the community in Article 39(b) to include all resources – natural and man‑made, public and privately owned – thereby giving a broad, inclusive meaning to the term. Thus, Minerva Mills dealt with the validity of the constitutional amendment (Article 31‑C), while Sanjeev Coke dealt with the substantive scope of material resources of the community under Article 39(b).Checking relevance for Excel Glasses Ltd. and Others VS State of Kerala...
Checking relevance for Kanaka Durga Wines, Visakhapatnam VS Government Of A. P. ...
1995 0 Supreme(AP) 229 : In Minerva Mills Ltd. v. Union of India the Supreme Court held that Section 4 of the Constitution (Forty‑Second Amendment) Act, 1976 – which amended Article 31‑C – was unconstitutional, striking down the amendment that expanded the protective scope of Article 31‑C. In contrast, Sanjeev Coke Mfg. Co. v. Bharat Coking Coal Ltd. dealt with the Constitution (Twenty‑Fifth Amendment) Act, 1971, which protected laws enacted to give effect to clauses (b) and (c) of Article 39. The Court upheld the validity of that amendment and held the Coking Coal Mines (Nationalisation) Act, 1972 to be protected under Article 31‑C. The Sanjeev Coke judgment expressly noted it did not overrule Minerva Mills and was concerned only with the 25th amendment, not the 42nd amendment addressed in Minerva Mills.Checking relevance for BAPUJI EDUCATIONAL ASSOCN. VS STATE...
1984 0 Supreme(Kar) 202 : In Minerva Mills Ltd. v. Union of India (AIR 1980 SC 1789) the Supreme Court struck down the 42nd Constitution Amendment’s insertion in Art. 31‑C, holding that the amendment violated the basic structure of the Constitution. In Sanjeev Coke Mfg. Co. v. Bharat Coking Coal Ltd. (AIR 1983 SC 239) a Constitution Bench expressed doubt about the correctness of the Minerva Mills decision but expressly held that the Court remains bound by the Minerva Mills judgment, which continues to be good law. Thus, the jurisprudential difference is that Minerva Mills invalidated the amendment, whereas Sanjeev Coke did not overturn that ruling but merely questioned it, reaffirming the continued authority of Minerva Mills.
