State of Madras v. Champakam Dorairajan

Here, the court held that Directive Principles of State Policy must conform to and run as subsidiary to the Chapter of Fundamental Rights. The chapter on Fundamental Rights was sacrosanct, and DPSPs as in article 37 are expressly made unenforceable by a Court, hence, cannot override the provisions found in Part III which, notwithstanding other provisions, are expressly made enforceable by appropriate Writs, Orders or directions under article 32. DPSP can only be implemented as long as there is no infringement of Fundamental Rights under Part III, subject to limitations to legislative and executive powers provided under different parts of the Constitution. It was only in Minerva Mills case that a balance between Fundamental Rights and DPSP was sought.