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Directive Principles of State Policy

Polity notes for UPSC CSE Prelims 2027 · Free

Last reviewed · Written and checked by the Prelims Lab faculty · About 35 min to read

Part IV, Articles 36–51: features, the principles article by article, later additions and the conflict with rights. Free notes for UPSC CSE Prelims 2027, written around the traps UPSC sets, with the exact text of the Constitution and every past question on the topic.

Directive Principles of State Policy in short
Nature and features
Directive Principles of State Policy (DPSP) are guidelines for the government. They tell the State what goals to work towards: a fair society, decent jobs, health, education, a clean environment.
The Directive Principles, article by article
Scholars group the Directive Principles into three types. This helps in remembering them.
Conflict with Fundamental Rights
What if a Fundamental Right and a Directive Principle clash? For example, a land reform law (a Directive) may take away someone's property (then a Right).

How to read: each section has The idea in brief (start here if the topic is new), Exam notes (the facts UPSC tests) and Ranker’s edge (the fine points). Each section opens with the bare text of the Constitution. Open In depth for the story behind it and past questions.

1. Nature and features

The bare text
Bare text · Article 36Constitution of India, as on 1 May 2024

36. Definition.—In this Part, unless the context otherwise requires, “the State” has the same meaning as in Part III.

Bare text · Article 37Constitution of India, as on 1 May 2024

37. Application of the principles contained in this Part.—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.

Reading the text

  • Article 37 makes three statements in one sentence, and UPSC tests each. The Directive Principles are not enforceable by any court. They are “nevertheless fundamental in the governance of the country”. And it is “the duty of the State to apply these principles in making laws”.
  • “In making laws”: the duty falls on the law-maker. A citizen cannot sue to force a law, but Parliament and the State legislatures are told to keep these goals in view.
  • Article 36: “the State” has the same meaning as in Article 12, so the Directives bind local bodies and other authorities too, not only governments.
The idea in brief

Directive Principles of State Policy (DPSP) are guidelines for the government. They tell the State what goals to work towards: a fair society, decent jobs, health, education, a clean environment. They are in Part IV (Articles 36 to 51).

The big difference from Fundamental Rights: you cannot go to court to force the government to follow a Directive Principle. But Article 37 says they are “fundamental in the governance” of the country, so the government must keep them in mind while making laws.

Think of it like thisFundamental Rights are like the brakes on a car: they stop the government from doing wrong. Directive Principles are like the GPS: they show where the government should go.
Exam notes
WherePart IV, Articles 36 to 51
SourceIrish Constitution (which took it from Spain). Similar to the “Instrument of Instructions” in the Government of India Act, 1935
Article 37Directive Principles are not enforceable by any court, but are “fundamental in the governance of the country”; the State has a duty to apply them in making laws (PYQ 2013, 2015, 2020)
PurposeTo establish social and economic democracy and a welfare State (PYQ 2002, 2015, 2020). Political democracy is set up by the Fundamental Rights
NaturePositive instructions to the State (do this), unlike most Fundamental Rights which are negative (do not do this). They are not legal limits on legislative or executive power (PYQ 2017)
“State”Same meaning as in Article 12: Centre, States, legislatures, local and other authorities
In detail: Ambedkar called them “novel features” of the Constitution. K.T. Shah called them “a cheque on a bank payable at the convenience of the bank”. Granville Austin called Parts III and IV together the “conscience of the Constitution”. Concentration of wealth is against Article 39(c), a Directive Principle (PYQ 2021).
Remember itRights are brakes, Directives are the GPS. Article 37 in two halves: not enforceable by courts, yet fundamental in governance. Rights build political democracy; Directives aim at social and economic democracy.
Beyond the basics · ranker’s edge
PointDepth
OriginsIrish Constitution (1937), which borrowed from Spain. Sapru Committee (1945) and B.N. Rau proposed splitting rights into justiciable and non-justiciable
ClassificationSocialist / Gandhian / Liberal-intellectual is a scholars’ grouping; the Constitution does not classify them
Courts using DPSPRead into Article 21: livelihood (Olga Tellis, 1985), education (Mohini Jain 1992, Unni Krishnan 1993), health (Paschim Banga Khet Mazdoor Samity, 1996). Randhir Singh (1982): equal pay for equal work enforceable via 14 and 16 read with 39(d)
Prelims trap: DPSPs are not legal limits on power, yet courts use them to judge the reasonableness of restrictions on rights. (PYQ 2017)
In depth: the story behind it and how UPSC asks it

The story behind it

The idea of splitting rights into two kinds, enforceable and non-enforceable, came to the Assembly through B.N. Rau and the Sapru Committee (1945), drawing on the Irish Constitution of 1937. The reason was money. A newly independent, poor country could promise a right to work or to public assistance, but could not yet deliver it everywhere. Making such promises enforceable would have flooded courts with cases the State could not satisfy.

Critics in the Assembly mocked the idea. K.T. Shah called the Directives “a cheque on a bank payable at the convenience of the bank”. Ambedkar’s reply was that their sanction is political, not judicial: any government that ignores them will answer to the voters. He compared them to the Instrument of Instructions issued to Governors under the 1935 Act, now addressed to the people’s own representatives.

How UPSC asks it

  1. UPSC 2021 Under the Indian Constitution, concentration of wealth violates:
    1. the Right to Equality
    2. the Directive Principles of State Policy
    3. the Right to Freedom
    4. the Concept of Welfare
    Show answer(b) the Directive Principles of State Policy. Article 39(c) directs the State to prevent concentration of wealth to the common detriment.
  2. UPSC 2020 Which part of the Constitution of India declares the ideal of a Welfare State?
    1. Directive Principles of State Policy
    2. Fundamental Rights
    3. Preamble
    4. Seventh Schedule
    Show answer(a) Directive Principles of State Policy. The Directive Principles set out the welfare State’s goals: livelihood, health, education, social security.
  3. UPSC 2020 With reference to the provisions contained in Part IV of the Constitution of India, which of the following statements is/are correct?
    1. They shall be enforceable by courts.
    2. They shall not be enforceable by any court.
    3. The principles laid down in this part are to influence the making of laws by the State.
    1. 1 only
    2. 2 only
    3. 1 and 3 only
    4. 2 and 3 only
    Show answer(d) 2 and 3 only. Article 37: not enforceable by any court, but the State must apply them in making laws.
  4. UPSC 2017 With reference to the Constitution of India, the Directive Principles of State Policy constitute limitations upon 1. legislative function 2. executive function
    1. 1 only
    2. 2 only
    3. Both 1 and 2
    4. Neither 1 nor 2
    Show answer(d) Neither 1 nor 2. They are instructions, not legal limitations; a law that ignores them is not invalid for that reason.
  5. UPSC 2015 Consider the following statements regarding the Directive Principles of State Policy:
    1. The Principles spell out the socio-economic democracy in the country.
    2. The provisions contained in these Principles are not enforceable by any court.
    1. 1 only
    2. 2 only
    3. Both 1 and 2
    4. Neither 1 nor 2
    Show answer(c) Both 1 and 2. They aim at social and economic democracy, and Article 37 makes them non-justiciable.
  6. UPSC 2015 The ideal of 'Welfare State' in the Indian Constitution is enshrined in its
    1. Preamble
    2. Directive Principles of State Policy
    3. Fundamental Rights
    4. Seventh Schedule
    Show answer(b) Directive Principles of State Policy. The Directive Principles lay down the welfare goals of the State.
  7. UPSC 2013 According to the Constitution of India, which of the following are fundamental for the governance of the country?
    1. Fundamental Rights
    2. Fundamental Duties
    3. Directive Principles of State Policy
    4. Fundamental Rights and Fundamental Duties
    Show answer(c) Directive Principles of State Policy. Article 37 calls the Directive Principles fundamental in the governance of the country.
  8. UPSC 2002 The purpose of the inclusion of Directive Principles of State Policy in the Indian Constitution is to establish:
    1. political democracy
    2. social democracy
    3. Gandhian democracy
    4. social and economic democracy
    Show answer(d) social and economic democracy. They aim at social and economic democracy; Fundamental Rights secure political democracy.

2. The Directive Principles, article by article

The bare text
Bare text · Article 38Constitution of India, as on 1 May 2024

38. State to secure a social order for the promotion of welfare of the people.—[(1)] The State shall strive to promote the welfare of the people by securing and protecting as effectively as it may a social order in which justice, social, economic and political, shall inform all the institutions of the national life.

[(2) The State shall, in particular, strive to minimise the inequalities in income, and endeavour to eliminate inequalities in status, facilities and opportunities, not only amongst individuals but also amongst groups of people residing in different areas or engaged in different vocations.]

Amended by: 44th (1978) Amendment
Bare text · Article 39Constitution of India, as on 1 May 2024

39. Certain principles of policy to be followed by the State.—The State shall, in particular, direct its policy towards securing—

(a) that the citizens, men and women equally, have the right to an adequate means of livelihood;

(b) that the ownership and control of the material resources of the community are so distributed as best to subserve the common good;

(c) that the operation of the economic system does not result in the concentration of wealth and means of production to the common detriment;

(d) that there is equal pay for equal work for both men and women;

(e) that the health and strength of workers, men and women, and the tender age of children are not abused and that citizens are not forced by economic necessity to enter avocations unsuited to their age or strength;

[(f) that children are given opportunities and facilities to develop in a healthy manner and in conditions of freedom and dignity and that childhood and youth are protected against exploitation and against moral and material abandonment.]

Amended by: 42nd (1976) Amendment
Bare text · Article 41Constitution of India, as on 1 May 2024

41. Right to work, to education and to public assistance in certain cases.—The State shall, within the limits of its economic capacity and development, make effective provision for securing the right to work, to education and to public assistance in cases of unemployment, old age, sickness and disablement, and in other cases of undeserved want.

Bare text · Article 44Constitution of India, as on 1 May 2024

44. Uniform civil code for the citizens.—The State shall endeavour to secure for the citizens a uniform civil code throughout the territory of India.

Reading the text

  • The verbs are soft on purpose: “shall strive”, “shall endeavour”, “shall … direct its policy”. Compare Part III, where the State “shall not” act.
  • Article 41 has a built-in limit: “within the limits of its economic capacity and development”. The right to work is a goal to be reached as the economy allows.
  • Article 39(b) and (c) are the most litigated Directive Principles: distributing “material resources of the community” for the common good, and preventing “concentration of wealth”. UPSC’s 2021 question on concentration of wealth points straight to 39(c).
  • Article 44 says “for the citizens” and “throughout the territory of India”: a single civil code for all citizens, regardless of religion.
The idea in brief

Scholars group the Directive Principles into three types. This helps in remembering them.

Memory hook for Gandhian ones“Panchayat, Khadi, Co-op, Weaker sections, No liquor, Cow.” (40, 43, 43B, 46, 47, 48)
Exam notes
ArticleThe State shall…Group
38Promote welfare through a just social order (social, economic, political justice); minimise inequalities in income, status, facilities (38(2), added 1978)Socialist
39Secure: livelihood for all; distribution of resources for the common good; prevent concentration of wealth; equal pay for equal work for men and women; protect workers and children; (f) opportunities for children (1976)Socialist
39AEqual justice and free legal aid (1976)Socialist
40Organise village panchayatsGandhian
41Right to work, education and public assistance in unemployment, old age, sickness, disablementSocialist
42Just and humane conditions of work and maternity reliefSocialist
43Living wage, decent standard of life, leisure and cultural opportunities for workers; promote cottage industries in rural areasSocialist; cottage industries Gandhian
43AWorkers’ participation in management of industries (1976)Socialist
43BPromote cooperative societies (97th Amendment, 2011)Gandhian
44Uniform Civil Code throughout the territory of IndiaLiberal
45Early childhood care and education for all children until age six (since 2002; originally free education till 14)Liberal
46Educational and economic interests of SCs, STs and weaker sectionsGandhian
47Raise nutrition and public health; prohibition of intoxicating drinks and harmful drugs except for medicinal use (PYQ 2008)Gandhian
48Organise agriculture and animal husbandry on modern lines; preserve breeds, prohibit cow slaughterGandhian / Liberal
48AProtect environment, forests and wildlife (1976)Liberal
49Protect monuments of national importanceLiberal
50Separate the judiciary from the executive in public services (PYQ 2020, 2025)Liberal
51Promote international peace and security; respect international law; settle disputes by arbitration (PYQ 2002, 2014)Liberal
In detail, the Gandhian list: 40 (panchayats), 43 (cottage industries), 43B (cooperatives), 46 (weaker sections), 47 (prohibition), 48 (cow slaughter) (PYQ 2012). The Uniform Civil Code (44) and leisure for workers (43) are not Gandhian.
Prelims trap: Prohibition of traffic in human beings and forced labour is a Fundamental Right (Article 23), not a Directive Principle (PYQ 2008). Equal pay for equal work is in the Constitution, in Article 39(d) (PYQ 2006). “Backward classes” is not defined in the Constitution.
Remember itGandhian six: Panchayat (40), Khadi (43), Co-op (43B), Weaker sections (46), No liquor (47), Cow (48). Anything about UCC, environment, monuments, judiciary or world peace (44, 48A, 49, 50, 51) is liberal-intellectual.
Beyond the basics · ranker’s edge
ArticleDepth
39(b) and (c)The only DPSPs protected by Article 31C (as upheld in Kesavananda)
44 UCCUrged in Shah Bano (1985), Sarla Mudgal (1995), John Vallamattom (2003). 21st Law Commission (2018): “neither necessary nor desirable at this stage”; 22nd Law Commission invited views (2023). Uttarakhand UCC in force 27 January 2025; Gujarat set up a drafting committee in 2025
48Cow slaughter bans upheld in Mirzapur Moti Kureshi (2005), which also covered progeny of cows
51Promote international peace, honourable relations, respect for treaties, arbitration. Basis of Panchsheel and non-alignment arguments
Prelims trap: Gandhian list: 40, 43 (cottage), 43B, 46, 47, 48.
In depth: the story behind it and how UPSC asks it

The story behind it

What is a “material resource of the community”? For decades, Justice Krishna Iyer’s view (1977) held sway: every private resource, including private property, could count. In Property Owners Association (5 November 2024), nine judges took a narrower view, 8:1. Not all private property is a material resource of the community; only resources with community character, judged case by case on factors such as their nature, scarcity and effect on the public, qualify.

The Uniform Civil Code stayed a Directive for seven decades because personal law is tied to religious identity. Goa has long had a common civil code inherited from Portuguese rule. In 2024 Uttarakhand passed the first such law by a State after independence; it came into force in January 2025. Courts have repeatedly reminded the Union of Article 44, for example in Shah Bano (1985) and Sarla Mudgal (1995).

How UPSC asks it

  1. UPSC 2025 Consider the following pairs (Provision in the Constitution of India – Stated under): I. Separation of Judiciary from the Executive in the public services of the State – The Directive Principles of State Policy II. Valuing and preserving the rich heritage of our composite culture – The Fundamental Duties III. Prohibition of employment of children below the age of 14 years in factories – The Fundamental Rights. How many of the above pairs are correctly matched?
    1. Only one
    2. Only two
    3. All the three
    4. None
    Show answer(c) All the three. Article 50 (DPSP), Article 51A(f) (Duty) and Article 24 (Fundamental Right): all three are correct.
  2. UPSC 2020 In India, separation of judiciary from the executive is enjoined by
    1. the Preamble of the Constitution
    2. a Directive Principle of State Policy
    3. the Seventh Schedule
    4. the conventional practice
    Show answer(b) a Directive Principle of State Policy. Article 50, a Directive Principle.
  3. UPSC 2014 In the Constitution of India, promotion of international peace and security is included in the
    1. Preamble to the Constitution
    2. Directive Principles of State Policy
    3. Fundamental Duties
    4. Ninth Schedule
    Show answer(b) Directive Principles of State Policy. Article 51.
  4. UPSC 2012 Consider the following provisions under the Directive Principles of State Policy:
    1. Securing for citizens of India a uniform civil code
    2. Organizing village Panchayats
    3. Promoting cottage industries in rural areas
    4. Securing for all the workers reasonable leisure and cultural opportunities.
    Which of the above are the Gandhian Principles that are reflected in the Directive Principles of State Policy?
    1. 1, 2 and 4 only
    2. 2 and 3 only
    3. 1, 3 and 4 only
    4. 1, 2, 3 and 4
    Show answer(b) 2 and 3 only. Village panchayats (40) and cottage industries (43) are Gandhian. The UCC is liberal; leisure for workers is socialist.
  5. UPSC 2008 Which of the following is/are included in the Directive Principles of State Policy?
    1. Prohibition of traffic in human beings and forced labour
    2. Prohibition of consumption except for medicinal purposes of intoxicating drinks and of other drugs which are injurious to health
    1. 1 only
    2. 2 only
    3. Both 1 and 2
    4. Neither 1 nor 2
    Show answer(b) 2 only. 1 is a Fundamental Right (Article 23). 2 is Article 47.
  6. UPSC 2006 Consider the following statements:
    1. There is no provision in the Constitution of India to encourage equal pay for equal work for both men and women.
    2. The Constitution of India does not define backward classes.
    1. 1 only
    2. 2 only
    3. Both 1 and 2
    4. Neither 1 nor 2
    Show answer(b) 2 only. Article 39(d) provides equal pay for equal work. ‘Backward classes’ is not defined.
  7. UPSC 2002 Which one of the following Articles of the Directive Principles of State Policy deals with the promotion of international peace and security?
    1. 51
    2. 48 A
    3. 43 A
    4. 41
    Show answer(a) 51. Article 51.

3. Directive Principles added later

The bare text
Bare text · Article 39AConstitution of India, as on 1 May 2024

[39A. Equal justice and free legal aid.—The State shall secure that the operation of the legal system promotes justice, on a basis of equal opportunity, and shall, in particular, provide free legal aid, by suitable legislation or schemes or in any other way, to ensure that opportunities for securing justice are not denied to any citizen by reason of economic or other disabilities.]

Bare text · Article 43BConstitution of India, as on 1 May 2024

[43B. Promotion of co-operative societies.—The State shall endeavour to promote voluntary formation, autonomous functioning, democratic control and professional management of co-operative societies.]

Amended by: 97th (2011) Amendment
Bare text · Article 45Constitution of India, as on 1 May 2024

[45. Provision for early childhood care and education to children below the age of six years.—The State shall endeavour to provide early childhood care and education for all children until they complete the age of six years.]

Amended by: 86th (2002) Amendment
Bare text · Article 48AConstitution of India, as on 1 May 2024

[48A. Protection and improvement of environment and safeguarding of forests and wild life.—The State shall endeavour to protect and improve the environment and to safeguard the forests and wild life of the country.]

Amended by: 42nd (1976) Amendment

Reading the text

  • Article 45 changed its meaning in 2002. Originally it asked the State to provide free and compulsory education for all children up to fourteen within ten years. The 86th Amendment moved that promise into Part III as the right in Article 21A, and rewrote Article 45 to cover early childhood care until age six. UPSC’s 2006 question tests this switch.
  • Each added Article carries its amendment: 39(f), 39A, 43A and 48A came with the 42nd Amendment (1976); 38(2) with the 44th (1978); the new 45 with the 86th (2002); 43B with the 97th (2011).
The idea in brief

Some Directive Principles were added later:

Exam notes
AmendmentAdded or changed
42nd, 1976Four new: 39(f) healthy development of children; 39A free legal aid; 43A workers in management (PYQ 2017); 48A environment
44th, 197838(2): minimise inequalities in income, status, facilities and opportunities
86th, 2002Article 45 changed to early childhood care up to six; free and compulsory education for 6–14 made a Fundamental Right (21A) and a parent’s duty (51A(k)) (PYQ 2006)
97th, 201143B cooperative societies
In detail: The 42nd Amendment (1976) also moved education from the State List to the Concurrent List (PYQ 2006), along with forests, weights and measures, wild animals and administration of justice.
Remember it1976 gave four, 1978 one, 2002 rewrote one, 2011 one: 42nd → 39(f), 39A, 43A, 48A; 44th → 38(2); 86th → new 45; 97th → 43B.
Beyond the basics · ranker’s edge
PointDepth
42nd (1976) listAlso moved education, forests, wild animals and birds, weights and measures, administration of justice to the Concurrent List
86th (2002) triad21A (right), 45 (ECCE under 6), 51A(k) (parent’s duty) — three changes in one amendment
97th (2011)43B, plus “co-operative societies” in 19(1)(c) and Part IXB
Prelims trap: 38(2) came by the 44th, not the 42nd. 43A (workers in management) is a 42nd addition. (PYQ 2017)
In depth: the story behind it and how UPSC asks it

The story behind it

The 1976 additions show the Emergency government’s social agenda: legal aid, workers in management, environment and child welfare. Unlike many other 42nd Amendment changes, the Janata government kept them in 1978, and even added one of its own: Article 38(2) on reducing inequalities of income, status and opportunity.

How UPSC asks it

  1. UPSC 2017 Which principle among the following was added to the Directive Principles of State Policy by the 42nd Amendment to the Constitution?
    1. Equal pay for equal work for both men and women
    2. Participation of workers in the management of industries
    3. Right to work, education and public assistance
    4. Securing living wage and human conditions of work to workers
    Show answer(b) Participation of workers in the management of industries. Article 43A. The other three were in the original Constitution.
  2. UPSC 2006 Consider the following statements:
    1. Free and compulsory education to the children of 6-14 years age-group by the State by the seventy-sixth Amendment to the Constitution of India.
    2. Sarva Shiksha Abhiyan seeks to provide computer education even in rural areas.
    3. Education was included in the Concurrent List by the Forty-second Amendment, 1976 to the Constitution of India.
    1. 1, 2 and 3
    2. 1 and 2
    3. 2 and 3
    4. 1 and 3
    Show answer(c) 2 and 3. The right to education came through the 86th Amendment (2002), not the 76th. 2 and 3 are correct.

4. Conflict with Fundamental Rights

The bare text
Bare text · Article 31CConstitution of India, as on 1 May 2024

[31C. Saving of laws giving effect to certain directive principles.— Notwithstanding anything contained in article 13, no law giving effect to the policy of the State towards securing [all or any of the principles laid down in Part IV] shall be deemed to be void on the ground that it is inconsistent with, or takes away or abridges any of the rights conferred by [article 14 or article 19;] [and no law containing a declaration that it is for giving effect to such policy shall be called in question in any court on the ground that it does not give effect to such policy]:

Provided that where such law is made by the Legislature of a State, the provisions of this article shall not apply thereto unless such law, having been reserved for the consideration of the President, has received his assent.]

Amended by: 25th (1971), 42nd (1976), 44th (1978) Amendments
Subs. by the Constitution (Forty-second Amendment) Act, 1976, s. 4, for “the principles specified in clause (b) or clause (c) of article 39” (w.e.f. 3-1-1977). Section 4 has been declared invalid by the Supreme Court in Minerva Mills Ltd. and Others Vs Union of India and Others, AIR 1980 SC 1789.The words in italics struck down by the Supreme Court in Kesavananda Bharati vs. State of Kerala, AIR 1973, SC 1461.

Reading the text

  • Article 31C protects laws that give effect to Article 39(b) or (c) from challenge under Articles 14 and 19. It is the main bridge between Part IV and Part III.
  • The footnotes in the official text tell its history. The 42nd Amendment’s wider version, covering “all or any of the principles laid down in Part IV”, was declared invalid in Minerva Mills (1980). The italicised words that barred courts from questioning such laws were struck down in Kesavananda Bharati (1973).
The idea in brief

What if a Fundamental Right and a Directive Principle clash? For example, a land reform law (a Directive) may take away someone’s property (then a Right).

Exam notes
Case / amendmentOutcome
Champakam Dorairajan (1951)If a Directive Principle conflicts with a Fundamental Right, the Right prevails; Directive Principles are subsidiary
Golaknath (1967)Parliament cannot amend Fundamental Rights even to implement Directive Principles
24th and 25th Amendments (1971)Parliament can amend any part; new Article 31C: laws for Articles 39(b) and (c) cannot be challenged under Articles 14 and 19
Kesavananda Bharati (1973)Upheld the first part of 31C; struck down the part that barred courts from checking whether the law really implements 39(b) and (c)
42nd Amendment (1976)Extended 31C protection to laws for any Directive Principle
Minerva Mills (1980)Struck down that extension. The Constitution rests on the balance and harmony between Parts III and IV; that balance is part of the basic structure
In detail, 2024: In Property Owners Association v. State of Maharashtra (Nov 2024), a nine-judge Bench held by majority that not every private property is a “material resource of the community” under Article 39(b).
Remember itRights first → amend for Directives → limit → balance: Champakam 1951, 24th/25th Amendments 1971, Kesavananda 1973, Minerva Mills 1980 (balance of Parts III and IV is basic structure).
Beyond the basics · ranker’s edge
CaseDepth
Waman Rao (1981)Upheld unamended Article 31C as basic-structure compliant
Sanjeev Coke (1983)Followed Justice Krishna Iyer’s minority view (Ranganath Reddy, 1977) that private resources are “material resources of the community”
Property Owners Association (Nov 2024)Nine judges: not every private resource is a community resource; tests include nature of resource, scarcity, impact on community, concentration in private hands. Overruled the Krishna Iyer line. Held that 31C as it stood before the 42nd Amendment survives
Prelims trap: Minerva Mills struck down only the 42nd Amendment’s extension of 31C to all DPSPs, not 31C itself.
In depth: the story behind it and how UPSC asks it

The story behind it: the conflict in five steps

  1. Champakam Dorairajan (1951): the Court held that Directive Principles must run subordinate to Fundamental Rights.
  2. 25th Amendment (1971): Parliament added Article 31C to protect laws on 39(b) and (c).
  3. Kesavananda Bharati (1973): the first part of Article 31C was upheld, but the clause barring judicial review was struck down.
  4. 42nd Amendment (1976): extended 31C to all Directive Principles. Minerva Mills (1980) struck that extension down, holding that harmony and balance between Parts III and IV is itself a basic feature.
  5. Property Owners Association (2024): the nine judges held unanimously that the original Article 31C, as upheld in Kesavananda, still stands.

5. How the Directive Principles have been implemented

The idea in brief

Even though courts cannot enforce them, governments have passed many laws to follow the Directive Principles:

Exam notes
DirectiveLaw or scheme
39A legal aidLegal Services Authorities Act, 1987 (NALSA): free legal services to SCs/STs, women, children, persons with disability, people in custody and those below an income limit (e.g., transgender persons with income under ₹2 lakh) (PYQ 2020)
40 panchayats73rd Amendment, 1992
41 right to work, public assistanceMGNREGA, 2005 (100 days), replaced from 1 July 2026 by the Viksit Bharat–Guarantee for Rozgar and Ajeevika Mission (Gramin) Act, 2025 (VB-G RAM G: 125 days a year, 60:40 Centre–State funding); National Social Assistance Programme (pensions) (PYQ 2010)
43 wages, cottage industriesMinimum Wages Act, 1948; KVIC; labour codes
44 Uniform Civil CodeGoa has a common civil code; Uttarakhand passed a UCC law in 2024, in force from January 2025
48A environmentWildlife (Protection) Act, 1972; Forest (Conservation) Act, 1980; Environment Protection Act, 1986
50 separation of judiciaryCriminal Procedure Code, 1973 separated judicial magistrates from the executive (the BNSS, 2023 replaced the CrPC from 1 July 2024)
In detail, Directives outside Part IV: Article 335 (claims of SCs/STs to services), Article 350A (instruction in the mother tongue at the primary stage) (PYQ 2001), Article 351 (development of Hindi). Education also links to the Fifth, Sixth and Seventh Schedules and to local bodies (PYQ 2012).
Law / schemeDirective it serves
Equal Remuneration Act, 1976 (now Code on Wages)Article 39(d) equal pay
Maternity Benefit Act, 1961 (26 weeks since 2017)Article 42
Minimum Wages Act / Code on Wages, 2019Article 43 living wage
MGNREGA, 2005 → VB-G RAM G Act, 2025Article 41 right to work
NFSA 2013, PM POSHAN, ICDSArticle 47 nutrition
Wild Life Act 1972, Forest (Conservation) Act 1980Article 48A
Ancient Monuments Act, 1958Article 49
CrPC, 1973Article 50 separation of judiciary
Cow slaughter laws (upheld in Mirzapur Moti Kureshi, 2005)Article 48
Remember itPair each Directive with one law: 39A–NALSA, 40–73rd Amendment, 41–MGNREGA→VB-G RAM G, 42–Maternity Benefit, 44–Goa and Uttarakhand UCC, 47–NFSA, 48A–Wildlife Act, 50–CrPC 1973.
Beyond the basics · ranker’s edge
DirectiveDepth
39ANALSA (1995 in operation); Lok Adalats get statutory status under the same Act.
42Maternity Benefit (Amendment) Act, 2017: 26 weeks; now part of the Code on Social Security, 2020
43Four labour codes (wages, industrial relations, social security, occupational safety) notified in force from 21 November 2025
47Total prohibition in Gujarat, Bihar, Mizoram, Nagaland and Lakshadweep
In depth: the story behind it and how UPSC asks it

The story behind it: how the goals became laws

Most Directive Principles are now carried out by statutes. That is how a non-justiciable goal turns into an enforceable right.

ArticleLaw that carries it out
39ALegal Services Authorities Act, 1987: free legal aid through NALSA and State and district authorities, for women, children, SC/ST, persons with disability, industrial workers and people below an income limit (UPSC 2020)
39(d), 42, 43Equal Remuneration Act, 1976 and Maternity Benefit Act, 1961; minimum wages and equal pay are now part of the Code on Wages, 2019
4073rd Amendment (1992): Panchayati Raj became a constitutional institution
45, 21ARight of Children to Free and Compulsory Education Act, 2009
48AWildlife (Protection) Act, 1972; Environment (Protection) Act, 1986
50Code of Criminal Procedure, 1973 separated judicial magistrates from the executive (now the BNSS, 2023)

Courts have also read Directive Principles into Fundamental Rights. Equal pay for equal work, from Article 39(d), was made enforceable through Articles 14 and 16 (Randhir Singh, 1982). Education, health and livelihood were read into Article 21.

How UPSC asks it

  1. UPSC 2020 In India, Legal Services Authorities provide free legal services to which of the following types of citizens?
    1. Person with an annual income of less than Rs. 1,00,000
    2. Transgender with an annual income of less than Rs. 2,00,000
    3. Member of Other Backward Classes (OBC) with an annual income of less than Rs. 3,00,000
    4. All Senior Citizens
    1. 1 and 2 only
    2. 3 and 4 only
    3. 2 and 3 only
    4. 1 and 4 only
    Show answer(a) 1 and 2 only. The Legal Services Authorities Act covers persons below the notified income limit and certain groups; transgender persons up to ₹2 lakh income were included. OBC status or age alone does not qualify.
  2. UPSC 2012 Which of the following provisions of the Constitution of India have a bearing on Education?
    1. Directive Principles of State Policy
    2. Rural and Urban Local Bodies
    3. Fifth Schedule
    4. Sixth Schedule
    5. Seventh Schedule
    1. 1 and 2 only
    2. 3, 4 and 5 only
    3. 1, 2 and 5 only
    4. 1, 2, 3, 4 and 5
    Show answer(d) 1, 2, 3, 4 and 5. All have links: Articles 45, 46; Eleventh and Twelfth Schedule subjects; tribal administration under the Fifth and Sixth Schedules; education in the Concurrent List.
  3. UPSC 2010 With reference to the Constitution of India, consider the following:
    1. Fundamental Rights
    2. Fundamental Duties
    3. Directive Principles of State Policy.
    Which of the above provisions of the Constitution of India is/are fulfilled by the National Social Assistance Programme launched by the Government of India?
    1. 1 only
    2. 3 only
    3. 1 and 3 only
    4. 1, 2 and 3
    Show answer(b) 3 only. NSAP gives public assistance in old age, widowhood and disability: Article 41, a Directive Principle.
  4. UPSC 2001 Which Article of the Constitution provides that it shall be the endeavour of every state to provide adequate facility for instruction in the mother tongue at the primary stage of education?
    1. Article 349
    2. Article 350
    3. Article 350-A
    4. Article 351
    Show answer(c) Article 350-A. Article 350A (added in 1956). 351 is about developing Hindi.

6. Quick revision and traps

Exam notes
36–51Part IV Articles; Article 37 = non-justiciable but fundamental in governance
39A, 43A, 48A, 39(f)Added in 1976
43BCooperatives, 2011
Welfare StateIdeal declared in the Directive Principles (PYQ 2015, 2020)
DPSPs outside Part IVArticle 335 (SC/ST claims in services), 350A (mother tongue), 351 (Hindi)
Added by 42nd / 44th / 86th / 97th39(f), 39A, 43A, 48A / 38(2) / new 45 / 43B
Beyond the basics · ranker’s edge
PYQ patternHow to prepare
Is X a DPSP or an FR?Make a two-column list of look-alikes: 23 vs 39(e)–(f); 21A vs 45; 17 vs 46