Interrelationship between Directive Principles of State Policy and Fundamental Rights - An Insight

Here, in this article we have shared the inter-relationship between Directive Principles of State Policy and Fundamental Rights.

1. INTRODUCTION

The Indian Constitution or what we use to call the Constitution of India, adopted on 26(twenty-six) January 1950, is a comprehensive document/detailed document that state the framework or structure for the governance of the country. Our Constitution of India has chapters likes on Fundamental Rights or FRs(Part III) and another on the Directive Principles of State Policy or DPSPs(Part IV). Firstly, Fundamental Rights are “justiciable rights guaranteed to every citizen, protecting them from state infringement and ensuring individual liberties”. The Directive Principles of State Policy/(DPSP), on the other hand we can state that they are non-justiciable guidelines for the government, outlining the socio-economic objectives the state should strives to achieve to establish an ideal society based on justice – social, economic, and political. India's Constitution, which entered into effect on 26 jan 1950, is not just a law-it's the framework that governs the lives of over a billion people. It was designed to guarantee that all citizens, irrespective of their background, enjoy some elementary rights and liberties. They are referred to as Fundamental Rights, and they form part of Part III of the Constitution.

The Directive Principles of State Policy (DPSP) and also along with Fundamental Rights too represents two critical pillars of the Indian Constitution. While Fundamental Rights are justiciable and enforceable through courts the Directive Principles serves as guiding principles for governance. In other words or in simple terms, Directive Principles sets policy goals (aiming at social welfare, economic justice, etc.) but do not create individual legal rights; lets take Fundamental Rights on the another hand, create enforceable rights against the State. This dual scheme reflects the Constitution’s vision of a welfare-oriented republic: one that guarantees civil and political liberties while also aiming to secure social, economic, and cultural justice. Early Constituent Assembly debates and scholars (like Ambedkar and Granville Austin) emphasized that FR and DPSP together form the “conscience of the Constitution.” Thus, DPSPs complement fundamental rights by guiding legislation toward the ideal of a just society, even though only Fundamental Rights can be directly enforced.

This research project explores the complex evolving relationship between these two constitutional features, examining how constitutional amendments and judicial interpretations have shaped their interrelationship over time. The apparent tensions between non-justiciable Directive Principles and enforceable Fundamental Rights has been a subject of significant constitutional debates, with the Supreme Court playing a crucial role in harmonizing these seemingly conflicting provisions to uphold the basic structure of the Constitution.

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2. FUNDAMENTAL RIGHTS(FRs) AND DIRECTIVE PRINCIPLES(DPSPs): A CONCEPTUAL OVERVIEW

“The Constitution of India is a living document that balances the enforceable Fundamental Rights (which is in Part III) with the non-justiciable Directive Principles of State Policy (which fall in Part IV).” Fundamental Rights ensure individual liberty and equality, while Directive Principles guide the State toward socio-economic justice. “The interrelationship between these two pillars has been a subject of judicial and academic discourse, reflecting the Constitution’s attempt to harmonize individual freedoms with collective welfare.”

2.1 Understanding Fundamental Rights (Part III of the Constitution)

So, the Part III of the Constitution of India, available from Articles 12 to 35, is dedicated to Fundamental Rights, often described as the Magna Carta of India. “These rights represent the basic human freedoms which every Indian citizen/citizens is entitled to enjoy for a proper and harmonious development of personality. They are fundamental in the sense that they are essential/important for the all-round development of individuals and are guaranteed by the Constitution itself. Also, these rights are not absolute and are subject to reasonable restrictions as specified within the Constitution, which can be imposed by the state in the interest of public order, morality, decency, sovereignty and integrity of India, and security of the state, among other grounds. We see origins of Fundamental Rights in India may be traced back to the Indian independence struggle, when leaders continuously urged the inclusion of essential human rights in any future constitution setup”. Inspired from historical documents like England's Bill of Rights of the United States Bill of Rights and also of  France's Declaration of the Rights of Man, the framers of the Indian Constitution or what we call maker of indian constituion meticulously drafted these provisions. The Sapru Committee Report in 1945 had suggested two categories of individual rights: justiciable and non-justiciable, which eventually led to the separate codification of Fundamental Rights (justiciable) and Directive Principles of State Policy (non-justiciable).

A crucial aspect of Fundamental Rights is their justiciable nature. By stating that this means that if any of these rights are violated, the aggrieved individual can approach the High Courts (under Article 226) or the Supreme Court directly (under Article 32) for their enforcement. “Article 32 we know itself is a Fundamental Right –we know as the Right to Constitutional Remedies – and has been referred to by Dr. B.R. Ambedkar as the ‘very soul of the Constitution and the very heart of it.’ This power of judicial review ensures that legislative and executive actions conform to the rights guaranteed by the Constitution. Fundamental Rights primarily amd mainly aim to establish political democracy in the country by preventing the establishment of an authoritarian or dictatorial rule. They act as limitations on the powers of the legislature and the executive.  They are largely negative in character, as they prohibit the state from acting in certain ways, thereby protecting individual liberty from arbitrary encroachment by the state.” “The "State," for the purpose of Part III, is defined under Article 12 to includes the Government and Parliament of India, the Government and Legislatures of states, and all local or other authorities within the territory of India or under the control of the Government of India.”

The Fundamental Rights guaranteed under the Constitution are broadly classified into six categories: “Right to Equality (Articles 14-18): Here it includes equality before the law, prohibition of discrimination on grounds of religion, race, caste, sex, or place of birth, equality of opportunity in matters of public employment, abolition of untouchability, and abolition of titles. After that Right to Freedom (Articles 19-22): This were surrounded by freedom of speech and expression, assembly, association, movement, residence, and profession. Article 20 provides protection in respect of conviction for offenses, and Article 21 guarantees the right to life and personal liberty. Article 21A, introduced later, provides for the right to education. Article 22 offers protection against arbitrary arrest and detention. After that Right against Exploitation (Articles 23-24): This prohibits traffic in human beings, forced labor (begar), and employment of children in hazardous jobs. Now Right to Freedom of Religion (Articles 25-28): This includes freedom of conscience and free profession, practice, and propagation of religion, freedom to manage religious affairs, freedom from payment of taxes for promotion of any particular religion, and freedom from attending religious instruction or worship in certain educational institutions. After that Cultural and Educational Rights (Articles 29-30): These rights protect the interests of minorities by allowing them to conserve their distinct language, script, or culture, and grant them the right to establish and administer educational institutions of their choice. Lastly, Right to Constitutional Remedies (Article 32): This empowers citizens to move the Supreme Court for the enforcement of their Fundamental Rights.”

2.2. Understanding Directive Principles of State Policy (Part IV of the Constitution)

So, now lets talk about Part IV, of the Indian Constitution, starting from Articles 36  and goes to 51, enshrines the Directive Principles of State Policy/(DPSP). These principles is the guidelines or ideals that the State – encompassing the central and state governments, the Parliament and state legislatures, and all public authorities – should keep in mind while formulating policies and enacting laws. So, now coming to the concept of DPSPs. It is said that it was borrowed from the Irish Constitution of 1937, which in turn had taken it from the Spanish Constitution. Dr. B.R. “Ambedkar Ji described or mentioned these principles as a 'novel feature' of the Indian Constitution, emphasizing their significance in achieving the socio-economic transformation of the country. The core objective of the DPSPs is to establish social and economic democracy and to create conditions for a welfare state. They means DPSPs aim to realise/understand the high ideals of justice, liberty, equality, and fraternity as outlined in the Preamble to the Constitution. Fundamental Rights, which are mainly focused on ensuring political justice by protecting individual liberties against state action, DPSPs on the another side are positive obligations on the state to secure for all citizens a social order permeated with justice – social, economic, and political”. A key characteristic of DPSPs is their non-justiciable nature. Article 37 clearly saying that the provisions contained in Part IV ‘shall not be enforceable by any court.’ This means that individuals cannot sue the state for not implementing these principles or for enacting laws that are contrary to them. However, the same article also declares that these principles 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’.  So, while they lack legal enforceability in courts, they possess immense moral and political sanction. The ultimate accountability/responsibility for their implementation lies with the electorate, who can consider the government's performance in upholding these principles. Lastly, the DPSPs lay down the positive obligations of the state, guiding it towards building a society that ensures holistic well-being and justice for all its citizens, even if these directives are not directly enforceable in a court of law. They act as a moral compass for the state and a benchmark for the people to judge its performance.

3.  CONFLICTS AND BALANCING BETWEEN FUNDAMENTAL RIGHTS AND DPSP

Despite the judiciary's consistent efforts to harmonises Fundamental Rights and Directive Principles of State Policy, and the established principles that they are complementary, situations of apparent conflict or tension can and do arise. These conflicts typically emerge when the State, in its endeavor to implement a DPSP aimed at achieving socio-economic justice or promoting the welfare of the community, enacts a law or takes an executive action that is perceived to infringe upon an individual's Fundamental Right. The challenges then lies in balancing these competing interests within the constitutional framework.

3.1 Areas of Potential Conflict

Historically, and even in contemporary times, several areas have witnessed a clash or tension between the imperatives of DPSPs and the sanctity of Fundamental Rights:

Right to Property vs. Socio-Economic Reforms: “This was the most prominent area of conflict in the early decades of the Constitution. The original Article 31 guaranteed the Fundamental Right to Property, while DPSPs like Article 39(b) (equitable distribution of material resources) and Article 39(c) (prevention of concentration of wealth) called for agrarian reforms and nationalization of resources”). Similarly, numerous land reform legislations aimed at abolishing zamindari and redistributing land were challenged as violating Article 31 and Article 14 (Right to Equality, concerning compensation). “This led to several constitutional amendments (1st, 4th, 17th, 25th, 42nd, and 44th) to insulate such laws from judicial scrutiny or to modify the right to property itself. And also if we look the deletion of the Right to Property as a Fundamental Right by the 44th Amendment Act, 1978 (making it a legal/constitutional right under Article 300A)” significantly reduced the scope of this conflict, but issues regarding "public purpose" and "compensation" for acquisition of property can still arise.

Right to Equality (Article 14) vs. Protective Discrimination for Weaker Sections (Article 46): Article 46 of Constitution come in DPSP directs/command the State to “promotes the educational and economic interests of the weaker section of the peoples, particularly Scheduled Castes(SC) and Scheduled Tribes(ST) and protects them from social injustice and all forms of exploitation. Similarly, measures like reservations in educational institutions and public employment, enacted to implement Article 46, have often been challenged as violating the Right to Equality (Articles 14 and 15(1)) and Equality of Opportunity in Public Employment (Article 16(1))”. Also, the judiciary have largely uphelded such affirmative action policies by invoking the concept of "substantive equality" and by reading Article 15(4), 15(5), 16(4), 16(4A), and 16(4B) (which permit special provisions) as enabling clauses that give effect to the DPSP under Article 46, while ensuring they do not become disproportionate or lead to reverse discrimination.

Freedom of Trade, Occupation, and Business (Article 19(1)(g)) vs. State Regulation for Public Welfare: DPSPs like Article 47 (prohibition of intoxicating drinks and drugs injurious to health), Article 39(b) and (c), and principles aimed at environmental protection (Article 48A) often require the State to impose restrictions on certain trades or businesses. For example, laws imposing liquor prohibition or regulating polluting industries have been challenged as infringing Article 19(1)(g). The courts typically resolves such conflicts by examining whether the restrictions imposed are "reasonable" and in the "interest of the general public" as permitted by Article 19(6). The DPSPs often provide the rationale for considering such restrictions reasonable and in the public interest.

Uniform Civil Code (Article 44) vs. Right to Freedom of Religion (Articles 25-28): If we take the look at the Article 44 which directs the State to try to attempt to secure for the citizens a Uniform Civil Code (UCC) throughout the territory of India. “The aim is to replace diverse personal laws based on religion with a common set of laws governing matters like marriage, divorce, inheritance, and adoption. This has been a contentious issue, with arguments that a UCC might interfere with the freedom of religion, particularly the right to manage religious affairs and follows personal laws derived from religious texts,” as guaranteed under Articles 25 and 26. The Supreme Court, in several judgments like “Sarla Mudgal v. Union of India case (AIR 1995 SC 1531) and John Vallamattom v. Union of India case (AIR 2003 SC 2902)”, has highlighted the desirability of enacting a UCC but has left it to the legislature to take the initiative, recognizing the sensitive nature of the issue.

3.2 The Doctrine of Basic Structure and its Impact on Balancing

The doctrine of "Basic Structure," enunciated in the Kesavananda Bharati case, has become a pivotal tool for the judiciary in balancing Fundamental Rights and DPSPs.

It establishes that while Parliament has the power to amend the Constitution, including Fundamental Rights, to implement DPSPs, it cannot abrogate or destroy the basic features of the Constitution.

Crucially, the Supreme Court in Minerva Mills held that the harmony, goodwill and balance between Fundamental Rights and Directive Principles is itself an essential feature of the basic structure. This means that any amendment that gives absolute primacy to one over the other, or completely sacrifices one for the sake of the other, would be unconstitutional.

This doctrine allows the judiciary to scrutinize constitutional amendments that seek to implement Directive Principles of State Policy/DPSPs at the cost of Fundamental Rights, ensuring that such implementation does not lead to the erosion of core individual liberties or the democratic fabric of the nation.

3.3 Constitutional Amendments and their Role in Shaping the Relationship

Our Parliament has frequently resorted to constitutional amendments to navigate the conflicts and to empower the State to implement DPSPs more effectively.

First Amendment (1951) – Shortly after Champakam case, Parliament added entries to the Ninth Schedule to protect land reform laws that conflicted with FR. This was an early legislative move to implement DPSP goals (e.g. equitable land distribution) without infringing Article 31.

Article 31C: Introduced by the “25th Amendment Act, 1971, it initially protected laws giving effect to the policy of the State towards securing the principles specified in Article 39(b) or Article 39(c) from being challenged on the ground of contravention of Articles 14, 19, or 31. It also sought to oust judicial review of such laws. The Supreme Court in Kesavananda Bharati upheld the first part of Article 31C (the protection from Articles 14, 19, and 31) but struck down the second part (ousting judicial review) as violative of the basic structure”.

The 42nd Amendment Act, 1976, attempted to expand the scope of Article 31C to cover all DPSPs, giving them blanket supremacy over Articles 14, 19, and 31.The Supreme Court in Minerva Mills struck down this extension as unconstitutional, reiterating that the balance between Fundamental Rights and DPSPs is a basic feature.

Other amendments, such as those relating to reservations (if we take example of adding clauses to Articles 15 and 16) or the Right to Education (Article 21A), have directly aimed at translating specific DPSP/Directive Principles of State Policy ideals into enforceable rights or enabling provisions.

3.4 Judicial Approach to Balancing: Harmonious Construction and Reading Down

In adjudicating conflicts, the judiciary has employed various interpretive techniques:

Principle of Harmonious Construction: Courts attempt to interpret the provisions in a way that gives effect to both Fundamental Rights and DPSPs, avoiding a direct clash as far as possible.

Reading Down: If a statutory provision appears to violate a Fundamental Right while trying to implement a DPSP, courts may read down the provision to save its constitutionality by interpreting it narrowly.

DPSPs as Interpretive Guides: “Courts increasingly use DPSPs to understand the scope and content of Fundamental Rights. For instance, the ‘reasonableness of a restriction under Article 19 is often tested by examining whether it furthers a DPSP”.

In conclusion, the said relationship between Fundamental Rights and DPSPs is one of dynamic equilibrium. Conflicts is not seen as inherent contradictions but as challenges that require a nuanced balancing act. The goal are to ensure that the pursuit of the socio-economic objectives of DPSPs does not lead to an unacceptable erosion of individual liberties, and conversely, that the assertion of Fundamental Rights does not become an impediment to achieving a just and equitable social order. The judiciary continues to play a vital role as the ultimate arbiter in maintaining this delicate but crucial constitutional balance.

4. EVOLUTION OF THE RELATIONSHIP BETWEEN FRs AND DPSPs THROUGH JUDICIAL INTERPRETATIONS

The relationship between Fundamental Rights (FRs, written in Part III of constitution) and Directive Principles of State Policy (DPSPs, written in Part IV of constitution) of the Indian Constitution has never been static; on the contrary, it has undergone a radical change through a series of landmark judicial judgments and pronouncements.“This evolution reflect the judiciary's attempts to interpret the Constitution as a living document and to balance the individualistic assertion of Fundamental Rights with the socio-economic goals predicted in the Directive Principles. In the stating the courts adopted a stance or approch of strict legalism, giving primacy to the justiciable Fundamental Rights over the non-justiciable DPSPs. However, over time, there has been a perceptible shift towards a more harmonious and complementary construction of the two.”  

4.1 Initial Stance/approach: Supremacy of Fundamental Rights

In the early years of the Republic, the Supreme Court took the view that in case of any conflict between Fundamental Rights and DPSPs, the former would prevail due to their explicit enforceability in courts. “State of Madras v. Srimathi Champakam Dorairajan (AIR 1951 SC 226), This was the first major case where the our apex Supreme Court had to consider the interplay between Fundamental Rights/FRs and DPSPs”. “The Court held that Directive Principles, being non-justiciable, have to conform to and run as subsidiary to the Fundamental Rights. It held that Fundamental Rights were inviolable and could not be curtailed by any legislative or executive action taken to give effect to DPSPs. This decision resulted in the First Constitutional Amendment Act, 1951, which, among other provisions, added Clause (4) to Article 15 to allow the state to provide special provisions for the backward classes of a social or educational nature so as to give effect to the intention behind certain DPSPs.” 

4.2 Attempts at Reconciliation and the Rise of Harmonious Construction

While the initial judicial view gave clear precedence to Fundamental Rights, the judiciary soon began to recognize the importance of DPSPs as instruments of social and economic justice.

“In re Kerala Education Bill (AIR 1958 SC 956): In this advisory opinion, the Supreme Court, while affirming the primacy of Fundamental Rights, opined that the courts should adopt the principle of harmonious construction and try to attempt to gives effects to both as much as possible. It suggested that DPSPs though not-enforceable/non-enforceable, are fundamental in the governance of the country and therefore, the courts should not entirely ignore them.  

I.C. Golaknath v. State of Punjab (AIR 1967 SC 1643): In a significant ruling, the Supreme Court/ apex court held that Fundamental Rights were 'transcendental and immutable' and that Parliament had no power to amend any of the FRs or Fundamental Rights, even for the implementation of DPSPs. This created a constitutional deadlock making it difficult for the government to implement socio-economic reforms. To overcome this Parliament enacted the 24th Constitutional Amendment Act, 1971”, which affirmed or declare that the Parliament's power to amend any part of the Constitution, including Fundamental Rights.

4.3 The Doctrine of Basic Structure and the Bedrock of Balance

The most crucial/important phase in the evolution of this relationship came with the pronouncement of the "basic structure" doctrine and the subsequent emphasis on balance.

“Kesavananda Bharati v. State of Kerala (AIR 1973 SC 1461): This historic judgment by supreme court overruled the Golaknath decision. The Supreme Court held that Parliament has the power to amends any of provisions of the Constitution, including Fundamental Rights, but this power is not unlimited. It cannot alter the ‘basic structure’ or framework of the Constitution. While the Court did not explicitly place DPSPs on par/equal with Fundamental Rights, it recognized their significance and implicitly suggested that the goals enshrined in DPSPs are integral to the constitutional scheme. This case opened the door for a more balanced interpretation.

Minerva Mills Ltd. & Ors v. Union of India & Ors (AIR 1980 SC 1789): This case is a landmark in the jurisprudence of the interrelationship between Fundamental Rights and DPSPs. The Supreme Court abolished and struck down Sections 4 and 55 of the 42nd Constitutional Amendment Act, 1976. Section 4 had placed all DPSPs above Fundamental Rights granted by Articles 14, 19, and 31. The Court declared that the Indian Constitution rests on the "bedrock of the balance between Part III (Fundamental Rights) and Part IV (Directive Principles). To give it the absolute preference to one over the other would disturb the harmony(i.e amiability) of the Constitution, which is an essential feature of its basic structure”. The Court famously remarked that Fundamental Rights and DPSPs are ‘two wheels of a chariot’ and ‘that to destroy one is to destroy the other’. It asserted that harmony and balance between them is an essential feature of the basic structure of the Constitution.  

4.4 DPSP as a Tool for Interpreting Fundamental Rights

In the post-Minerva Mills era, the judiciary has increasingly used directive principle of state policy (DPSPs) as a tool to interpret and expand the scope of Fundamental Rights, particularly Article 21 (Right to Life and Personal Liberty).

“Unni Krishnan J.P. v. State of Andhra Pradesh (AIR 1993 SC 2178): The Supreme Court held that the Right to Education (up to the age of 14) is a Fundamental Right flowing from Article 21, read in conjunction with Article 45 (DPSP, as it then stood, urging the state to provide and offer for free and compulsory education for children). This judicial activism eventually led to the 86th Constitutional Amendment Act, 2002, which inserted Article 21A (Right to Education) as a Fundamental Right and modified Article 45.

Numerous other rights, such as the right to a healthy environment, right to livelihood, right to shelter, and right to health, have been read into Article 21 by the judiciary, drawing inspiration from various DPSPs. For instance, the principles in Article 39(e), Article 47, and Article 48A have been used to buttress the right to a clean and healthy environment as part of the right to life.”

Thus and lastly, the judicial journey reflects a maturation from a position of conflict and subordination to one of synthesis and complementarity. Whereas Fundamental Rights remains the primary individual safeguards, the Directive Principles are now viewed as crucial for understanding the content and spirit of those rights and for guiding the state towards achieving the constitutional vision of a just and equitable society. The current position is that there is no inherent conflict between the two; they complement each other, and the courts have to try their best to interpret them harmoniously.

5. SIGNIFICANCE AND CONTEMPORARY RELEVANCE OF THE INTERRELATIONSHIP

The interrelationship between Fundamental Rights and DPSPs is of profound, deep, great significance in India's constitutional democracy.

5.1. DPSP's Role in Achieving Socio-Economic Justice- So as per now we know DPSPs are the conscience of the Constitution/Indian Constitution and embody the aspirations of the Indian people for a society free from exploitation and inequality. They provides the blueprint for a welfare state. Many laws and government policies concerning land reforms, labor rights (e.g., Minimum Wages Act, Equal Remuneration Act), education (Right to Education Act), environmental protection (Wildlife Protection Act, Forest Conservation Act), and upliftment of weaker sections are manifestations of the state's commitment to implementing DPSPs. While non-justiciable, their political and moral sanction drives the state towards achieving these socio-economic goals.

5.2. Fundamental Rights as a Check on State Power in Implementing DPSP: While DPSPs guide state action, Fundamental Rights ensures that the state, in its promoting to achieves socio-economic objectives, does not trample upon individual liberties and due process. They act as a crucial check against arbitrary state power. The balance ensure that the pursuit of collective good does not lead to an authoritarian regime where individual rights are sacrificed. The principle of reasonable restrictions within Fundamental Rights allows for state intervention for public good, aligning with DPSP objectives, but subject to judicial scrutiny.

5.3. The Path Towards a Welfare State: The ultimate goal of the Indian Constitution is to establishs a welfare state based on justice, liberty, equality, and fraternity. This cannot be achieved by focusing on either Fundamental Rights or DPSPs in isolation. A harmonious and synthesised approach means combination of both is necessary. Fundamental Rights provides the necessary freedoms and protections for individuals to develops and participates in society, while DPSPs direct the state to create conditions where these rights can be meaningfully enjoyed by all sections of society, especially the marginalized and disadvantaged. The judiciary's evolving interpretation has increasingly emphasized this synthesis, viewing both Parts III and IV as complementary and supplementary to each other, forming the core of the Constitution.

CONCLUSION

The interrelationship between Directive Principles of State Policy(DPSP) and Fundamental Rights(FR) is a base and foundation of the Indian constitutional framework. It shows a unique attempt by the framers of the Constitution or what we call makers of Indian constitution to balances individual liberties with the imperative of socio-economic justice. At the very starting it appears as distinct. With Fundamental Rights holding a superior position due to their justiciability the relationship has evolved significantly mainly through judicial interpretation. The journey from the “Champakam Dorairajan case” which established the inferiority of DPSPs to Fundamental Rights, to the Kesavananda Bharati and Minerva Mills cases, which enshrined the doctrine of harmony and balance as a basic feature of the Constitution, demonstrates and displays a maturing of constitutional jurisprudence. Today it is widely accepted that “Fundamental Rights and DPSPs are not opposite of each other but are two sides of the same coin, working towards the common goal of a just and equitable society”. DPSPs provides the goals and vision for a welfare state while Fundamental Rights provides the means and safeguards to achieves them in a democratic manner.

While Directive Principles of State Policy/DPSPs remain non-justiciable in the traditional sense, their "fundamentalness" in the governance of the country have been increasingly recognized. The Indian Courts has used DPSPs as an interpretive tools to expand the perspective of Fundamental Rights, particularly Article 21. The implementation of various DPSPs through legislation stands as a testament to their importance in shaping state policy. 

The current legal position recognises the supremacy or domination of Fundamental Rights while allowing for reasonable restrictions to implement Directive Principles. This balanced approach acknowledges that individual rights and social welfare are interconnected and mutually reinforcing rather than inherently contradictory. 

The implementation of Directive Principles through legislation and government programs have made significant progress but faces ongoing challenges related to economic constraints and political priorities. The way forward requires a continued commitment to harmonizing rights and welfare within the constitutional framework.

At Last in conclusion, the interrelationship between Fundamental Rights and Directive Principles is not static but is a dynamic and evolving aspect of Indian constitutionalism. The commitment to achieving the ideals enshrined in both Parts of the Constitution is crucial for India's journey towards becoming a truly inclusive and developed welfare state. They both together form the soul of the Constitution, aiming to build an egalitarian society where every citizen can live a life of dignity and fulfillment.

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NEXT IAS, Directive Principles of State Policy (DPSPs): Meaning, Features & More, https://www.nextias.com/blog/directive-principles-of-state-policy-dpsps/