Rights,
directive principles, duties: what is fundamental?
ROHINTON FALI NARIMAN
WHEN this country was declared independent
in 1947, it had a mammoth task before it, a formidable task of drawing up a
Constitution which would serve its people and replace the English Government of
India Act of 1935. That task was performed in a whirlwind three years – a
little less than three years as a matter of fact, and the Preamble to this new
document made it clear that there was going to be a completely fresh start. In
ringing words, it begins with ‘We the People’. So, therefore, first and
foremost, British rule was replaced by Peoples’ rule. The Preamble stated that
we were Sovereign, our own sovereign, having thrown off the British yoke, and
we believed in the democratic way forward, which meant we would govern
ourselves within the framework of a republican form of government as opposed to
the antithetical, monarchical type.
We are a Sovereign Democratic Republic. We
elect our representatives, who rule us. Two words, ‘socialist’ and ‘secular’,
were rejected in 1947 and then in 1950 but were introduced in 1976. As a
matter of fact, K.T. Shah and one other member did their best to try and
include the words ‘socialist’ and ‘secular’. Dr Ambedkar,
who piloted the Constitution, in a sense, felt that these two words were
unnecessary because they were already reflected. The Directive Principles of
State Policy made it clear that we were going the socialist way and there were
many provisions that made it clear we were secular.
The road map was set. There will now be for
‘We the People’, justice, socio-economic and political. Political justice was
established immediately by a stroke of the pen. Article 326 of the Constitution
declared that in place of the few voters in the provinces in the days of
British rule, there would now be universal adult franchise. At that point the
voting age was 21 years which we have now changed to people being eligible to
vote at 18 years of age. Social and economic justice had a very long way to go,
for which we borrowed heavily from the Irish Constitution, which incidentally
was a Roman Catholic Constitution, that opens with the words, ‘... we are
devotees of the Trinity and then of our Lord Jesus Christ.’
Interestingly, after justice, come the
three words which are the cri de cœur of the
French Revolution: liberty, equality, and fraternity. Liberty was to be of
thought, expression, faith, belief, worship; equality was to be of both status
and opportunity. These three words were in Part III of the Fundamental Rights
chapter of the Indian Constitution, and above all, fraternity was in the
forefront implying that it was fundamental to both the dignity of the
individual and more important, it was basic to unity. Later, the phrase,
integrity of the nation, was added.
The Preamble states categorically that it
was a huge break from the past. For the first time we had recognized
fundamental rights, and
we had Directive Principles of State Policy. Fundamental rights can be traced
back to Anglo-Saxon jurispru-dence, to the Magna Carta itself, which is a document drafted in 1215, which
was wrested by the Barons from King John, one of the wickedest kings that
England was ruled by. What survives even today are Clauses 39 and 40, by a
Statute of Westminster of 1297. We are primarily concerned with Clause 39,
which says that no man shall be tried, except by his peers and under the law of
the land. The Rule of Law therefore, as we know, can be traced back to Clause
39 of the Magna Carta.
To
summarize there would now be no executive fiat, no arbitrariness of the king,
but instead, the law of the land would govern us. It took many centuries for
Parliament to mature as an institution and become a rival to the King in
England. In 1689, when England had its Glorious Revolution, glorious because
not even one shot was fired to expel James II. His son-in-law and his daughter
eventually ruled as William III and Mary II. During their reign Parliament
introduced a Bill of Rights in 1689. That Bill of Rights primarily pitted Parliament
against the King. You remember, Magna Carta was baron against the king. Parliamentarians were
given the right to free speech, and above all, excessive bails and fines; cruel
and unusual punishment were outlawed.
One hundred years on two documents of seminal
importance appear: first, the U.S. Constitution of 1789, and second, the
Declaration of the Rights of Man which was born out of the French Revolution.
Most of our fundamental rights, as we know them, have some place in this Bill
of Rights which was added by an amendment – the First Amendment. It was not
part of the original Constitution of the United States of America. These rights
are pretty much the rights that we recognize today, and they are rights no
longer of parliament against King, but of the citizen against parliament, as it
were – parliamentary law, and the executive. These are the mammoth leaps that
we have taken through the centuries, starting with the noblemen against king,
then parliament against the king, and now citizen against parliament.
The
Declaration of the Rights of Man was equally important in that it stated these
rights were natural rights which inhere in us because we are human. Something
very important as this was only picked up by our courts in as late as 2017, to
finally declare that yes, these are natural rights and rights which inhere in
us, that they are not something to be taken for granted. In 1948, came the
United Nations declaration, a result of the most horrible world war that took
place between 53 nations, and post that world war, thanks largely to Eleanor
Roosevelt, a declaration of fundamental freedoms as we know them to be today,
was bestowed on us. Interestingly, the very first fundamental freedom is
fraternity because they realized, as Beethoven did in the last movement of his
Ninth Symphony, that until men become brothers there
can never be world peace. So, the single most important thing which world peace
requires is fraternity, and therefore, you find it as the very first right
human right in the U.N. declaration.
Apart from this, there are other rights
such as the right to privacy, right to leisure, and most importantly, the
fundamental right to see that all these rights are not declared only in name,
but come down to the people and are justiciable by courts which are
independent. All these concepts are framed in what is now called Part III of
our Constitution. Part III begins with Article 12 to remind us that fundamental
rights in essence are the rights of the citizen against the state, and the
state is defined very widely because the state would include legislative
activity, executive activity, local authority activity, and all other authority
activity under the rule of government. Therefore, the moment a citizen
petitions a court, a superior court, and claims that his fundamental right has
been infringed, the state becomes the respondent, has to answer, and if it has
no answer, the citizen trumps the state.
This is
extremely important because you then have the wherewithal of trumping the state
in the next article, which is Article 13 that is of seminal importance. It says
that the moment there is any law or executive action that is made contrary to a
fundamental right, it will be declared by a court to be void to the extent, of
course, that it contravenes a fundamental right; and that declaration of voidness will enure to the
citizen’s benefit and give the citizen relief. With Article 13 we have Article
32 which is an unique article not found in any other
constitution in the world. It specifically states that it is a fundamental
right to approach the Supreme Court in order to enforce other fundamental
rights. And it is through this mechanism of Articles
32 and 13 that all the great rights mentioned are enforced in favour of the
citizen as against the almighty state.
There are the great equality articles –
Article 14, is equality before the law and the equal protection
of the law. Article 15 once again establishes that the state cannot
discriminate on grounds of religion, race, sex, place of birth, or any such. Article 16, guarantees employment in government to persons who are
citizens. Article 17 is a ringing declaration against untouchability. The Parliament is compelled to introduce an
Untouchability Offenses Act to see that this article
is faithfully carried out. Article 18 deals with titles and states titles
etcetera given by a foreign state are not recognized. Article 19 is very
important. Both Article 14 and 19 are important as the two basic rights which
inhere in us, because we are human.
One is
not to be discriminated against, which is Article 14 and Article 19 has a
number of facets, each one of which is extremely important. The very first,
19(1)(a), is freedom of speech, and the court has read
into it, freedom of speech and expression, and freedom of the press which is
most important. The second is the great fundamental right of free assembly
which is crucial to a democracy. The third is the right to freely associate and
form unions. The fourth is to move anywhere freely throughout the territory of
India, a right not reflected in the U.S. Constitution. The fifth is a right to
reside anywhere in India, again not reflected in the U.S. Constitution. The
sixth is a right to property which caused a lot of trouble in the 1970s, and
finally was done away with in 1978, and the last one is a right you won’t find
in the older constitutions across the world, the right to practice any
occupation or carry on any business.
These seven fundamental basic rights are
all contained in Article 19. In Article 20 and 21, the famous ‘no double
jeopardy’, is where a person can be convicted of an offence only on the day
that he has actually carried out the offense; there can be no ex post facto
offence created and the great right not to incriminate oneself. Article 21
which lay dormant for a period of 28 years has now come back into being,
guaranteeing not just life and personal liberty, but also the right to live
with human dignity; the right to privacy. In Article 23 and 24 there is a
declaration against any form of begar, slavery, or
child exploitation. Article 25 and 26, address religious freedom, subject only
to public order, morality, and health. There is a separation of church and
state, of religion and state.
What is
important is when children are taught in a wholly controlled state educational
institution, religion cannot be taught, and if religion is taught in aided
institutions, every individual has the option to opt out of that religious
instruction. Article 29 is extremely important because it reflects the fact that
we are an extremely diverse people. All cultural rights, which a very diverse
people have, are preserved and protected. Now the word culture is vast and
subsumes a large number of things that we do in our daily lives. In Article 30
rests the important right to a minority institution to admit students of their
choice. Fundamental rights are basically addressed to the courts, to an
independent judiciary set up under the Constitution, which deliberates on these
rights, enters into a balancing act in each case that is before it, between the
citizen and the state, and then decides either in favour of the citizen or of
the state.
When we come to Directive Principles of
State Policy, these principles emanate from a constitution which is Roman
Catholic, and our two basic directive principles in Article 39(b) & (c) run
as follows. 39(b) – that the ownership and control of the material
resources of the community shall be so distributed as best to subserve the common good; and 39(c) – that the economic
system does not result in concentration of wealth to the common detriment. Both
these are directly lifted from an encyclical that is a letter written to the
Bishops by Pope Leo XIII as far back as in 1891. So, we do have these Catholic
concepts that were directly lifted and put into our Constitution. These
Catholic concepts, therefore, have given birth to a large number of
legislations that are socially beneficial and intended to usher in the social
revolution that the makers of our Constitution had thought about.
Other
than these directive principles, free legal aid as a matter of right; workers being looked after in various ways, with equal pay for
equal work, a basic living wage, was also included. There was a
concentration on the weaker sections to see that
they are uplifted, and also an article that addresses the prohibition of
intoxicating drugs and intoxicating drinks if they are detrimental to health.
Another part of the Constitution suggested the imposition of an excise duty on
alcohol to earn revenue for the state. This is what we find in the Directive
Principles of State Policy and it was Sir Benegal Narsing Rau, who wrote the first draft of our Constitution
and had a peculiar notion that the Directive Principles of State Policy were
primary and all important and that the fundamental rights would have to subserve them.
Fortunately, the founding fathers of the
Constitution emphatically rejected this notion and made it clear in Article 37,
which is of fundamental importance, and appears in the Directive Principles
chapter, that though these Directive Principles, like the other rights, are
fundamental, they are fundamental in the gover-nance
of the country, and they will apply to the legislature and the executive but
most importantly, they will not be justiciable in courts. Therefore, the scheme
of the Constitution was that the Directive Principles of State Policy would
guide the way for legislatures and the executive, and that the courts would
then test such legislation on the grounds that they either violate or not
violate funda-mental rights.
This was all very well until, very early in
our constitutional history in 1951, without waiting for the parliamentary
election due to take
place the following year, the same provisional Parliament which was the
Constituent Assembly, rushed through our Constitution’s First Amendment. The
reason for rushing it through was that the government of the day was very keen
that agrarian reform measures
go through and not get stalled. They rushed through the first amendment which
included two articles that upset the scheme. The scheme was that fundamental
rights are fundamental in their sphere – citizen against state that the citizen
can enforce. And that directive principles are
fundamental only in governance, applying to the legislature and the executive.
The waters now get muddied.
In 1951,
Article 31A and Article 31B (capital) were introduced by this First Amendment.
These articles subvert the scheme. The moment there is an agrarian reform
measure under 31A, all fundamental rights cease. However, all fundamental
rights were fortunately changed to Articles 14 and 19 that speak about equality
and the seven rights, and also 31 which was a property right. This was ensured
by the Fourth Amendment of the Constitution. From the Fourth Amendment on,
when there is a contest between an agrarian reform
legislation and equality rights, all the rights contained in 14 and 19 go out
of the window.
Then comes the
article that was meant to be an adjunct to Article 31A. That article is almost
a black hole in the universe of our Constitution. It is an extremely drastic
provision. It is open-ended and basically says, without prejudice to Article
31A, that the moment any act passed by either Parliament or the state
legislature is put into the black hole, which is the Ninth Schedule, all
fundamental rights cease. Second, and most important, is that it is not subject
specific. In the early years the courts could have read it to mean subject
specific, but unfortunately in the 1965 judgment in the N.B. Jeejeebhoy’s case, Chief Justice Subbarao
said 31B is independent of 31A. It was akin to a validating act provision, and
therefore, would have been tied only to agrarian reform. Therefore, 31B stands
as a massive roadblock qua every single fundamental right.
The
moment a legislation on any subject is put into this
black hole, the statute springs alive by virtue of having been put into this
black hole. Article 31B unfortunately was not put to test in any real sense
because in the very first judgement in 1952, Shankari
Prasad Singh, the Supreme Court said that since it was a constitutional
amendment it could not be tampered with substantively. Golaknath,
a 1967 judgement of eleven learned judges, by a razor thin majority said, thus
far no further and therefore, upheld it. Thus far and no further means 31B
continues. Eventually, in Kesavananda Bharati, in 1973, they put up the ‘basic structure’ test
and said that any constitutional amendment that violated the basic structure
must go. So, 31B was never tested on the grounds that it was a terrible inroad
into the separation of powers and fundamental rights.
A five judge bench in the Waman Rao judgement in 1981 held
that we will restrict 31B hereon. Every act in the Ninth Schedule,
would have to be tested on the grounds of basic structure. Justice Khanna’s judgment in Kesavananda Bharati, had said the right to property is not part of the
basic structure and by the time it came to be tested in Waman
Rao, the right to property had gone altogether. Waman Rao spoke of basic
structure and finally Waman Rao
was referred to a larger bench in I.R. Coelho. Coelho was a nine judge bench
and could have done many things in so far as 31B was concerned. It could have
said fundamental rights are part of basic structure, which it did, but then
went on to say that some fundamental rights may not be part of basic structure.
I fail to see which fundamental right would not be part of the basic structure
in 2005 when property had gone. Perhaps the title provision, Article 18, but
short of that everything is fundamental, and they are all rights that naturally
inhere in us.
The
two-tier test muddied the waters again. This test was that first it would have
been what is referred to as the Rights’ test and thereafter, the Essence of
Rights’ test. What does that mean? It asks whether the law contravenes a
fundamental right. If the answer is yes, then does it contravene the very
essence of that right or not. For example, if there is
some arbitrary pension scheme which takes away a large part of a person’s
pension, it is as egregious an infraction of Article 14 as an infraction of
Article 14 can be. It is very difficult to understand this core and penumbra
test which they laid down and therefore kept 31B alive, so far as core and
penumbra were concerned. 31C is bringing back to fruition B.N. Rau’s emphasis
that fundamental rights run subsidiary and are subservient to the directive
principles.
Long before 31C came into force in 1971, a
communal GO was challenged in 1951, and one wondered why it was called a
communal GO. It was a peculiar GO where in the engineering colleges, medical
colleges and suchlike, there were 14 seats reserved – six for Hindus who were
non-Brahmin, two for Brahmins, two for Harijans, two
for OBCs; one for Muslims, and one for Christians. This communal GO was
challenged in the Madras High Court and then here. Justice Das struck down the
communal GO and said: fundamental rights are most important and directive
principles are in fact subservient to them. He said this because if you read
Article 13 and Article 37, it becomes clear that Directive Principles are not
enforceable in the courts under Article 37, so they must run subservient.
The same
thing echoed in Mohd. Hanif
Qureshi’s case, which was involved cow slaughter.
That cow slaughter case was upset in 2005 by a bench of seven judges who said
that the balanced view that Qureshi had taken is no
longer balanced because even though cattle may not be useful for giving milk or
as draft cattle, nonetheless, if there is legislation that says they cannot be
touched, you cannot touch them. It is not a coincidence that six of the seven
judges were vegetarian.
31C became the subject matter of challenge
in our most populated bench of Kesavananda Bharati which consisted of the maximum 13 judges and 31C
was upheld by six judges on the grounds that a constitutional amendment could
not be struck down. There was no basic structure test applied to it. It was
Justice Khanna, the seventh judge, who applied basic
structure, and struck down what is called the last part of 31C that precluded
even a limited judicial review of going into whether the law was in fact in
pursuance of Article 39(b) or (c) or not.
As things stood, for the first time there
was a full-blown challenge to 31C in the same Waman Rao judgment in 1981, and Waman Rao somehow or the other said we are bound by 13 judges. It
was the end of the matter. That was not correct because basic structure had
never been applied to 31C. The majority six had said 31C had to stand because
you could not touch constitutional amendments. It also went on to say it was
very difficult to conceive of a case would violate Articles 14 or 19 if a law
were truly under the Directive Principle of 39(b) or (c).
This reasoning was specious. 19(1)(a) is the single
most important right in a democracy; the right to free speech and the right to
freedom of the press. Think of a law that said all newspapers over a certain
circulation of x pages were either to be nationalized or shut down altogether
because they are critical of government. Such a law would have passed muster.
Therefore, when both Justice Khanna and Waman Rao spoke of no law being made in pursuance of 39(b) or (c) violating 14 or
19, they totally forgot the most basic, cardinal right in a democracy – freedom
of speech. The most fundamental right is the right to freedom of speech and of
the press. Unfortunately for us, 31C continues on the statute book as
originally enacted.
In 1976, B.N. Rau’s vision was realized.
Every single Directive Principle and any law made in pursuance of any Directive
Principle, out go the two most basic rights: equality and all the seven rights
contained in 19. This was tested in the celebrated Minerva Mills judgment and
fortunately, the enlargement of the scope of Article 31C did not stand scrutiny
and the court struck it down. The court correctly, for the first time, spoke of
Fundamental Rights and Directive Principles being two wheels of a chariot. It
spoke of the balance required to maintain a means and ends analysis. Directive
Principles are the ends to be obtained by the state. The means through which
they can be obtained are only through Funda-mental
Rights. Once this is viewed correctly, as it was in Minerva Mills, everything
becomes crystal clear.
The court went on to say that Directive
Principles of State Policy are contained in every constitution, totalitarian or
otherwise. Funda-mental rights may also be in
totalitarian constitutions but without any enforcement machinery. The
difference between our nation and many other nations is that the rights are
there as is the enforcement machinery, and fortunately for us, the enlarged 31C
that was B.N. Rau’s vision was rejected by the Constituent Assembly, and also
by our court, so that today we actually have 31B somewhat controlled by this
basic structure doctrine. I only wish the court would go into 31C again,
particularly with regard to the fact that 19(1)(a) is
a matter which is of fundamental importance to any democracy. If 19(1)(a) can be snuffed out by taking recourse to 39(b) and (c),
we will be no different from China or Russia.
The Fundamental Duties chapter was introduced in 1976
by the Swaran Singh Committee. The committee had
eight duties, two of which were that every citizen must pay his taxes and
number two, every citizen must follow the Directive
Principles of State Policy which today, are not in Fundamental Duties. Benjamin
Franklin had said that there was no certainty except death and taxes, but what
he could not conceive of was taxes that caused death. The taxes that caused
death in 1976 were the income tax which was at a peak of 97 per cent with a
wealth tax, if you were eligible, would come to 103 per cent.
Fortunately or unfortunately, the Swaran Singh Committee findings were not followed perhaps
for this reason and therefore, the fundamental duty to pay taxes was not part
of the chapter. The committee had one interesting provision – that Parliament
pass a law penalizing persons or citizens who do not obey their Fundamental
Duties. That too was dropped. Today we have ten Fundamental Duties with an
eleventh added later. The Fundamental Rights chapter is Citizen versus State.
The Directive Principles State Policy chapter is where the state is made to
follow Directive Principles while enunciating laws. The Fundamental Duty
chapter spells out the moral precepts plus how a citizen should behave with
other citizens.
The first fundamental duty in Article 51A is that
citizens have to abide by the Constitution, its ideals, institutions, and
respect the national flag and the national anthem. Here is the question: How
can one abide by the Constitution unless one know what
the Constitution is to start with? Does not the government have a duty to
spread the tenets of the Constitution in every Indian language and make sure
citizens are aware of their constitutional rights?
It is essential that these moral precepts
filter down to everyone. My suggestion is that the government of the day should
distribute free copies of the Constitution of India in every possible language,
so that every citizen knows what his rights are.
We are told to uphold the sovereignty and unity of the nation. The fourth
fundamental duty states you can be called upon to defend the nation. The fifth
fundamental duty is of crucial importance and is the cardinal value of
‘fraternity’ which is now in our Fundamental Duties chapter, and not in
Fundamental Rights or Directive Principles chapters. Here it empha-sizes the extreme importance to honour other citizens
in a spirit of brotherhood transcending religious, sectarian and other
fissiparous tendencies, and to abjure practices which are derogatory to women.
Most importantly, the key word here is ‘transcending’.
We have a fundamental duty in respecting our composite
culture. For me, fraternity is extremely important. Criminal law is sometimes
used selectively. To check this there are some interventions that are
essential, For one, civil courts should take up any
suit filed by any citizen against, for example, hate speech. Hate speech
disrupts harmony. It disrupts brother-hood. Therefore, the moment a citizen
petitions a court against hate speech, the court cannot merely issue a
declaration and an injunction because of the fundamental duty. It must also
award punitive damages. Nothing hurts more than that which hurts the purse. If
the courts were to take cognizance of civil suits in which these three things
are done, it would go a long way towards preserving and protecting fraternity.
Fortunately for us, a recent Supreme Court
order went out of its way to say that every authority must act the moment there
is hate speech, and if the authorities do not act, it will be seen as contempt
of court. This was a good step in the right direction. Another very important
step is a civil step given this fundamental duty and given the fact that the
Fundamental Duties chapter, unlike both fundamental rights and directive
principles, is silent on the court’s role. This can be corrected.
A civil suit could encompass any civil
right, which is in fact a constitutional right. It is higher than any statute.
If we are going to live by the cardinal principle of fraternity, this is the
only way. It is the only constitutional method of assuring the dignity of every
individual citizen of this country and of ensuring the unity and integrity of
the nation. It must be given some teeth. I can only quote from Justice
Jackson’s great judgment in West Virginia Board of Education versus Barnett
which was the Jehovah’s Witness case of 1943, where they refused to salute the
U.S. flag and Justice Jackson upheld their right not to salute the flag because
they had a serious conscientious religious objection to it.
In India these words apply all the more because of the
massive diversity this country has unlike America. The words are, ‘if there is
any fixed star in our constitutional constellation, it is that no official high
or petty will be allowed to prescribe what is orthodox, in politics,
nationalism, religion or any other mode of thought.’ Beautiful
words.
When no official is allowed to interfere with that diversity, it translates into unity, not otherwise. I will end by sharing with you another Jehovah’s Witness case, this time from the Supreme Court of India. I quote Justice Chinnappa Reddy’s great words where he ends Bijoe Emmanuel, which was another case where children of Jehovah’s Witness refused to sing the national anthem, again on religious grounds. He put it beautifully when he said: ‘our tradition teaches tolerance, our philosophy preaches tolerance, our constitution practices tolerance, let us not dilute it.’
Footnotes:
* Edited speech delivered by Justice Rohinton F. Nariman at the 13th V.M. Tarkunde Memorial Lecture, New Delhi, 11 November 2022.