Directive Principles And Socio-Economic Justice - The Role Of Article 39 In Shaping India’s Welfare State
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DIRECTIVE PRINCIPLES AND SOCIO-ECONOMIC
JUSTICE: THE ROLE OF ARTICLE 39 IN SHAPING INDIA’S WELFARE STATE Shourya Shubham, Gujarat National Law University I.
INTRODUCTION
"If we wish to maintain democracy not merely in form, but also in fact, we must hold fast to constitutional methods of achieving our social and economic objectives. " -B. R. Ambedkar India is the second most populated country and a nation with such huge population is home to a lot of social evils such as poverty, discrimination, illiteracy, increasing crime rate, etc. A large part of the population suffers and struggles for employment or a source of living due to which the crime rate in general is tremendously increasing in the country, thereby affecting the overall well-being of the country. It is a well-known thing that crime or injustice spares none and it just doesn’t happen against those who are able to fight it making the underprivileged the most severely hit.
In these cases, the legal system of the country comes to the rescue by ensuring their protection from infringement of rights. Article 39 which is also a part of the Directive Principles of State Policy that has been introduced in our country for better handling of such cases and to protect the underprivileged and impoverished from becoming the most oppressed ones who face all the wrath of such evils. 1 It emphasizes that it is the State’s responsibility to take pro-active measures and flourish together as a nation where the interests of every person are taken into consideration. India is a nation with a very wide range of diversity and turbulent history of societal oppression of certain classes; hence, it becomes state’s responsibility to help them get back on the same page.
Directive Principles of State Policy occupy an essential position in constitutional governance which serves as the foundational framework within which all government policies must be
1 INDIA CONST. art. 39.
developed. 2 These principles act as the cornerstone for policy establishment, thereby, guiding legislative action toward broader societal goals. While public discourse often focuses intensely on fundamental rights and federal structures, the Directive Principles of State Policy (DPSP) frequently receive insufficient attention despite their profound importance. 3 The inclusion of Directive Principles in our Constitution offers hope to marginalized and economically disadvantaged communities and embody the potential to transform our current social inequities into a more just society where principles of fairness, equality, and equity are recognized. 4 Article 39 of the Constitution of India embodies 6 important clauses that provides for protection of the rights of the underprivileged community of the society and reflect the idea of notion of social justice and welfare.
Article 39 (a) states that all citizens irrespective of their gender are entitled to adequate means to livelihood. 5 The next two clauses of article 39 focus on the common distribution of public resources and the welfare of society in general. 6 Then, Article
39 (c) carries with it the most crucial aspect of contemporary society i.e. equal work equal pay.7
This provision reaffirms the principle of equality and rejects the notion of discrimination based on gender. Article 39 (e) accentuates the importance of the overall health of the population and to bar them to engage in any employment which is not suited to their age and strength. 8 The last clause of Article 39 i. e. , 39 (f) highlights the concern for an environment that provides ample freedom and dignity for the holistic development of children and to protect them from exploitation or any immoral activity. 9 I. A. Article 39A: Paving a path for balance in society In a democratic country like India, justice is something that every individual is entitled for. All the classes of our society can hail for justice and there is absolutely no difference in provision for have and have-nots.
The Indian Constitution through Article 39 A establishes a provision for offering free legal assistance to economically disadvantaged individuals who would otherwise be unable to secure their own legal representation in courts. This constitutional safeguard ensures that financial limitations do not prevent citizens from accessing justice
2 J.N. PANDEY, CONSTITUTIONAL LAW OF INDIA (52nd ed., 2015).
3 Nishita Kirty, Equal Justice and Free Legal Aid, 4 IJLMH 1359, 1359 – 1365 (2020).
4 Ibid.
5 INDIA CONSTI. art 39, cl. a.
6 INDIA CONST. art. 39, cl. b, c.
7 INDIA CONSTI. art 39, cl. c.
8 INDIA CONSTI. art 39, cl. e.
9 INDIA CONSTI. art 39, cl. f.
within the legal system. 10 Every individual, no matter what his caste, creed, religion or sex is, he/she has the right to be heard before a court of law as per the rule of natural justice laid down in the legal principle of ‘audi alteram partem’. Justice P. N. Bhagwati rightly laid down the concept of legal aid and stated, “Legal Aid is a means which provides an arrangement in the society so that the mission of administration of justice becomes easily accessible and is not out of reach of the poor and illiterate. ” The State must ensure that every individual gets equal justice and enough means to be heard and get represented.
The Parliament passed the Legal Services Authorities Act in 1987 to establish a comprehensive and standardized national system to deliver free, professional legal services to vulnerable populations across the country to ensure equal access to justice regardless of socio-economic status. 11 The Legal Services Authorities Act of 1987 established the National Legal Services Authority (NALSA) which is responsible for effectively implementing legal policies and programs at the grassroots level to protect and advance the interests of disadvantaged and marginalized communities. 12 The responsibility of the state is shared by National Legal Services Authority (NLSA) or State Legal Services Authority (SLSA) or the concerned District Legal Services Authority (DLSA) under the Legal Services Authorities Act, 1987 to provide for the free legal aid to the impoverished individual in need of justice.
13 There has been establishment of several additional institutions to ensure justice and promote the advancement of vulnerable populations, including Lok Adalats (People's Courts), the Supreme Court Legal Service Committee, High Court Legal Service Committees, and other similar organizations. 14 The concept of legal aid was non-existent in India before 1976, and it was a collective and prolonged effort of various jurists and committees that led to the inclusion of Article 39A in the Constitution of India by the 42nd amendment. 15 India is a welfare state and is responsible for the balance of interest of its people. The concept of Free legal Aid does not only include free representation of poor people before the court of law but also includes awareness in the
10 Supra Note 3.
11 Supra Note 2.
12 National Legal Services Authority, Functioning of NALSA, (Dec. 20, 2010, 10:04 AM),
https://doj.gov.in/sites/default/files/NALSA%20BRIEF.pdf.
13 Legal Services Act, 1987, No. 30, Acts of Parliament, 1987(India), § 12, 13.
14 Supra Note 2.
15 INDIA CONST. amend. XLII.
country through various programmes, schemes, and initiatives, conducting Lok Adalat for speedy and expeditious justice and availing victim compensation where necessary. Article 39A of the Indian Constitution ensures justice for all by guaranteeing free legal assistance to those in need and from vulnerable communities which is further reinforced by Articles 14 and 22(1) of the Constitution. 16 It further places an obligation on the State to maintain equality before the law and to establish a judicial system that administers justice equitably for all citizens. 17 I. B. Statutory Recognition of Article 39 Article 39 is considered as one of the most important provisions of our constitution as the whole responsibility to guide the state towards better falls on this very provision.
It is the guide of the state in making policy decisions and meticulously scrutinizes the need and interests of every individual. 18 Article 39 falls under the ambit of the socialist principle where the overall welfare of the state is taken into consideration. 19 It is often read with Article 38 which talks about the protection of social order and Article 41 states about the right to work and education. Also, Articles 14 and 22(1) of the Constitution make the State responsible to ensure equality before the law and provide an unbiased legal system that promotes justice and provide equal opportunity to all. 20 The concept of legal aid has also been mentioned under Section 304 of CrPC i. e. , the procedural law of our country which states that the accused should have legal assistance and if he is not financially sound to do so; the court must provide him with it on the account of state.
21 The right to a speedy trial and free legal aid have been recognised as well as embedded as a part of the right to life. 22 However, irrespective of how noble the cause, DPSPs are not enforceable by law, rather they are mere directives to the state. Also, there had been a long conflicting history between Directive Principles and Fundamental rights. The Judiciary has time and again clarified the ambiguities that have arisen among these two provisions. The Supreme Court in Re Kerela Education Bill case23 had introduced the Doctrine of Harmonious Construction to avoid any
16 INDIA CONST. arts. 14, 22.
17 S MAURALIDHAR, LAW, POVERTY AND LEGAL AID
ACCESS TO CRIMINAL JUSTICE 72-74 (2nd ed., 2004).
18 Id.
19 V. N. SHUKLA, CONSTITUTION OF INDIA (13th ed.,2017).
20 Id.
21 Criminal Procedure Code, 1973, Act No. 2, Acts of Parliament, 1974 (India), § 304.
22 INDIA CONST. art. 21.
23 Re: The Kerala Education Bill, (1959) 1 SCR 995 (India).
situation of conflict or confusion while enforcing any of these two provisions. The Doctrine of Harmonious Construction talks about no inherent conflict between two concerning provisions and that the two can be given effect harmoniously while interpreting the law.24 II.
CONTRIBUTION OF THE JUDICIARY IN SECURING THE PILLARS OF
ARTICLE 39 The pillars of the judiciary lie in the principles of justice and equality. The supreme law of the country i. e. the Constitution has provided the judiciary with the power as well as the responsibility of protecting the weaker sections of the society. The judiciary has played an active role in providing free legal aid and protecting the rights of marginalized sections of the society. 25 In the case of Hussainara Khatoon v. State of Bihar26, a petition was filed in the Supreme Court of India that brought the attention of the country towards the poor condition of prisoners. The case was filed concerning the miserable conditions of prisoners from underprivileged communities who were detained in Bihar Jail. 27 In the aforementioned case, Justice P. N.
Bhagwati stated that prisoners had already undergone a lot of torture and inconvenience, and this treatment has exceeded the punishment that they were entitled to. Therefore, the court released the prisoners with immediate effect and reaffirmed that the State cannot shrug off its duty of providing everyone with the constitutional right of a speedy trial on the ground that the State lacks adequate resources. Furthermore, the court highlighted that Article 39A is necessary for the fair and just procedure of law and is included under the right to life enshrined in Article 21 of the constitution. 28 In another landmark case of SK Das v. Union Territory of Arunachal Pradesh29, Justice P. N. Bhagwati recognized the issue of lack of awareness of the rights and increased degree of exploitation in the weaker and poorer section of society. Another prominent pioneer of his field
24 H.R. KHANNA, MAKING OF INDIA'S CONSTITUTION 217-219 (2ND ED., 2018).
Justice Krishna Iyer rightly put forward the concept of free legal aid and reaffirmed their constitutional and statutory rights. He stated that it is the implied duty of the court under Article
14230 read with Articles 21 and 39-A of the Constitution to assist a person with legal counsel
if he is not represented fairly. The Legal Services Authorities have also contributed a lot in establishing a premise where free legal aid is easily accessible to needy and impoverished people. Their prominent role was notably seen in the case of Sampurna Behrua v. Union of India31, wherein a PIL was filed in the interest of the children or juveniles who were not receiving proper benefits under the Juvenile Justice (Care and Protection) Act, 2015. 32 A plea was made revolving around the fundamental rights of these children being infringed. The Delhi Legal Services Authority played a very vital role in helping the petitioner put forward her case on this issue of child rights. Furthermore, in another case of National Legal Services Authority v. Union of India33, the Apex court was approached about recognition of the rights of transgender.
The court invoked Part III of the constitution of India and held that transgender hold equal rights as any other citizen of India and will be treated as ‘third gender’. The state should legally recognize them and give them the status of socially and educationally backward classes of citizens to maintain the balance of society. Furthermore, the court in the case of Sunitha v. State of Telangana34 emphasized the importance of Article 39 A of the constitution for providing equal justice and free legal aid. In this case, the lawyers were continuously going in for strike which lead to recurring cases and delay injustice. The bench further stated that it is very important that the bar and bench work together to achieve the common goal of the legal fraternity i. e. , to deliver justice without any delay.
These judgments have not only emphasized on legal aid being an important element of the judicial system, but also the roles of judges in guaranteeing its proper recognition and implementation. The current system of judiciary is burdened with lots of pending cases which
30 INDIA CONST. art. 142.
31 Sampurna Behrua v. Union of India, (2018) 4 SCC 433 (India).
32 Juvenile Justice (Care and Protection) Act, 2015, No. 23, Acts of Parliament, 2015 (India).
33 National Legal Services Authority v. Union of India, Writ Petiion (civil) No. 604 of 2013 (India).
34 Sunitha v. State of Telangana, Appeal (Crl.), 2068 of 2017, (India).
hampers speedy justice.35 Therefore, the Indian Judiciary has made attempts to reduce the burden of courts by setting up Lok Adalats and other specialized courts as an alternative dispute resolution system.36 III.
ARTICLE 39 v. FUNDAMENTAL RIGHTS: BALANCING OF RIGHTS Article 39(b) of the Constitution states that “The State shall, in particular, direct its policy towards securing the ownership and control of the material resources of the community are so distributed as best to sub serve the common good. ” Recently, the Supreme Court in a 9-judge judgment gave a historic judgment which redefines private property rights and favours market economy over state control, thereby overturning the socialist era interpretation of Article 39(b). 37 This judgment denounced Justice Krishna Iyer’s contribution, specifically his concurring opinion in State of Karnataka v. Ranganatha Reddy38.
During the post-Emergency period, their judicial activism favoured the poor and underprivileged, restoring the Court’s credibility that had declined after its failure to defend citizens’ fundamental rights during the Emergency. In subsequent years, progressive judges of the Court favoured individual’s rights over State. In Ranganatha Reddy case39, the Court examined the validity of the Karnataka Contract Carriages (Acquisition) Act, 1976 in which the Court upheld the Act under Article 31 C of the Constitution.
Article 31C which was added by 25th Constitutional amendment states that “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. ”40 35 F. E. Online, Over 4 million cases pending in High Courts of India, lower courts more burdened with 2 Crores cases, THE FINANCIAL EXPRESS (May 17, 2021, 10:04 AM), https://www. financialexpress. com/india-news/over-4-million-cases-pending-in-high-courts-of-india-lowercourts-more-burdened-with-2-crores-cases/1426165/.
36Lok Adalat, National Legal Services Authority, (May 25, 2021, 11:00 AM), https://nalsa. gov. in/lok-adalat.
37 Property Owners Ass'n v. State of Maharashtra, (2023) 1 SCC 125 (India).
38 State of Karnataka v. Ranganatha Reddy, (1978) 4 SCC 471 (India).
39 Id.
40 INDIA CONST. art. 31C.
Justice Iyer interpreted “material resources of the community” in Article 39(b) to include both privately owned and state-owned resources, however, it was a minority opinion. 41 Then afterwards, a subsequent five-judge Constitution Bench reiterated the same rationale in g in Sanjeev Coke Manufacturing Co. v. Bharat Coking Coal Ltd. 42 This judicial error persisted until 2002 and it took around 22 years to correct this flawed judicial stand when a seven-judge Bench referred it to a nine-judge Bench in Property Owners Association v. State of Maharashtra. 43 The bench criticized Justice Iyer’s reasoning. Paragraph 213 of the judgment states: “To declare that Article 39(b) includes the distribution of all private resources amounts to endorsing a particular economic ideology and structure for our economy. Justice Krishna Iyer’s judgment in Ranganatha Reddy...
was influenced by a particular school of economic thought. The interpretation of Article 39(b) adopted in Sanjeev Coke (Justice Chinnappa Reddy) and Ranganatha Reddy and Bhimsinghji (Justice Krishna Iyer) is rooted in a particular economic ideology and the belief that an economic structure which prioritises the acquisition of private property by the state is beneficial for the nation. ”44 The Court's majority opinion determined that the framers of the Constitution deliberately avoided mandating any socio-economic framework or policy direction. Instead, they created a flexible constitutional structure that permits successive elected governments to implement various economic governance approaches while remaining subject to democratic accountability.
Two dissenting justices vigorously championed Justice Krishna Iyer's jurisprudential contributions and challenged the majority's emphasis on deferring to elected officials' judgment, cautioning against mistaking electoral success for constitutional legitimacy. The majority identified what they considered a fundamental flaw in Justice Krishna Iyer's reasoning and his assertion that a strict economic philosophy advocating government control of private resources represents the definitive foundation for constitutional governance.
The majority’s problematic equation of constitutional interpretation with electoral majority appears in Paragraph 216: “India’s economic trajectory indicates that the Constitution and the custodians of the Constitution—the electorate—have routinely rejected one economic dogma 41 Supreme Court Observer, Nature of Private Property: Judgement & Pronouncement - Property Owners v. State of Maharashtra, https://www. scobserver. in/reports/nature-of-private-property-judgement-pronouncementproperty-owners-v-state-of-maharashtra/ (last visited May 7, 2025).
42 Sanjeev Coke Manufacturing Co. v. Bharat Coking Coal Ltd., (1983) 1 SCC 147 (India).
43 Property Owners Ass'n v. State of Maharashtra, (2023) 1 SCC 125 (India).
44 Property Owners Ass'n v. State of Maharashtra, (2023) 1 SCC 125, ¶ 213 (India).
as being the exclusive repository of truth.”45 The majority ruled that Article 39(b) does not automatically include all private property and clarified that while no blanket ban exists on including private property, such inclusion requires meeting two tests: qualifying as a “material resource” and having a “community” element. They emphasized that these qualities must be assessed on a case-to-case bias and not in abstraction. They reasoned that sometimes government control serves the “common good,” while in other instances, distribution among private players achieves this aim. The resources falling under Article 39(b) require context-specific analysis considering several factors46:
1. The resource’s nature and characteristics;
2. Its impact on community welfare;
3. Its scarcity and
4. The consequences of such a resource being concentrated in the hands of private players.
A. Significant dissents
In his dissent, Justice Dhulia upheld the broad, inclusive interpretation of “material resources of the community” established by Justices Krishna Iyer and O. Chinnappa Reddy in Ranganatha Reddy and Sanjeev Coke. 47 He maintained that this interpretation retains its relevance and jurisprudential value along with its appreciative audience and strongly disapproved of the majority’s remarks on the Krishna Iyer Doctrine. Justice Nagarathna held that “material resources of the community” encompasses privately owned resources, excepting “personal effects” and also challenged the majority’s critique of Justices Iyer and Chinnappa Reddy’s observations in Ranganatha Reddy and Sanjeev Coke as unjustified and unwarranted.
48 She questioned their criticism, which stemmed merely from evolving state socio-economic policies and shifting paradigms and emphasized that constitutional interpretation demands consideration of its historical context.
45 Property Owners Ass'n v. State of Maharashtra, (2023) 1 SCC 125, ¶ 216 (India).
46 Supra Note 41.
47 Id.
48 Id.
IV.
HURDLES IN THE EFFECTIVE IMPLEMENTATION OF ARTICLE 39
India is a country with lots of diversity in race, religion, creed, and class, yet united by the thread of brotherhood and integrity. The concept of legal aid was primarily introduced in India to control and manage the population of India by restoring their faith in the established justice system. 49 However, despite so many efforts, the judiciary is not placed on that pedestal by the citizens of this country to which it was originally entitled to. The concept of free legal aid which was expected to rebuild the image of the judiciary by giving them speedy and fair justice has also fallen flat. Free legal aid was carried forward with it a very noble cause yet it has faced such a huge failure. Also, the hurdles in the way of properly implementing the guidelines of Article 39 are as follow50:- A.
Quality of free legal aid services There is a flawed perception that free service cannot come with quality, and there will always be some hindrances in the way of smooth running. The service of free legal aid often fails because there are not enough lawyers under the authorities who are willing to offer free legal service to the needy people as the remunerations given by the committee is quite trivial; it falls short of even meeting the incidental expenses. 51 Another reason is the lack of awareness among the people about their right to free legal aid. One of the possible solutions of making legal aid to be a practical option for everyone is “the law-making its reach to the people and not the other way around”.
Also, more lawyers should be encouraged to inform citizens about it and also be a part of the noble cause of free legal services that ensures justice to the darkest part of society too. B. Sensitisation The Government has perpetually introduced a lot of schemes and qualitative policies and has constituted many committees to yield great results in light of a welfare state. However, it is not enough in reaching to the ground level because there is a lack of awareness. The Government
49 U. Sarathchandran, Bringing legal aid a step closer home, THE HINDU (May 2, 2025, 10:45 AM),
https://www.thehindu.com/opinion/lead/bringing-legal-aid-a-step-closer-home/article2609718.ece.
50 Supra Note 3.
51 Soibam Rocky Singh, Most see free legal aid as last-ditch option
report, THE HINDU (April 23, 2025, 09:09 AM), https://www. thehindu. com/news/cities/Delhi/most-see-free-legal-aid-as-last-ditch-optionreport/article28237300. ece. before making policy decisions should focus more on spreading awareness amongst the people who most likely will be accessing them about the benefits of this right through various policies and schemes. 52 The Government needs to get with campaigns to inform and educate the people of this country of their rights and set up more efficient processes to enhance the existing system of society. 53 The process of spreading awareness will get accelerated if the justice system of our country comes into the picture. The State lags in organizing legal awareness camps, which has the capability of making remarkable success in accomplishing the goal.
The government must involve itself more in organising these camps from time to time and with an inspecting authority to oversee the working of the State authorities for proper implementation. 54 C. Resource Constraints The provision of quality legal aid services across India's vast and diverse population requires substantial financial investment, skilled personnel, and robust infrastructure which are not adequately available. 55 Moreover, government budgetary allocations for legal aid programs consistently fall short of actual requirements which limits the scope and reach of assistance available to disadvantaged communities. This financial shortfall translates into insufficient compensation for legal aid lawyers, resulting in limited participation from experienced attorneys and compromising the quality of representation provided.
Furthermore, physical infrastructure deficiencies, including inadequate legal aid clinics and insufficient technological resources, particularly in rural and remote areas create practical barriers to access. The human resource gap is equally concerning, with an insufficient number of trained legal professionals willing to work in legal aid services, often due to financial disincentives and overwhelming caseloads. This combination of fiscal constraints, infrastructural limitations, and human resource shortages significantly undermines the constitutional promise of equal justice for all, leaving many marginalized citizens unable to effectively navigate the legal system despite the constitutional guarantees enshrined in Article 39.
52 Id.
53 National Human Right Commission, India, Human Rights Education important in spreading awareness, NHRC NEWS LETTER (April 16, 2025, 9:00 AM), https://nhrc.nic.in/press-release/human-rights-education-importantspreading-awareness.
54 Supra Note 35.
55 Id.
D. Coordination Challenges
The multi-layered legal aid framework in India comprising of the National Legal Services Authority (NALSA), State Legal Services Authorities, District Legal Services Authorities, and Taluk Legal Services Committees often suffers from fragmented communication and overlapping responsibilities. This complex institutional structure frequently results in disjointed service delivery, where information sharing between agencies remains inadequate and strategic alignment is lacking. Additionally, coordination gaps exist between legal aid bodies and other relevant stakeholders, including the judiciary, police departments, social welfare organizations, and grassroots NGOs, whose collaboration is essential for comprehensive legal assistance. The absence of standardized protocols for case referrals, information exchange, and resource sharing further exacerbates these coordination deficiencies.
Rural areas face particularly acute challenges, where geographical distances and communication barriers complicate coordination efforts. The resulting siloed approach to legal aid delivery creates inefficiencies, duplication of efforts, and service gaps that disproportionately affect the most vulnerable citizens, ultimately undermining the constitutional mandate of ensuring equal access to justice for all sections of society. E. Limited Monitoring The legal aid system lacks robust performance evaluation frameworks to track service quality, case outcomes, and beneficiary satisfaction. Without comprehensive data collection and analysis, identifying systemic gaps and measuring program effectiveness becomes nearly impossible, leaving authorities unable to make evidence-based improvements.
56 The few monitoring systems that exist often focus on quantitative metrics like case numbers rather than qualitative aspects of representation, failing to capture the actual impact on access to justice. F. Training Deficiencies Training deficiencies compound these challenges, as many legal aid providers receive insufficient preparation for addressing the specialized needs of marginalized communities. Legal education programs rarely emphasize poverty law, social justice, or the unique legal challenges faced by disadvantaged groups57. Continuing education opportunities for practicing
56 Id.
57 Supra Note 35.
legal aid lawyers remain limited, leaving them ill-equipped to handle complex cases involving vulnerable populations. Additionally, frontline staff often lack training in crucial soft skills such as empathetic communication, cultural sensitivity, and trauma-informed approaches necessary for effective engagement with marginalized clients. These combined shortcomings in monitoring and training create a significant barrier to fulfilling the constitutional promise of equal justice embodied in Article 39. V.
CONCLUSION
India is considered one of the greatest democracies of all time and the Constitution of India is regarded as the supreme law of the land. The Constitution was founded to retain the faith of people in the legal structure of the country and to ensure the restoration of justice. If we concise our preamble, we will distinctly see the three clear and broad aims of the country i. e. , social, economic, and political justice. India has a concealed dark past of severe exploitation and great struggle behind its shiny and scintillating track of progress and development. The framers of the constitution have given the responsibility to different provisions of DPSPs to create a healthy and progressive environment for our citizens to live in peacefully.
India is a welfare state and has the responsibility of maintaining the balance of interest between all the classes of the society without any prejudice. The courts have also in a plethora of judgments have indicated the obligation of the state to provide for the marginalized section of the society. In a nutshell, Article 39 is the cornerstone of the constitution which makes a holistic framework of guidelines for the State to help all sections of the society to flourish. For the sustainable growth of our country, we need a positive attitude and open mind to give exposure to the modification of the laws according to the changing needs and demands of society. The exploitation of marginalized people can only be defeated when the people become aware of their legal rights, and the system along with the society works together to ensure their protection that they are entitled to by law.