Directive Principles And Sustainable Development - Revisiting Constitutional Goals For Future Generations

Author: LawSphereX

Category: Constitutional & Human Rights

Published: 2026-08-23T19:27:30.236Z

Updated: 2026-08-30T07:07:28.892Z

DIRECTIVE PRINCIPLES AND SUSTAINABLE

DEVELOPMENT: REVISITING CONSTITUTIONAL GOALS FOR FUTURE GENERATIONS

Sudhikrishna AS, Assistant Professor, Marian College, Kuttikkanam (Autonomous)

ABSTRACT

Constitutional Directives are certain obligations that every state has to follow while framing its laws and policies. In India, the Directive Principles of State Policies (DPSP) are the set of principles that guide state governance. Part IV of the Indian Constitution, from Articles Use 36 to 51, deals with the DPSP. These principles are intended to improve the socio-economic conditions of the citizens to improve the standard of living. One of the most important features of the DPSP is that they are not legally enforceable, so even though they act as a guideline for the state governance, still, even if the state is not implementing the DPSP, no one can take any legal action, which means each state has its discretionary power to implement the DPSP, and if they are hesitant to implement, no one can enforce its implementation legally. This will create an impact on the future as the circumstances that led to the development of DPSP at the time of drafting the constitution are not similar as compared to the present scenario; generations have evolved and their needs have changed, but still only certain DPSP has been implemented by the state uniformly, thus creating a dilemma among various people residing in different states, which will ultimately affect sustainable development. Through this article, we will analyse how the existing Articles related to DPSP in the Constitution of India help in achieving sustainable development and in what ways these articles need to be amended to satisfy the needs of future generations. Keywords: Directive Principles of State Policy (DPSP), Indian Constitution, Part IV (Articles 36 to 51), Sustainable Development, Socio-economic justice, Non-enforceability, Constitutional directives, State governance.

Introduction

The framers of the Constitution conceived the Directive Principles of State Policy (DPSP), incorporated in Part IV (Article 36 to Article 51), which is a basic aspect for the proper governance of a nation, to serve as a beacon, to bring about an egalitarian society. Aspirational goals are not legally enforceable; these goals embody the spirit of a welfare state that is pledged to social justice, economic equality, and environmental prudence. Over the years, some of these DPSPs (Directive Principles) have worked their way into major policy decisions, while others have been neglected or unevenly adopted by the states. In this current fluid socio-economic environment, where sustainable development has become far more pressing an issue than before, the relevance of DPSPs cannot be left to rest. This Article seeks to analyse the extent to which the current DPSPs contain within them objectives of sustainable development and discusses the constitutional and policy reforms that are required for them to be in sync with the changing needs of the present generation. ARTICLE 38 In order to ensure order in society, the Government of a state shall ensure that the social, economic and political justice of all people are protected, which will ultimately ensure the welfare of the people by facilitating equal opportunity to all.1 This Article helps in attaining the following goals of sustainable development. SDG 1 aims to put an end to poverty; through this article, the state is aiming to achieve that goal by reducing income inequality and by promoting equal opportunity. SDG 3 aims to promote good health and well-being to all; this goal is also implicitly included in this article. By promoting the welfare of the people and by taking efforts to eradicate poverty, the state ensures the health and well-being of all people. In Air India Statutory Corporation v. United Labour the bench of the Supreme Court explained the concept of “social justice.” They stated that justice is a genus and social justice is a species. It is very important that in a society like ours, which is vast and complex, the need for safeguarding justice is mandated through our Constitution. If society believes that its justice is protected, then it creates a more equitable society that ensures long-term sustainability. ARTICLE 39 The Government of a state shall specifically focus their policy on ensuring that all people, [1] INDIA CONST, art 38 irrespective of gender, has an equal right to a sufficient living standard, and the resources of society are owned and controlled in a way that best satisfies the interests of society. The functioning of the economic structure does not lead to the accumulation of wealth at the expense of everyone; all persons, irrespective of gender, receive the same remuneration for the same amount of labour. workers' and women's health and strength, as well as the tender ages of children, are not mistreated, and that people are not forced by their financial necessity to take up careers that are not suited for their age or strength; that children are provided with the means to grow up in a healthy way and under conditions of freedom and dignity; and that childhood and youth are shielded from exploitation and material and moral abandonment.”2 This Article sets out the policies that need to be followed by the state to ensure social and economic justice, by giving more emphasis on concepts like equal opportunities for sufficient resources of livelihood and prevention of accumulation of resources and same level of wages for same level of work, fair distribution of resources and protection of children, men and women in terms of their health and strength. This Article is connected with sustainable development in the following ways. SDG 4(Quality education) is ensured by preventing exploitation of children by forcing them to enter into any employment out of necessity, SDG 8 is attained by providing equal pay for all irrespective of gender and SDG 10(Reduced inequalities) is achieved by distributing resources for the interest of public and also by preventing the accumulation of resources in hands of few, which is detriment to the society. In State of Tamil Nadu V. Abu Kaver Bai3 Here, the judiciary upheld the nationalisation of the Transport Service, stating that it was necessary to avoid the accumulation of wealth and to ensure the equitable distribution of resources for the common good. Article 39's principles are vital for achieving a Fair and impartial society, which matches the goals of sustainable development by promoting inclusive growth, reducing inequalities and promoting well-being for all. In the case of State of Bihar V. Kameshwar Singh,4 the Honourable Supreme Court held, any legislation that prevents the concentration of resources by some people is devised based on an egalitarian approach. ARTICLE 39A The Government of a state must make sure that no person is denied access to justice because [2] INDIA CONST, art 39 [3] (1984) 1 SCC 515 [4] AIR 1952 SC 252 of their inability to secure financial needs 5. This Article aligns with the goals of sustainable development in the following manner. By providing free legal aid this article promotes the development of marginalised section of society to come to the arena of justice even if they don’t have sufficient income, which ultimately helps to attain SDG 1 and SDG 10, apart from that Article 39A strengthens our legal system by developing the concept of inclusiveness which is vital for promoting peace and justice, hence this article will allows the state to achieve SDG

16. In Centre of Legal Research V. State of Kerala6 The Supreme Court held that states must

take measures to ensure the participation of voluntary organisations in promoting legal aid, and it should not be limited only to the traditional litigation program. Hence, the main objective of Article 39 A is to reduce inequality and promote fairness in equal justice, and all these objectives will strengthen the goals of sustainable development. To implement the concept of free legal aid and equal justice as mentioned under Article 39A, the Government has enacted legislation in 1987, which is called the Legal Services Authorities Act (1987). ARTICLE 40 "This Article enables village panchayats to operate as units of self-government; the Government of a State must take measures to organize them and grant them the authority and powers that may be required"7. This Article allows the state to delegate its power to the village panchayat for the proper management and administration of the communities, which helps in the attainment of SGD 11 (Sustainable Cities and Communities). This decentralised power will help in the proper governance of the institution as the local authorities will be able to deal with issues of their nearby community, and also help in the proper management of resources. This Article will also ensure the attainment of SDG 16 by enhancing local governance and empowering rural communities, which will help in building effective, accountable and inclusive institutions in all spheres. The 73rd and 74th amendments of the Constitution inserted the following articles from 243 Z to 243 ZG, which are the major steps taken by the State in the implementation of the directives regarding Article 40 of the Indian Constitution. Thus, Article 40 ensures that principles of sustainable development are aligned by inclusive participation, local governance, and community-led initiatives that address social, economic, and environmental issues at the grassroots level. [5] INDIA CONST, art 39A [6] AIR 1986 SC 1322 [7] INDIA CONST, art 40 ARTICLE 41 “The Government of a state must make an effort to assist all needy people, especially those who are in the stage of unemployed, aged or have any illness8 This Article directs the Government of a state to take steps to protect the right to work and education of the people within their economic capacity of each state. By ensuring the right to work is safeguarded, it promotes economic growth and employment opportunities for all, which ultimately helps in the attainment of SDG 8, and by providing the right to education, it promotes inclusive and equitable learning opportunities for all, which helps in the attainment of SDG 4 apart from that, vulnerable sections of society benefit from the public assistance that helps in the attainment of SDG 1 and SDG 3 by eradicating poverty and safeguarding health and wellbeing. In order to implement the concept of Article 41, the government has enacted various legislation and schemes like the Employee State Insurance Act (1948), old age pension schemes, disability schemes, rural employment guarantee schemes, etc. ARTICLE 42 “The government must provide for maternity leave and fair and humane working conditions.”9 A good working environment promotes economic growth and productivity of the employee, which results in the attainment of SDG 8. Similarly, by granting maternity relief to women, they will be able to balance both work and family responsibilities, which will eventually help in the attainment of SDG 5 (Gender Equality). Both good working conditions and maternity benefits will ensure good health and well-being, which is mentioned under SDG 3. In the landmark judgement of the Honourable Supreme Court in Vishaka and Others v. State of Rajasthan10 Various guidelines were set for the prevention of sexual harassment in the workplace, which include forming a committee by the employer, and that committee should be led by a woman and third-party members, apart from that, creating awareness about sexual harassment and measures to be adopted for reporting such events. Thus, Article 42 matches with sustainable development by correlating with gender equality, decent working conditions and good health, which promotes a fair and equitable society. ARTICLE 43 [8] INDIA CONST, art 41 [9] INDIA CONST, art 42 [10] AIR 1997 SC 3011 “In particular, the Government of a State must work to promote cottage sectors in rural areas and also ensure that every worker has access to a living wage and proper working conditions, which will allow them to lead a proper life by enjoying everything.11 By facilitating living wages, poverty can be reduced and the living standards of people can be improved, which helps in the attainment of SDG1(No Poverty) and by providing living wages, productive employment and decent work can also be ensured, which helps in the attainment of SDG 8. This article promotes cottage industries, which thereby reduce inequalities by providing employment opportunities and help in the attainment of SDG 10 (Reduced Inequalities). Apart from that, by fostering innovation and promoting sustainable industrialisation through cottage industries, this article helps in fulfilling SDG 9. So, to achieve the objective of this article, the parliament has passed “The Minimum Wages Act 1948.” The provision of this Act has been challenged in the Supreme Court in the case Bijay Cotton Mills Ltd vs The State of Ajmer. Here, the employers filed a petition stating that the Minimum Wages Act violates Article 19(1)(g) of the Indian Constitution, as they were not able to establish a business due to the requirement of providing minimum wages. The Supreme Court held that the Minimum Wages Act 1948 is not unconstitutional, and the provisions in this act are adopted by keeping the larger interests of the people. Md Imran Ahmad vs Government of NCT of Delhi & Anr on 18 September, 2023.12 Here, the High Court held that the Government of Delhi should not allow any employers to post the advertisement of job vacancies that do not comply with the provisions of the Minimum Wages Act 1948. So, by promoting the concepts related to fair wages, decent working conditions and promotion of rural industries, Article 43 supports the principles related to sustainable development. ARTICLE 43A.

“The Government of a state must make an effort to include the employees in the decisionmaking process of the establishment13 This article guarantees the inclusion of workers in the management decision-making process, facilitating cooperative decision-making that fosters dignified employment and equitable economic growth. This helps to attain SDG 8 by encouraging workers' participation; it improves industrial relations and contributes to sustainable industrial relations. In this way, it helps in the attainment of SDG 9 (Industry, Innovation, and Infrastructure). Apart from that, by involving workers in the management [11] INDIA CONST, art 43 [12] W.P.(C) 1922/2023 and CM APPL. 7341/2023 [13] INDIA CONST, art 43A process it promotes equality, thereby bridging the gap between the workforce and management, which in turn helps to attain SDG 10. Effective implementation of this article will facilitate equitable growth, social justice, and sustainability. ARTICLE 43B “The state will work to support cooperative societies' voluntary creation, independent operation, democratic governance, and expert management.”14 Cooperative societies ensure financial inclusion by providing credit to the poor people, which helps in the attainment of SDG 1 (No Poverty), and these cooperative societies are established for achieving various objectives, which include the promotion of agriculture, handicrafts, and small industries, which contribute to sustainable economic growth, and thus it results in the creation of job opportunities and fosters entrepreneurship, which in turn helps in the attainment of SDG 8. Apart from that, these cooperative societies will reduce the economic disparity between rural and urban areas by giving underprivileged sections of society access to the resources and economic opportunities, thereby resulting in the attainment of SDG 10 (Reduced Inequalities). By fostering economic community participation, cooperative societies help in building sustainable communities, and thus, it results in the attainment of SDG 11. Thus, Article 43B helps in achieving multiple SDGs, particularly in the context of rural development and inclusive growth. Based on this article, the state government has enacted various legislations for governing the cooperative societies of each state. For example, Kerala State Cooperative Societies Act 1969. ARTICLE 44 “The Government of a state must work to make sure that all Indian citizens are subject to a uniform civil code.”15 This article helps in reducing inequalities among members of society by creating a common code. Through the implementation of a uniform civil code, rules regarding marriage, succession, and divorce will be uniform for all religions. It will also ensure that all woman from various religions have equal rights in this way it helps top attain SDG 5 (Gender Equality) and it also helps to attain SDG 10(Reduced Inequalities) considering all people equal irrespective of their religion apart from that this article helps in the establishment of inclusive society by ensuring all citizens have access to consistent legal protection which ultimately helps [14] INDIA CONST, art 43B [15] INDIA CONST, art 44 in attainment of SDG 16. In Shabnam Hashmi V. Union of India16A conflict was there between personal law and the Juvenile Justice Act 2000; here, the honourable Supreme Court held that while personal law and its beliefs need to be respected, at the same time, it cannot be used to invalidate the options granted under this secular law. The enforcement of this article uniformly in India is still a long-standing debate and discussion; the major concern over this article is whether the personal law or the secular law shall prevail. ARTICLE 45 “The Government of a state must make sure that all children up to the age of six receive care and education.17 The main aim of this article is to provide education to all children irrespective of their socio-economic background. By providing free and compulsory education to all children, it improves their foundational skills and learning opportunities, which aligns with SDG 4 (Quality Education). To enforce this article and to increase the responsibility of the state in providing free and compulsory education. Apart from the free and compulsory education, the state will be able to reduce inequalities, as education is a tool that can be used to improve the living standard of people having low income and from rural and marginalised communities, which helps in the attainment of SDG 10 (Reduced Inequality). In Mohini Jain V. State of Karnataka18 Here the Supreme Court held that the right to education is a fundamental right and it indirectly supports Article 45. In Unni krishnan V. State of Andhra Pradesh19 in this case the judiciary recognised that the right to education will extend only up to the age of 14 and after that state’s obligation to provide education depends on its economic capacity this led to the 86th Constitutional Amendment in 2002, in which the provision under Article 45 was revised concerning providing early childhood education, and the responsibility of the state to provide free and compulsory education for the child between the ages of 6 and 14 years was included in Article 21A, which is a fundamental right at present. Article 45 primarily focuses on SDG 4, which gives quality education, and it is the foundation for achieving sustainable development. The Parliament has enacted the Right of Children to Free and Compulsory Education Act, 2009 (RTE Act) for enforcing the objective of this article. ARTICLE 46 [16] AIR 2014 SC 1281 [17] INDIA CONST, art 45 [18]AIR 1992 SC 1858 [19]AIR 1993 SC 2178 “The Government of a state must make an effort to satisfy the interests of the weaker section of society by ensuring that they receive proper education and their economic interest are safeguarded.”20 The main aim of this article is to uplift the marginalised section of society and to provide education for them. By promoting education among weaker sections of society, this article aligns with SDG 4 (Quality Education). Apart from that, this article also ensures the upliftment of weaker sections of society by providing them with quality education, resources and other opportunities. Thus, it results in the attainment of SDG 10 (Reduced Inequalities). In order to promote the socio-economic interests of weaker sections of society, reservations were given in the field of education and jobs. This reservation was not limited only to government institutions. After the hearing of the case, P. Inamdar V. State of Maharashtra,21 Parliament, through the 93rd Constitutional Amendment, inserted clause 5 to Article 15, which enabled the government to put reservations in private educational institutions even if they are not aided by the government or not. Thus, we can ensure that through these legislations and precedents, the state is committed to fulfilling the objectives mentioned under Article 46, through which we will be able to achieve inclusive development, justice and equality. ARTICLE 47 “One of the State's main responsibilities will be to improve public health, raise the standard of living and nutrition of its citizens, and work to outlaw the use of intoxicating beverages and harmful drugs other than for medical purposes.”22 This article ensures that the level of nutritional standard is improved, which helps in combating hunger and malnutrition; in this way, it helps to achieve SDG 2 (Zero Hunger). Measures taken by the state to prohibit the consumption of alcohol and drugs will help in the attainment of SDG 3. The directive issued by this article regarding the prohibition of the consumption of intoxicants promotes responsible consumption, which helps in the attainment of SDG 12 (Responsible Consumption and Production). In Ugar Sugar Works Ltd V. Delhi Administration & Ors,23 the Honourable Supreme Court held that there is no fundamental right that supports the trading of intoxicating substances such as alcohol. ARTICLE 48 “The Government of a state must make an effort to protect the agriculture and animals, especially [20] INDIA CONST, art 46 [21] AIR 2005 SC 3226 those which are giving milk.24 Promoting scientific agricultural systems and livestock management it ensures agricultural productivity and food security, and this will help in the attainment of SDG 2 (Zero Hunger). Apart from that, improved livestock breeding and sustainable farming practices contribute more to the production system, and they lower environmental deterioration. In this way, SDG 12 (Responsible Consumption and Production) is attained; this article indirectly supports the conservation of biodiversity through the prohibition of unnecessary cattle slaughter, which helps in fulfilling SDG 15 (Life on Land). This Article also helps in the attainment of SDG 3 (Good Health and Well-being) by ensuring high-quality livestock and sustainable farming practices, and public health is improved by providing safe and nutritious food. In Mohd Hanif Quareshi V. State of Bihar, the Honourable Supreme Court held that the ban on the slaughter of the cow is based on its utility, while interpreting Article 48, it is clearly stated that the ban is applicable for cows, calves and other animals that provide milk and act as draught relief animals. Therefore, Article 48 doesn’t prohibit the slaughter of all cows or cattle. The Supreme Court, therefore, held that the ban on the slaughter of bulls and buffaloes that stop yielding milk or work as draught cattle is not justified. Therefore, the Apex Court opined that a total ban slaughter of all cows doesn’t infringe Article 19(1)(g) of the Constitution. The decision in the above case was overruled in the State of Gujarat V. Mirzapur Moti Kureshi Kassab Jamat.25 Here, the Honourable Supreme Court held that the cattle used by humans since time immemorial should be treated compassionately, even if they are not useful. In order to strengthen the link between the SDGs and Article 48, the Government should provide education to the farmers and enhance research in sustainable agricultural technologies. ARTICLE 48A “The Government of a state must make an effort to protect the environment26. The main objective of this article is to safeguard the forest and wildlife and also to improve the environment; this aligns with SDG 13, which combats the changes in climatic conditions and their impact. The policies developed by India regarding afforestation, renewable energy and conservation are rooted in this constitutional principle. This article supports SDG 15 by promoting sustainable use of terrestrial ecosystems, managing forest resources, and stopping biodiversity loss. Various initiatives of the government, like Project Tiger, biosphere reserves, and wildlife sanctuaries, have been developed based on this. By protecting the environment, it inherently conserves water [24] INDIA CONST, art 48 [25] AIR 2006 SC 212 [26] INDIA CONST, art 48A resources; in this way, it aligns with SDG 6. As part of the production process, sustainable use of resources and minimal wastage are supported by Article 48A, emphasising environmental protection and thus helping in the attainment of SDG 12 (Responsible Consumption and Production). Though this Article emphasises the terrestrial ecosystem, it indirectly includes reducing pollution, which affects the aquatic ecosystem. In Sachidananda Pandey vs State Of West Bengal & Ors27 The Honourable Supreme Court held that while dealing with matters regarding the maintenance of ecology, the objective of Article 48A must be kept in mind. ARTICLE 49 “Every monument, location, or item of artistic or historic significance that has been declared by Parliament or under laws made by it must be protected from deterioration, disfigurement, destruction, removal, disposal, or export, as applicable.”28 This article helps in the preservation of cultural heritage, which plays an important role in making cities and communities sustainable; thus, it aligns with SDG 11. These protected monuments and heritage will become the focal point for sustainable tourism that creates jobs and promotes local culture and products, and thus, it helps in the attainment of SDG 8. Apart from that, by promoting cultural and historic landmarks, future generations will gain insights about their past cultural diversity, which helps in the attainment of SDG 4 (Quality Education). Apart from that, this article protects the monuments and other objects of historic and artistic importance and prevents illegal trade and export of these materials, aligning with SDG 16, which helps to combat cultural property theft and illegal trade. The implementation of Article 49 helps in strengthening India's commitment to cultural protection. ARTICLE 50 “The Government must make an effort to create a boundary between executive and judiciary.29 Through the separation of the judiciary from the executive, it establishes judicial independence, sustains the rule of law, and ensures impartial access to justice for all. This will help in the attainment of SDG 16 (Peace, Justice, and Strong Institutions). A Judiciary that is free from the influence of the executive will ensure the enforcement of laws that protect public spaces, prevent unlawful encroachments, and safeguard community rights, and in this way, it helps in the attainment of SDG 11 (Sustainable Cities and Communities). In order to give legislative support [27] AIR 1987 SUPREME COURT 1109 [28] INDIA CONST, art 49 [29] INDIA CONST, art 50 to this article, the Code of Criminal Procedure (at present BNSS) separates the executive magistrates and judicial magistrates in the criminal justice system. By proper and impartial governance, the provisions of Article 50 also support the other SDGs. In Union Of India vs Sankal Chand Himatlal Sheth And Anr30 The Honourable Supreme Court held that Article 50 is the Directive Principles of State Policies and that it is the responsibility of the state to keep the judiciary separate from the executive and public service. Therefore, it gave importance to protecting the judiciary from government interference. The doctrine of separation of powers gives protection to a person’s life from arbitrary rule and prevents organs of the government from taking the power of the other organs. This separation of powers will strengthen the democratic values of India, and it aligns with India's standards and global sustainability standards. ARTICLE 51 "The Government of a state must make an effort to maintain healthy relations between foreign nations, and in case of any issues, the disputes must be resolved through arbitration.31 This Article aims to reduce violence globally and encourages arbitration and dispute resolution, which ensures the rule of law and access to justice for all. By respecting international law, it strengthens global governance and in all these way it helps to attain SDG 16 ( Peace, Justice, and Strong Institutions) and by respecting various multilateral agreements and international treaties it reinforce the spirit of global partnerships for sustainable development and thus it aligns with the SDG 17 (Partnerships for the Goals) In Vishaka & Ors vs State Of Rajasthan & Ors32 In this case, the Honourable Supreme Court referred to the international convention (CEDAW), Convention on the Elimination of All Forms of Discrimination Against Women, to frame guidelines for sexual harassment, emphasising Article 51(c). Similarly, in Shayara Bano v. Union of India33 In this case, the Court relied upon international human rights principles to declare Triple Talaq as unconstitutional. Table 1 shows the summary regarding the relation between the Directive Principles and the Sustainable Development Goals. [30] 1977 AIR 2328 [31] INDIA CONST, art 51 [32] AIR 1997 SC 3011 [33] AIR 2017 SC 4609 ARTICLES SDG ATTAINED SDG1, SDG 3 SDG4, SDG8, SDG10 39A SDG1, SDG10, SDG16 SDG11, SDG16 SDG8, SDG4, SDG1, SDG3 SDG8, SDG5, SDG3 SDG1, SDG8, SDG10, SDG9 43A SDG8, SDG9, SDG10 43B SDG1, SDG8, SDG10, SDG11 SDG5, SDG10, SDG16 SDG4, SDG10 SDG4, SDG10 SDG2, SDG3, SDG12 reliable, sustainable, and modern energy for all" by 2030 and (SDG 14) is about "Life Below Water which aims to conserve and sustainably use the marine resources for sustainable development. Even though there are no explicit articles in DPSP that state about SDG 7 and SDG

14 still the legislature has passed various enactments to prevent water pollution and also to

regulate coastal zones. Hence, it is possible to state that in one way or another, efforts are made to achieve sustainable development goals. Even though these constitutional directives are helping to attain the goals of sustainable development, they still raise a question regarding how well these directives fulfil the needs of the present generation. Conclusion The main issue that was found in this DPSP is that the interpretation of the articles is quite vague and ambiguous. Each article focuses on certain elements like welfare, equality, environmental management, etc., but the way in which these elements can be achieved is not mentioned, and this will lead to multiple options for implementation; therefore, it creates ambiguity as it lacks uniformity. The concept of sustainable development mainly aims to meet the needs of the present generation without sacrificing those of future generations. But the issue is that these directive principles of state policies were adopted 74 years back, so the needs of the existing generation, as compared to the past one, have changed a lot, and these principles remain intact. Apart from that, the evolution of technology has not been reflected in any of the articles. Especially with regards to Article 48, which states that efforts should be made to prohibit the slaughter of cows and calves and other milch and draught animals, the main intention of this article was to promote the lives of animals that acted as a source of income for poor people and also to promote agriculture by using draught animals. At present, due to the advancement of technology, various agricultural practices can be performed by the use of technology, and by using various methods, the birth of cows and other milch animals can be increased, so it will not affect the income generation source of poor people. These directive principles can be enforced through legislation, so without legislation, it is not possible to achieve the objectives of all these articles, especially Article 44. Different legislations are enacted for various religions, and still, there is no uniformity in their implementation, which is causing severe injustice to a particular section of society. In India, which is a secular nation, each state has its laws with regard to the Uniform Civil Code, which elucidate that the needs of the present generation have changed a lot as compared to past ones, as they demand a uniform law in matters related to succession, marriage and divorce.

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