In Brief
The Supreme Court in a 7-judge majority ruled that Article 31C survives in its unamended form (as upheld in Kesavananda Bharati) following Minerva Mills' invalidation of the Forty-Second Amendment, since the original text is revived when substitution amendments are struck down. On Article 39(b), while privately owned resources may theoretically be "material resources of the community," not all private property automatically qualifies. The Court rejected the expansive Krishna Iyer interpretation followed in Sanjeev Coke. Qualification requires context-specific analysis considering resource nature, community impact, scarcity, and concentration risks. "Distribution" has broad meaning including state acquisition/nationalization, provided it subserves common good. The decision limits state power to acquire private property under Article 39(b) while respecting property rights under Article 300A.
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