Consider the following statements: I. The 25th Constitutional Amendment Act (1971) inserted a new Article 31C, whose first provision was declared as invalid by the Supreme Court in the Keshavananda Bharati Case (1973). II. The Supreme Court in the Minerva Mills Case (1980) considered the extension of the scope of the second provision of Article 31C as invalid as well. III. The Supreme Court in the Minerva Mills Case (1980) has considered the importance of harmony and balance between Fundamental Rights and Directive Principles. IV. The present interpretation with respect to the Fundamental Rights and Directive Principles is the same reiteration of the first propounded by the Supreme Court in the Champakan Dorairajan case (1951). Which of the statement/statements given above is/are incorrect ?

Statement I is incorrect. The 25th Constitutional Amendment Act (1971) inserted Article 31C, which had two provisions. The first provision stated that laws to give effect to certain Directive Principles (Articles 39(b) and 39(c)) could not be deemed void on the ground of contravening Fundamental Rights under Articles 14, 19, and 31. The Supreme Court in the Kesavananda Bharati Case (1973) upheld the validity of the first provision but declared the second provision (which extended this protection to any law giving effect to any Directive Principle) as invalid. So, the first provision was declared valid, not invalid. Statement II is incorrect. The Supreme Court in the Minerva Mills Case (1980) considered the extension of the scope of the second provision of Article 31C as invalid, which was already declared in the Kesavananda Bharati Case. The Minerva Mills case primarily dealt with the interplay between Fundamental Rights and Directive Principles and the extent of parliamentary power to amend the Constitution. It reiterated that while the Directive Principles are important, they cannot override the basic structure of the Constitution, which includes the core of Fundamental Rights. Statement III is correct. The Supreme Court in the Minerva Mills Case (1980) indeed emphasized the importance of harmony and balance between Fundamental Rights and Directive Principles. It held that the Fundamental Rights and Directive Principles are complementary to each other and aim at establishing a welfare state. Neither can override the other. The court struck down Section 4 of the 42nd Amendment Act, which gave precedence to Directive Principles over Fundamental Rights. Statement IV is incorrect. The present interpretation with respect to Fundamental Rights and Directive Principles is not the same reiteration as that propounded in the Champakam Dorairajan case (1951). In Champakam Dorairajan, the Supreme Court initially adopted a rigid view, stating that Fundamental Rights would prevail over Directive Principles. However, subsequent judgments, particularly Kesavananda Bharati and Minerva Mills, have established a more harmonious and balanced approach, recognizing that both are essential for achieving the socio-economic goals of the Constitution.Therefore, statements I, II, and IV are incorrect.