In Property Owners Association v State of Maharashtra, the SC held that all private properties cannot form part of the 'material resources of the community' under Article 39(b) of the Constitution. 

• It over ruled Judgment in State of Karnataka v. Ranganatha Reddy (1978) and Sanjeev Coke Manufacturing Company vs. Bharat Coking Coal Ltd. and Anr. (1983) case which held that private properties can be regarded as community resources.

Key Observations 

• Scope of Article 39(B): Ambit of "material resource of community" must be based on the nature of the resource, the scarcity of the resource, etc. 
  • The Public Trust Doctrine (ensure that everyone gets equal access to all natural resources without any discrimination) can also be applied here.
• Upheld Keshavananda Bharati verdict (1973): That allowed for the judicial review of the laws enacted as per Article 31C (refer to box). 
• Approach for Economic Policies: The judgment stressed that governments should be allowed to adapt economic policies according to changing needs, rather than imposing a fixed economic doctrine.