Article 31 originally provided for the right to property as a Fundamental Right. However, over time, the need to reform land ownership and undertake public welfare projects often conflicted with this right. The government faced legal hurdles while acquiring private land for development purposes.
To resolve this, the 44th Constitutional Amendment Act of 1978 deleted Article 31 and transferred the right to property to Article 300A under Part XII. This change meant that the right to property was no longer a Fundamental Right, but merely a constitutional/legal right.
This shift allowed the government more flexibility in land acquisition, while still requiring that it be done by authority of law.