Horizontal vs Vertical Application of Rights

A separate but related distinction concerns against whom a right can be enforced.

• Vertical application is the default and classical model: a Fundamental Right restrains the State (as defined in Article 12) in its dealings with individuals — the individual stands "below" the State and the right operates "vertically" upward against it. Most of Part III — Articles 14, 19, 21, and so on — is vertical in this sense: you sue the government, a public authority, or a State instrumentality, not your neighbour or your employer, for its violation.
• Horizontal application is the exception, where a Fundamental Right is enforceable even against private individuals or non-State actors. Indian constitutional law recognises a handful of expressly horizontal rights: Article 15(2) (non-discrimination in access to shops, restaurants, wells, roads), Article 17 (abolition of untouchability), Article 23 (prohibition of forced labour/trafficking), and Article 24 (child labour) are all enforceable directly against private parties, not merely the State. Courts have also horizontally extended protection in specific contexts through directions binding private employers — the Vishaka guidelines against workplace sexual harassment (1997) being the leading example, later codified into the POSH Act, 2013, and squarely binding private workplaces, not just government offices.

The general rule to remember: Part III is primarily a vertical charter (a shield against the State), with Articles 15(2), 17, 23 and 24 as the express horizontal exceptions, supplemented by judge-made horizontal extensions in specific welfare and dignity contexts.