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M.C. Mehta v. Union of India & Ors.

Interlocutory Application · Neutral citation not assigned (Interlocutory Application Nos.487 of 2017, 491 of 2017, 494 of 2017, 489 of 2017 & 495 of 2017 in W.P. (Civil) No.13029 of 1985)Decided 29 Mar 2017
Interlocutory Application Nos.487 of 2017, 491 of 2017, 494 of 2017, 489 of 2017 & 495 of 2017 in W.P. (Civil) No.13029 of 1985
Justice Madan B. Lokur · Justice Deepak Gupta

Background

This order arose within M.C. Mehta's long-running environmental writ petition, in applications filed by vehicle manufacturers and dealer associations seeking permission to sell and register, on and after 1 April 2017, two/three/four-wheelers and commercial vehicles that met the older Bharat Stage-III (BS-III) emission norms but not the new Bharat Stage-IV (BS-IV) norms taking effect that day. Manufacturers argued they had lawfully produced this BS-III stock before the deadline and should be allowed reasonable time to clear it, while the amicus curiae argued that allowing such sales would add to the already severe air pollution harming millions of people. The Solicitor General confirmed that BS-IV compliant fuel would be available nationwide from 1 April 2017, and that government refineries had spent roughly Rs.30,000 crore to produce it.

Decision Breakdown

The Supreme Court held that public health must take priority over the commercial interests of manufacturers and dealers in clearing unsold BS-III stock, noting that manufacturers had known since 2010 that the BS-IV switchover deadline was coming and had failed to act despite having the technology to comply earlier. The Court directed that (a) no BS-III (non-BS-IV-compliant) vehicle of any category could be sold in India by any manufacturer or dealer on or after 1 April 2017, and (b) all vehicle-registering authorities under the Motor Vehicles Act, 1988 were barred from registering any such non-compliant vehicle on or after that date, except where proof existed that the vehicle had already been sold on or before 31 March 2017. The Court indicated that detailed reasons for the order would follow separately, but the operative directions themselves were final and immediately binding.

Lesson Learnt

Once a regulatory deadline for a public-health measure like vehicle emission standards is fixed and well-publicized in advance, businesses cannot expect the courts to let them continue selling non-compliant stock simply because they manufactured it before the cutoff: courts will weigh collective public health above individual commercial loss.

Official source (sci.gov.in)View Judgment (PDF)

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