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

Writ Petition (Civil) · 2018 INSC 982Decided 24 Oct 2018
Writ Petition (Civil) No. 13029 of 1985
Justice Madan B. Lokur · Justice S. Abdul Nazeer · Justice Deepak Gupta

Background

This order arises within the decades-long M.C. Mehta environmental litigation. Earlier, the Court had directed that Bharat Stage IV (BS-IV) compliant vehicles become mandatory nationwide from 1 April 2017, and had refused manufacturers extra time to sell off non-compliant stock. The issue now was the next, stricter fuel standard, Bharat Stage VI (BS-VI), due nationwide from 1 April 2020: vehicle manufacturers, through the Society of Indian Automobile Manufacturers (SIAM), sought a grace window (three to six months) to sell leftover BS-IV vehicles manufactured before that date, relying on a government notification that allowed registration of such vehicles up to 30 June or 30 September 2020.

Decision Breakdown

The Court rejected the manufacturers' request for extra selling time, holding that allowing continued sale of more-polluting BS-IV vehicles when cleaner BS-VI technology is already available serves no legitimate purpose and cannot be justified on economic grounds, given the severe health and environmental costs of air pollution. It found the manufacturers' claim that vehicles contribute only marginally to pollution unpersuasive against expert committee data showing a significant share of particulate pollution came from vehicles. Because 31 March 2020 was still roughly a year and a half away, ample time for industry to transition, the Court held that the government's own rule (sub-rule 21 of Rule 115 of the Central Motor Vehicle Rules) permitting continued registration of old BS-IV stock after the cutoff was unconstitutional insofar as it extended the deadline, since it violated the right to life under Article 21 by prolonging avoidable pollution. Exercising its special constitutional power under Article 142, the Court "read down" that rule and directed that no BS-IV vehicle may be sold or registered anywhere in the country on or after 1 April 2020.

Lesson Learnt

When a government rule designed to protect public health is diluted in a way that benefits industry convenience over citizens' wellbeing, courts can step in and override even a formally issued rule to protect the constitutional right to a healthy environment: a reminder that environmental and health deadlines set to curb pollution are treated as firm, not negotiable.

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

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