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State of Madhya Pradesh v. Centre for Environment Protection Research and Development & Ors.

Civil Appeal · 2020 INSC 516Decided 28 Aug 2020
Civil Appeal Nos. 8932-8933 of 2015
Justice Arun Mishra · Justice Indira Banerjee

Background

In a public interest case about vehicular pollution in Indore, the National Green Tribunal (NGT), Bhopal, directed the Madhya Pradesh government to ensure vehicles without a valid "Pollution Under Control" (PUC) certificate would have their registration suspended/revoked, and ordered that such vehicles additionally be denied fuel by any petrol pump or dealer. When the State sought review and more time to comply, the NGT granted 60 more days but also ordered the State to deposit Rs. 25 crores as security, failing which the amount would be used for environmental purposes. The State challenged both orders before the Supreme Court.

Decision Breakdown

The Supreme Court held that the NGT did have the power to direct strict enforcement of the existing Motor Vehicle Rules requiring a valid PUC certificate, including suspension or cancellation of registration for non-compliance, since this flows from the Air Act, the Environment Protection Act and the Motor Vehicle Rules. However, the Court held the NGT had no legal basis to direct fuel dealers to deny fuel to such vehicles (since no rule provides for this penalty) or to direct the State to deposit Rs. 25 crores as a security against compliance, since the NGT Act's own penalty provisions (for non-compliance with its orders) already cover this and do not contemplate a security deposit. The appeals were allowed only to strike down these two extra directions, while the core requirement of strictly enforcing the PUC rules was upheld.

Lesson Learnt

Even tribunals created for a specific, important public purpose (like environmental protection) can only exercise the powers actually granted to them by statute: they cannot invent new forms of punishment or financial security that the law does not provide for, however well-intentioned the goal.

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

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