M C Mehta v. Union of India (CNG Vehicles Case)
A student-friendly explainer on how the Supreme Court used Article 21 to clean Delhi’s air—moving buses to CNG and tightening emission control.
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CASE_TITLE- Title: M C Mehta v. Union of India (CNG Vehicles Case)
- Citation: AIR 2002 SC 1696
- Court: Supreme Court of India
- Jurisdiction: India
- Author: Gulzar Hashmi
- PUBLISH_DATE: 05 Apr 2002
- LOCATION: India
- PRIMARY_KEYWORDS: CNG Vehicles Case, Article 21, clean environment
- SECONDARY_KEYWORDS: Delhi air pollution, emission norms, public transport
- Slug:
m-c-mehta-v-union-of-india-2002-cng-vehicles-case
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Quick Summary
The Supreme Court treated clean air as part of the right to life under Article 21. Seeing dangerous pollution in Delhi, the Court ordered a shift of public buses to CNG, tighter emission norms, and tougher enforcement. The ruling linked public health with environmental governance.
Issues
- Has Delhi’s air pollution reached a level that harms public health?
- Do existing laws require strong government action against vehicular pollution, especially from heavy vehicles and buses?
Rules
- Article 21, Constitution of India: Right to life includes the right to live in a clean and healthy environment—more than mere animal existence.
- Enforcement Tools: Writ jurisdiction under Article 32 enables directions to protect fundamental rights.
Facts (Timeline Style)
1998: Environmental lawyer M. C. Mehta approaches the Supreme Court under Article 32 due to alarming air pollution in Delhi.
Data show heavy vehicle emissions—PM, NOx, CO—raising risks of asthma, heart disease, and other illnesses.
Existing measures were patchy and slow; buses still ran on diesel, enforcement was weak.
Mehta sought court-monitored steps: CNG transition, better public transport, and strict emission checks.
Arguments
Petitioner (M. C. Mehta)
- Pollution levels violated the right to life under Article 21.
- Diesel buses and heavy vehicles were major contributors.
- Requested city-wide CNG conversion and strict emission enforcement.
Respondents (Union/Authorities)
- Pointed to existing steps but faced capacity and timeline constraints.
- Raised implementation challenges for fleet conversion.
Judgment
- Core Holding: Clean and healthy environment forms part of Article 21’s right to life.
- CNG Mandate: All Delhi diesel buses to convert to CNG by 31 March 2002; non-compliance attracted daily fines.
- Enforcement: Stronger checks of emission norms; improvement of public transport was directed.
- Public Health Focus: Court treated vehicular emissions as an imminent health risk needing immediate action.
Ratio Decidendi
Article 21 protects a dignified life, which includes clean air. Courts can order practical, time-bound environmental measures—like shifting public fleets to cleaner fuel—to secure that right.
Why It Matters
- Linked human health directly with environmental quality under fundamental rights.
- Pushed large-scale fuel transition in a megacity.
- Became a reference point for clean-transport policy and enforcement.
Key Takeaways
- Clean air = part of Article 21.
- CNG mandate for Delhi buses with penalties.
- Stricter emission checks and public transport upgrades.
- Court can set time-bound environmental directions.
- Vehicular emissions treated as a rights issue.
- Model for other Indian cities and cases.
Mnemonic + 3-Step Hook
Mnemonic: “AIR-CNG-ACT”
- AIR: Clean air is part of life under Article 21.
- CNG: Buses must switch to CNG by a firm deadline.
- ACT: Enforce emission norms and improve public transport.
IRAC Outline
Issue
Whether Delhi’s air crisis required court-mandated action and whether Article 21 supports clean-air measures against vehicular pollution.
Rule
Article 21 protects a dignified life, which includes a healthy environment; the Supreme Court may give directions under Article 32.
Application
Evidence of harmful emissions from diesel buses justified a time-bound CNG shift and strict enforcement to protect public health.
Conclusion
Court ordered CNG conversion, penalties for delay, and stronger emission control to secure the Article 21 right.
Glossary
FAQs
- CASE_TITLE
- M C Mehta v. Union of India (CNG Vehicles Case)
- PRIMARY_KEYWORDS
- CNG Vehicles Case, Article 21, clean environment
- SECONDARY_KEYWORDS
- Delhi air pollution, emission norms, public transport
- PUBLISH_DATE
- 2002-04-05
- AUTHOR_NAME
- Gulzar Hashmi
- LOCATION
- India
- slug
- m-c-mehta-v-union-of-india-2002-cng-vehicles-case
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