What is MC Mehta v. State of Tamil Nadu (1996) about?

The case deals with child labour in hazardous industries, especially in the match and fireworks factories of Sivakasi in Tamil Nadu. The Supreme Court held that employing children in such work violates their fundamental rights under Article 24 and Article 21 of the Constitution.

Which constitutional provisions did the Supreme Court rely on in this case?

The Court relied mainly on Article 24, which bans employment of children below 14 years in factories, mines and other hazardous work. It also read Article 21, the right to life with dignity, and the Directive Principles in Article 39(e) and (f), to protect children from exploitation and to secure their education and health.

Why is MC Mehta v. State of Tamil Nadu important for law students?

This case is important because it turns child labour from a mere policy problem into a clear fundamental rights issue. It also shows how Public Interest Litigation can be used to protect vulnerable groups and how the Supreme Court can frame detailed, practical directions for the government to follow.

What did the Supreme Court order the government to do in the MC Mehta case?

The Court ordered state governments to survey and withdraw children from hazardous industries, set up a Child Labour Rehabilitation-cum-Welfare Fund financed by fines on defaulting employers, provide education to rescued children and arrange alternate employment or income support for an adult member of the child’s family.

MC Mehta v. State of Tamil Nadu (1996) Child Labour

MC Mehta v. State of Tamil Nadu (1996)
Supreme Court on Child Labour & Article 24

Easy, classroom-style notes on the child labour judgement that turned children’s work in hazardous factories into a clear fundamental rights issue.

Supreme Court of India 1996 Fundamental Rights of Children 8 min read

Author: Gulzar Hashmi Location: India Published: 22 Nov 2025

Quick Summary

PRIMARY_KEYWORDS: MC Mehta v. State of Tamil Nadu case summary, child labour, Article 24, Supreme Court of India, Sivakasi child labour

SECONDARY_KEYWORDS: Article 21, Article 39(e) & (f), Public Interest Litigation, children’s right to education, hazardous industries, fireworks factories, welfare fund, Indian Constitutional Law

In this Public Interest Litigation, environmental lawyer M.C. Mehta approached the Supreme Court against large-scale child labour in match and fireworks factories of Sivakasi in Tamil Nadu. Children as young as 6–7 years were working in dangerous conditions.

The Supreme Court treated child labour in hazardous industries as a direct violation of Article 24 (prohibition of child labour in factories) and also linked it with Article 21 (right to live with dignity, health and education). The Court issued detailed directions: survey and withdraw children from hazardous work, create a Child Labour Rehabilitation-cum-Welfare Fund financed by employers’ fines, and arrange education and family support.

This case converted child labour from a “poverty problem” into a clear fundamental rights problem and became a key authority for exam answers on child rights, Directive Principles and PIL.

Issues Before the Court

Whether employing children below 14 years in hazardous industries like match and fireworks factories violates Article 24 of the Constitution.
Whether such child labour also violates Article 21, that is, the child’s right to live with dignity, health and basic education.
How should the Court direct the State to eliminate child labour while also considering the poverty and livelihood of the children’s families.
What practical remedies and enforcement mechanisms should be created to make child labour laws effective on the ground.

Rules & Legal Provisions

Article 24 – Prohibits employment of children below 14 years in any factory, mine or other hazardous employment.
Article 21 – Right to life includes a right to live with dignity, which covers health, safety and access to education.
Article 39(e) and (f) – Directive Principles that tell the State to protect children from abuse and to ensure that their childhood is safe and meaningful.
Child Labour (Prohibition and Regulation) Act, 1986 – Prohibits child labour in specified hazardous processes and regulates their working conditions in other sectors.
International Conventions and Child Rights Instruments – India’s commitments at the global level, which support the need to end hazardous child labour.

Facts – Timeline Style

Timeline

Background – Child Labour in Sivakasi

In Sivakasi (Tamil Nadu), thousands of children were working in match and fireworks factories. Many were below 14 and faced serious risks like burns, explosions and toxic fumes.
Poverty & Lack of Education

Families were extremely poor. Parents sent children to work to support basic survival. Children missed school and were trapped in a cycle of low-paid, hazardous work.
Existing Laws but Weak Implementation

Laws like the Child Labour Act existed on paper, but enforcement was very weak. Inspections were limited and penalties were rare.
PIL by M.C. Mehta

Public interest lawyer M.C. Mehta filed a petition under Article 32 of the Constitution in the Supreme Court, seeking protection of child workers and proper enforcement of the law.
Supreme Court’s Response

The Court treated the case not just as a local Sivakasi problem but as a nationwide child labour issue. It ordered enquiries and sought suggestions on how to protect children and support their families.

Arguments – Appellant vs. Respondent

Petitioner – M.C. Mehta

Employment of children below 14 years in hazardous industries is a clear violation of Article 24.
Child labour destroys the child’s dignity, health and safety, and therefore violates Article 21.
Children are denied basic education and remain stuck in lifelong poverty and exploitation.
India has international obligations on child rights, but implementation is weak and needs judicial push.
The State is failing to enforce its own laws and Directive Principles that protect children from exploitation.

Respondent – State of Tamil Nadu

The State admitted that child labour exists, but argued that instant elimination is not practical.
Many families depend on the child’s income; a sudden ban might make them more vulnerable.
The State pointed to existing welfare schemes and regulations, claiming that change must be gradual.
Economic realities should be taken into account while framing any strict directions to abolish child labour.

Supreme Court Judgment & Directions

Landmark Ruling

Supreme Court judgement concept illustration for MC Mehta child labour case

The Supreme Court gave a strong and practical ruling. It held that employing children in hazardous industries is not only illegal under statutory law but is also a direct violation of Articles 24 and 21 of the Constitution.

Key Directions Issued by the Court

Nationwide Survey & Withdrawal: State governments must conduct a survey to identify children working in hazardous industries and withdraw them immediately from such work.
Child Labour Rehabilitation-cum-Welfare Fund: Every employer who illegally employs a child must pay ₹20,000 per child as compensation. This money will go into a special welfare fund used for the child’s education and rehabilitation.
Family Support / Adult Employment: Where a child is withdrawn from hazardous work, one adult member of the family should, as far as possible, be given alternate employment or monetary support to reduce the income loss.
Free & Compulsory Education: The State must ensure that rescued children receive free and compulsory education, preferably in residential or special schools where needed.
Monitoring & Follow-up: Authorities must regularly monitor implementation and send reports, so that the Court’s orders do not remain only on paper.

Ratio Decidendi

Article 24 is absolute for hazardous work: Children below 14 cannot be employed in factories, mines or similar hazardous industries under any excuse, including poverty.
Article 21 includes child dignity, health and education: The right to life for a child means a life with basic education, safety and development, not a life spent in dangerous factories.
State must actively remove children from hazardous labour: It is not enough to have laws; the State has a positive duty to identify, withdraw and rehabilitate child workers.
Welfare plus enforcement model: The Court balanced child rights with family poverty by combining penalties on employers with welfare measures for families.

Why This Case Matters

It converts child labour from a general social problem into a constitutional wrong.
It shows how PIL can be used to protect vulnerable groups like children even when they cannot speak for themselves.
It links fundamental rights with Directive Principles, turning moral duties into enforceable directions.
It gives a practical blueprint for governments: survey, withdraw, create welfare funds, educate and support families.
For students, it is a must-quote case in answers on child labour, Article 24, Article 21, social justice and PIL.

Key Takeaways for Exams

Use as leading case for Article 24 and children’s rights.
Remember the ₹20,000 per child fine and the Child Labour Rehabilitation-cum-Welfare Fund.
Mention the balance between rights and poverty – Court protected children but also thought about family income.
Connect with Article 21 + Article 39(e), (f) to show integrated reading of rights and DPSPs.
Show that the Court treated child labour as a national issue, not just a local Sivakasi problem.

Mnemonic & 3-Step Memory Hook

Mnemonic: “SAFE CHILD”

S – Survey all hazardous industries for child workers.
A – Give an Adult in the family employment/support.
F – Fund: ₹20,000 per child to welfare fund.
E – Education must be free and compulsory.
CHILD – Court Holds Illegal Dangerous labour.

3-Step Hook to Recall the Case

Think of a small child in a fireworks factory – unsafe and smoky.
Imagine the Supreme Court judge hitting the gavel and shouting: “No child below 14 in hazardous work – Article 24!”
Picture a piggy bank named ‘Child Welfare Fund’, filled with ₹20,000 coins from each defaulting employer, paying for the child’s school bag and books.

IRAC Outline – MC Mehta v. State of Tamil Nadu

I – Issue

Whether employment of children below 14 years in hazardous industries like match and fireworks factories violates Article 24 and Article 21 of the Constitution and what measures should be taken to protect such children.

R – Rule

Article 24 absolutely prohibits child labour in factories, mines and hazardous work. Article 21 guarantees a dignified life including health and education. Article 39(e), (f) and the Child Labour Act guide the State’s duty to keep children away from exploitation.

A – Application

The Court examined the situation in Sivakasi, noted the presence of very young children in dangerous work and found that laws were not effectively implemented. It applied Article 24 and Article 21 together with Directive Principles to hold that the State must actively remove children from hazardous jobs and ensure their rehabilitation and schooling.

C – Conclusion

The Court held that child labour in hazardous industries is unconstitutional and directed a detailed scheme: nationwide survey and withdrawal, creation of a Child Labour Rehabilitation-cum-Welfare Fund with employer fines, provision of free education and support to the children’s families. This became a leading authority on children’s rights and State responsibility.

Glossary – Important Terms

Hazardous Industry: A type of work or factory where there is a serious risk to life, health or safety, for example, fireworks, chemicals or mining.
Child Labour: Work done by children that is harmful, interferes with their education or exploits their weakness and poverty.
Public Interest Litigation (PIL): A case filed in court to protect public interest, especially for people who cannot approach the court on their own.
Directive Principles (DPSPs): Policy directions in Part IV of the Constitution which guide the State to create a just and fair society. They are not directly enforceable, but courts often use them to interpret fundamental rights.
Rehabilitation: Steps taken to help a child move out of harmful work and into a safer life, including education, health care and family support.

FAQs – Student Doubts Answered

The case is mainly about child labour in hazardous industries, especially in the match and fireworks factories of Sivakasi in Tamil Nadu. The Supreme Court held that such employment of children below 14 years violates Article 24 and also affects their right to a dignified life under Article 21.

The Court understood that many families were poor. So it did not stop at banning child labour. It ordered that a fine of ₹20,000 per child must be collected from the employer into a welfare fund and, as far as possible, an adult member of the family should be given alternate employment or financial support. This way, the family income could continue while the child went to school.

You can quote this case whenever you write about Article 24, child labour, children’s right to education, PIL or the link between fundamental rights and DPSPs. In a short answer, mention: hazardous child labour, Article 24 + 21, the ₹20,000 fine and the welfare fund, and the Court’s concern for both children’s rights and family poverty.

The Court clearly said that child labour is a national issue. Although the facts came from Sivakasi, the directions were addressed to all States in India. So this judgement has a wider effect and is relevant for child labour in other hazardous industries across the country.