Case Analysis: MC Mehta v. Union of India (2002) | CNG Vehicle Case

The 'Case Analysis: MC Mehta v. Union of India (2002)' highlights the judiciary's active role in environmental protection. The apex court mandated the use of CNG as an alternative to diesel, thereby aiming to improve air quality and mitigate the health hazards caused by vehicular pollution.

Case Title: M.C. Mehta v. Union of India

Court: Supreme Court of India

Citation: 2002 (2) SCR 963

Judges: Justice B.N. Kirpal, Justice V.N. Khare and Justice Ashok Bhan

Date of Judgment: 05/04/2002

Introduction

The Judiciary has always been crucial to the effort to preserve the environment. In the area of environmental law, several cases have produced significant rulings. Indian Constitution’s Article 48A also refers to the need to conserve the environment. Article 51-A (g) states that it is the responsibility of every citizen to protect and improve the natural environment including forests, lakes, rivers and wildlife, and to have compassion for living creatures; in addition to Article 48A. Following the 42nd Amendment, these articles were incorporated into the Constitution.

The Environment (Protection) Act, of 1986, and the Water (Prevention and Control of Pollution) Act, 1974 are just a couple of the Acts and laws that guarantee environmental protection. Among these are the Indian Forest Act, the Wildlife Protection Act and a few more. Additionally, a number of these acts went through modifications. 

Another name for this is the 'CNG Vehicle Case'. In this situation, Delhi’s air pollution levels were a big problem. 10,000 people were estimated to die annually in the capital of the nation as a consequence of air pollution, according to a survey that was done.

However, the 'CNG Vehicles Case' is the name given to the legal case M.C. Mehta v. Union of India. In India, there is a noteworthy environmental case. In this instance, the Indian Supreme Court issued orders requiring the utilization of compressed natural gas (CNG) around public vehicles and controlling the flow of commercial cars through the city to reduce air pollution in the Delhi-NCR area.

The court’s ruling attempted to lessen the harmful impacts of air pollution on human health and enhance the region’s air quality. This case demonstrates the judiciary’s responsibility for environmental preservation and is frequently used as an illustration of Indian judicial activism for environmental causes.

The right to life, including the right to a hygienic and healthful environment, is guaranteed by Article 21 of the Constitution. On numerous occasions, the Supreme Court has stood up to defend this right. In this instance, the court has taken an aggressive stance by ordering the conversion of all diesel buses to CNG.

Despite the existence of sufficient regulations, the court’s worry regarding the level of pollution in the air of Delhi, the Indian capital, increased as a result of the enforcement agencies’ lack of effort. Articles 39, 47, and 48-A impose obligations on the state to safeguard public health, enhance environmental protection, and safeguard individual health. According to Delhi research, air pollution-related issues claim the lives of 10,000 people annually, or an individual every hour.

Facts of the Case

1. In 1985, environmental activist M. C. Mehta launched a Public Interest Litigation (PIL) contrary to the Union of India at the Hon’ble Supreme Court.

2. Mr Mehta claimed that the capital city’s air pollution levels have significantly grown and that the people of Delhi were at risk from unregulated air pollution’s detrimental effects on their health.

3. The Bhure Lal Committee was established by Section 3 of the Environmental (Protection) Act, 1986, during this case. It advised switching to the CNG method and gave the go-ahead to phase out non-CNG buses. The government overstated the financial difficulties in implementing the court’s decisions, but the court did not take this into account based on the committee’s conclusions.

4. The court’s primary goal was to strike an equilibrium between the city’s unimpeded transportation system and environmental protection from damage.

5. Ultimately, the Apex court ruled in 2002 that the transportation industry needed to have access to CNG.

Legal Provisions

The Supreme Court of India made several rulings and regulations about CNG vehicles. The following were the main legal provisions involved :

• The Constitution of India: Invoking fundamental rights, particularly the right to life (Article 21), highlights the significance of safeguarding the environment and the health of all people.
• The Environment Protection Act, 1986: The national government is given the authority to take action to safeguard and enhance the environment under this act. To combat the problem of air pollution, the Supreme Court issued several instructions, which included requiring the use of compressed natural gas (CNG) in public vehicles and controlling the entry and exit of commercial vehicles into Delhi and the National Capital Region.
• The Motor Vehicle Act, 1988: To reduce air pollution, provisions about vehicle registration, emission requirements, and regulatory authority for car-related concerns were reviewed.

Issues Raised

M.C. Mehta v. Union of India focused on the CNG vehicle case, primarily addressing the concerning degrees of air pollution in Delhi and the National Capital Region (NCR) caused by vehicle emissions. The case specifically addressed the following issues:

1. Determining whether the elevated air pollution levels in Delhi were primarily caused by vehicular emissions and, if so, outlining directives for the Supreme Court to address this concern effectively.
2. Addressing the need to identify, preempt, and combat the fundamental factors contributing to environmental deterioration, emphasizing the responsibility of both the State Government and statutory bodies in this regard.
3. Recognizing the urgency of taking proactive measures to prevent environmental degradation without delay, even in the absence of exhaustive scientific knowledge, particularly when the risk of irreversible harm and significant environmental damage is imminent.

Arguments from Both the Sides

Petitioner:

1. The petitioner claimed that Delhi’s rising pollution levels have been harmful to people’s health.
2. To protect public health, the government was obligated by the environmental laws in place to take action to reduce air pollution.
3. He further said that the Court recognized in 1990 that the primary cause of the air pollution issue was heavy vehicles, such as trucks, buses, and defence vehicles, based on the Ministry of Environment and Forests (MoEF) assessment.
4. The petitioner therefore highlighted the negative effects of air pollution on people’s health, including respiratory conditions, heart problems, and other conditions that afflict locals, particularly the elderly and children who are most vulnerable.

Respondent:

1. Delhi Transport Corporation’s former chairman and managing director, R Mehta, claimed that the switch to CNG was a legally driven approach which severely impacted the average citizen.
2. To obtain CNG, drivers of buses had to travel 40 kilometres and stand in line for a long time in front of CNG distribution stations. Because of this, there weren’t many buses available for customers to board.
3. The court’s rulings forced the DTC to purchase 2000 buses within 14 months. Nonetheless, CNG buses were 1.6 times more expensive than diesel buses. Additionally, the cost of establishing CNG stations was high.
4. The general public, who relied on public transportation, was severely impacted.
5. Since the proprietors of private buses had to make significant financial commitments to switch to CNG, there was an equity issue. They contended that other vehicles contributed significantly more to Delhi’s air pollution than did private buses.

Judgment

The Supreme Court's verdict on rising air pollution is undeniably a turning point in Indian judicial historical events. Following a thorough hearing on every detail, the court used important legal innovations—such as the recognition of health as a component of the right to life and the application of the polluter pays principle to the penalization of polluting technologies—to precisely map out a path of action for a government that is evasive and inconsistent.

In the landmark decision, the Supreme Court of India has ordered diesel buses to be removed from Delhi’s streets gradually. The Supreme Court of India imposed a corrective duty on the state as per Articles 39(c), 47 and 49(a) of the Indian constitution to improve the environment and public health of the citizens.

Further, the Supreme Court directed the Delhi Government to create a high-power committee to deal with the problem of air pollution in Delhi. In his response, the government created the Bhure Lal Committee by the Environmental (Protection) Act, 1986, section 3. It advised switching to CNG mode and gave the go-ahead to phase out non-CNG buses. The government overstated the financial difficulties in implementing the court’s decisions, but the court has not taken this into account based on the committee’s conclusions.

About the judgement of the case, the Supreme Court further stated that all public transport should make use of CNG for the movement of their vehicles in the state. The ruling ordered Pollution Under Control (PUC) facilities to be established to periodically inspect and certify cars for compliance with emissions regulations.

The court mandated that commercial cars that travel within Delhi be regulated, especially those that do not comply with emission requirements. This action was taken to manage and lessen pollution coming from the transportation industry. The apex court has considered practical approaches to provide this landmark judgment.

Conclusion

In this case, as well as many other environmental cases, the Supreme Court has taken a very proactive stance in support of citizens’ rights to an environment that is healthy and clean. The public interest should not be subordinated to economic concerns, the court had declared. In this case, the court took a strong stance and demonstrated how Indian courts are progressively using a realist approach to case resolution. The court also expressed the court’s concern for safeguarding the environment and, by extension, the public’s health.

But for the court to make the right ruling in situations involving environmental contamination and other social difficulties, certain materials must be presented to it. Law enforcement cannot be applied abstractly. In addition, social and economic considerations must be made. The decision’s implementation, effects on people’s lives and cause and effect must all be addressed.

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