MC Mehta v. Union of India WP (C) 13029/1985
Article 21

Judgement Details
Court
Supreme Court of India
Date of Decision
4 November 2024
Judges
Justice Abhay Oka || Justice Ahsanuddin Amanullah || Justice Augustine George Masih
Citation
Acts / Provisions
Section 13(1)(ia), Hindu Marriage Act, 1955
Section 25, Hindu Marriage Act, 1955
Facts of the Case
This case, a continuation of the landmark MC Mehta v. Union of India litigation on environmental issues, focused on air pollution in Delhi NCR caused by stubble burning in Punjab and Haryana. The facts of the cases are as follows:
- Despite bans and orders under the Commission for Air Quality Management (CAQM) dated June 10, 2021, stubble burning persisted, contributing to severe air pollution in the region.
- Both Punjab and Haryana governments claimed reductions in cases of stubble burning and imposition of fines/penalties. However, the Supreme Court found the enforcement inconsistent and inadequate.
- The Court noted that governments were hesitant to prosecute farmers, citing possible political reasons.
Issues
- Whether stubble burning violates citizens' fundamental right under Article 21 to live in a pollution-free environment?
- Whether the governments of Punjab and Haryana failed to implement CAQM directives and penal provisions effectively?
- Should political considerations hinder enforcement of environmental laws?
Held
Stubble burning infringes on the fundamental rights of citizens. The state governments of Punjab and Haryana must take consistent penal actions against violators. The Court expressed dissatisfaction with the selective and inadequate enforcement of CAQM directives. The Union Government was directed to address Punjab’s request for funds to provide resources such as tractors, drivers, and diesel to small farmers, with a decision to be made within two weeks.
Analysis
- The Court’s emphasis on stubble burning as a violation of Article 21 highlights the judiciary’s proactive stance in recognizing pollution as a human rights issue.
- The directive to improve enforcement mechanisms reflects the need for better coordination among central and state governments.
- The acknowledgment of political interference underlines a key obstacle in enforcing environmental laws. The Court’s insistence on legal adherence reaffirms the non-negotiable nature of fundamental rights.
- By directing the Centre to consider funding proposals for farmers, the Court aims to address the root cause of stubble burning and encourage sustainable farming practices.