M. C. MEHTA versus UNION OF INDIA & ORS.

M. C. MEHTA versus UNION OF INDIA & ORS.

Sub-rule 21 of Rule 115, Central Motor Vehicle Rules, 1989, is violative of Article 21 insofar as it permits registration of BS-IV vehicles beyond 31.03.2020, adversely affecting public health; thus, it must be read down to prohibit sale or registration of BS-IV vehicles in India after 01.04.2020. Health and environment are to be prioritised over manufacturers’ economic concerns.

Parties
Petitioner: M. C. Mehta; Respondent: Union of India & Ors.
Jurisdiction
India
Judgment Date
24 October 2018
Procedural Posture
Writ Petition (civil) / Final Judgment
Outcome
sub-rule 21 of Rule 115 is read down; sale or registration of BS-IV vehicles prohibited after 01.04.2020
Legal Topics
Vehicular Pollution, Emission Standards, Public Health, Interpretation of Rules, Fundamental Rights (article 21)
Environmental Law Constitutional Law Administrative Law Vehicular Pollution Emission Standards Public Health Interpretation of Rules Fundamental Rights (article 21)

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Parties

M. C. Mehta

Petitioner

Union of India & Ors.

Respondent

Procedural Posture

Writ Petition (civil) / Final Judgment

Legal Issues

  1. 1 Whether BS-IV compliant vehicles should be permitted to be sold or registered in India after 31.03.2020
  2. 2 Whether sub-rule 21 of Rule 115 of Central Motor Vehicle Rules, 1989 is violative of Article 21 of the Constitution by extending registration time beyond 31.03.2020

Ratio Decidendi

Sub-rule 21 of Rule 115, Central Motor Vehicle Rules, 1989, is violative of Article 21 insofar as it permits registration of BS-IV vehicles beyond 31.03.2020, adversely affecting public health; thus, it must be read down to prohibit sale or registration of BS-IV vehicles in India after 01.04.2020. Health and environment are to be prioritised over manufacturers’ economic concerns.

Court Disposition

sub-rule 21 of Rule 115 is read down; sale or registration of BS-IV vehicles prohibited after 01.04.2020

Orders

  • No motor vehicle conforming to BS-IV emission standard shall be sold or registered in India with effect from 01.04.2020.
  • Automobile manufacturers must comply and cannot sell or register non-BS-VI vehicles after this date.