M.C. Mehta v State of Tamil Nadu & Others
M.C. Mehta v. State of Tamil Nadu & Others
1. Court:
Supreme Court of India
2. Background / Facts:
This case arose out of a public interest litigation (PIL) filed by M.C. Mehta, a renowned environmental lawyer and activist.
The petition highlighted the issue of pollution caused by tanneries located in Tamil Nadu, particularly in and around Chromepet and Ambattur areas.
Tanneries were discharging untreated industrial effluents into water bodies, severely polluting the environment and affecting the health of the residents.
The State Government of Tamil Nadu and various industries were impleaded as respondents.
The petitioner sought directions to control pollution and protect the environment under the Environmental Protection Act, 1986, and other environmental laws.
3. Issues:
Whether the State of Tamil Nadu and polluting industries violated environmental laws by discharging untreated effluents.
The adequacy of action taken by the State Government to control pollution.
The responsibility of the industries and the State to prevent environmental degradation.
The scope of judicial intervention in environmental protection.
4. Judgment:
The Supreme Court held that the right to life under Article 21 of the Constitution includes the right to a clean and healthy environment.
It was held that pollution from tanneries was a violation of fundamental rights of residents and warranted strict action.
The Court issued directions for the closure or relocation of polluting tanneries which were not complying with pollution control norms.
It emphasized the “polluter pays” principle, holding polluting industries responsible for the cost of pollution control.
The State was directed to enforce pollution control measures effectively and to monitor compliance strictly.
The Court also highlighted the precautionary principle, mandating industries to take preventive measures against environmental harm.
The judgment reinforced the role of the judiciary in protecting the environment and ensuring enforcement of environmental laws.
5. Legal Principles Established:
Right to Environment as Part of Right to Life:
The right to a clean environment is an integral part of the fundamental right to life under Article 21.
Polluter Pays Principle:
Polluters are liable to bear the cost of pollution control and compensation for damage caused.
Precautionary Principle:
Industries must take preventive steps to avoid environmental damage, even if scientific certainty is not absolute.
Judicial Activism in Environmental Protection:
Courts can intervene to enforce environmental laws and direct actions for protection and remediation.
State’s Duty:
The State has an obligation to enforce environmental laws and protect citizens’ right to a pollution-free environment.
6. Related Case Law:
| Case | Principle |
|---|---|
| Rural Litigation and Entitlement Kendra v. State of UP (Dehradun Quarry Case, 1995) | Judicial enforcement of environmental laws. |
| Indian Council for Enviro-Legal Action v. Union of India (1996) | Polluter Pays principle and compensation for environmental damage. |
| Vellore Citizens Welfare Forum v. Union of India (1996) | Precautionary principle and sustainable development. |
7. Significance:
The case is a milestone in environmental jurisprudence in India, underscoring environmental protection as a constitutional mandate.
It expanded the scope of Article 21 to include the right to a clean and healthy environment.
The case reinforced the accountability of industries and governments in environmental matters.
It advanced the principles of sustainable development and environmental justice.
The ruling encouraged public interest litigation as a tool to address environmental issues.
8. Summary Table:
| Aspect | Details |
|---|---|
| Case Name | M.C. Mehta v. State of Tamil Nadu & Others |
| Court | Supreme Court of India |
| Issue | Pollution control, environmental protection, and fundamental rights |
| Held | Right to clean environment under Article 21; strict action against polluters |
| Legal Principle | Right to life includes environment; Polluter pays; Precautionary principle |
| Significance | Landmark environmental judgment; judicial activism in pollution control |
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