M.C. MEHTA V. UNION OF INDIA AND ORS INSC 840

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

Citation: 1997 (4) CCC 126 Appellant: M. C. Mehta Respondent: Union of India and Ors.

FACTS M. C. Mehta filed a Public Interest Litigation (PIL) regarding the regulation and control of traffic in National Capital Region (NCR) and the National Capital Territory (NCT), Delhi, to safeguard public safety amidst rising road accidents. The need is accentuated by the alarming rise in the number of road accidents and the resulting deaths and bodily injuries caused thereby. The most recent tragedy in which a school bus broke the parapet of a bridge and fell into the river a couple of days back does not permit any further delay in taking urgent measures on this behalf.

ISSUES Whether the executive authorities have sufficient powers under existing laws to regulate road traffic and ensure public safety? Whether the inaction of authorities in enforcing traffic regulations violates the public’s right to safety under Article 21 of the Constitution? Whether the Judiciary can issue directions to supplement the enforcement of traffic regulations in light of administrative inefficience?

HOLDING The Court held that the existing provisions under the Motor Vehicles Act, 1988, provide adequate authority to regulate road traffic and ensure road safety. However, due to continued administrative inaction and rising traffic-related hazards, the Court issues further specific directions to ensure immediate enforcement of traffic control measures.

RATIONALE The Court analyzed several provisions of the existing Motor Vehicles Act, 1988. This included the sections on licensing (s.19), registration (s.39), permits (s.66) and traffic control (Chapter VIII), which empowered the authorities to regulate road traffic. The Court realized that public safety is of utmost priority. Thus, traffic laws must be strictly enforced. The Court found it necessary to intervene under its jurisdiction in Article 32 and Article 142 of the Constitution since the matter concerns public safety and falls under the ambit of article 21 of the Constitution. The Court recognized the constraints faced by law enforcers (executive) and clarified that the authorities could delegate their powers to overcome practical difficulties.