Supreme Court permits registration of BS-IV vehicles for public utility and educational purposes: M.C. Mehta vs. Union of India (09 April 2021)

Date of the Judgment: 09 April 2021
The Supreme Court of India, in a series of applications within the ongoing case of M.C. Mehta vs. Union of India, addressed the registration of Bharat Stage-IV (BS-IV) compliant vehicles. This case highlights the balance between environmental regulations and the practical needs of public services and educational institutions. The bench comprised of Hon’ble The Chief Justice, Hon’ble Mr. Justice A.S. Bopanna, and Hon’ble Mr. Justice V. Ramasubramanian.

Case Background

The case of M.C. Mehta vs. Union of India is a long-standing Public Interest Litigation (PIL) concerning environmental protection. Several applications were filed seeking directions for the registration of BS-IV compliant vehicles, which were facing hurdles due to the implementation of stricter emission norms. These applications were filed by various entities, including municipal corporations, educational institutions, and private individuals. The core issue revolved around whether the court should allow the registration of BS-IV vehicles, especially those intended for public utility and essential services, despite the prevailing emission standards.

Timeline:

Course of Proceedings

The Supreme Court was hearing a batch of Interlocutory Applications (IAs) in the main case of M.C. Mehta vs. Union of India. These applications were filed by various parties seeking specific directions, primarily concerning the registration of BS-IV compliant vehicles. The applications were necessitated by the transition to BS-VI emission norms, which had created hurdles for the registration of vehicles that met the older BS-IV standards. The court considered each application on its merits, taking into account the nature of the applicant and the intended use of the vehicles.

Legal Framework

The primary legal framework in this case revolves around the environmental regulations concerning vehicular emissions in India. The transition from Bharat Stage-IV (BS-IV) to Bharat Stage-VI (BS-VI) emission standards is a critical aspect. The court was essentially dealing with the practical implications of these regulations, particularly regarding vehicles purchased before the cut-off date for BS-IV compliance, but not yet registered.

Arguments

The arguments presented before the Supreme Court were primarily focused on the need to allow the registration of BS-IV vehicles, especially those meant for public utility and essential services.

• Municipal Corporations: The North Delhi Municipal Corporation sought registration for CNG BS-IV Tata trucks with water tankers and CNG BS-IV auto tippers. The East Delhi Municipal Corporation requested registration for BS-VI hook loaders. They argued that these vehicles are essential for public utility services like waste management and water supply.
• Delhi Fire Service: The Delhi Fire Service sought registration for 30 fire units (BS-IV), stating that these vehicles were purchased before 31.03.2020 and were registered on the E-Vahan portal. They emphasized the public safety aspect of these vehicles.
• Educational Institutions: Various educational societies and schools requested registration for BS-IV CNG compliant school buses. They argued that these buses are essential for transporting students and are compliant with the CNG norms.
• Private Individuals: Some private individuals also sought registration for their BS-IV vehicles, citing various reasons, including purchases made before the cut-off date.

The underlying argument across these applications was the need to balance environmental regulations with the practical needs of public services and essential activities. The applicants contended that the vehicles were either essential for public service or were purchased before the implementation of BS-VI norms, and therefore, their registration should be permitted.

Submissions of Parties

Issues Framed by the Supreme Court

The Supreme Court did not frame specific issues in a separate section, but the core issue was whether to allow the registration of BS-IV compliant vehicles, given the transition to BS-VI emission standards. The sub-issues included:

• Whether vehicles purchased before the BS-VI implementation deadline could be registered.
• Whether vehicles intended for public utility and essential services should be treated differently.
• Whether vehicles that were already registered on the E-Vahan portal should be allowed registration.

Treatment of the Issue by the Court

The following table demonstrates how the Court decided on the issues:

Authorities

The Supreme Court primarily relied on its previous order dated 18.09.2020, which had set a precedent for allowing the registration of BS-IV vehicles under specific circumstances. There were no other authorities cited in the present order.

Judgment

The Supreme Court allowed the registration of BS-IV vehicles in several applications, primarily those related to public utility services, educational institutions, and vehicles purchased before the cut-off date of 31.03.2020. The Court’s decision was based on the principle that these vehicles serve essential public needs and were either purchased or intended for use before the stricter BS-VI norms came into effect.

The Court followed its previous order dated 18.09.2020, which had set a precedent for allowing the registration of BS-IV vehicles under specific circumstances.

What weighed in the mind of the Court?

The Supreme Court’s decision was primarily influenced by the need to balance environmental regulations with the practical needs of public services and essential activities. The Court recognized that municipal corporations, fire services, and educational institutions rely on these vehicles for their day-to-day operations. The fact that many of these vehicles were purchased before the BS-VI norms came into effect or were already registered on the E-Vahan portal also played a crucial role in the Court’s decision.

The Court’s reasoning was based on a combination of factual considerations (such as the intended use of the vehicles and the timing of their purchase) and legal considerations (such as the previous order of the court).

Logical Reasoning

The Court’s decision to allow the registration of BS-IV vehicles for public utility and essential services was a practical approach to balancing environmental concerns with the immediate needs of the public.

The court stated, “Since these vehicles are to be put to use for public utility services, the application is allowed as prayed for, following the Order dated 18.09.2020 passed by this Court.” The court also noted, “Since the vehicles in question are to be put to use for public purposes and also since they have been purchased before 31.03.2020 and also registered on the E-Vahan portal, the applications are allowed.” In the case of educational institutions, the court observed, “Since these buses are BS-IV CNG compliant vehicle, this application is allowed following our earlier orders.”

Key Takeaways

• The Supreme Court permitted the registration of BS-IV vehicles intended for public utility services, such as those used by municipal corporations for waste management and water supply.
• BS-IV vehicles purchased before 31.03.2020, and those already registered on the E-Vahan portal, were allowed registration.
• Educational institutions were permitted to register BS-IV CNG compliant school buses.
• Private individuals seeking registration of BS-IV vehicles were directed to have their cases verified by the Amicus Curiae, and may need to approach the Allahabad High Court.

Directions

The Supreme Court directed the Amicus Curiae, Shri A.D.N. Rao, to verify the applications of private individuals seeking registration of BS-IV vehicles and determine if they should approach the Allahabad High Court.

Development of Law

The case reinforces the principle that while environmental regulations are crucial, practical considerations and the needs of public services cannot be ignored. The ratio decidendi is that BS-IV vehicles purchased before the cut-off date or intended for public utility and essential services can be allowed registration, following the precedent set by the order dated 18.09.2020. There was no change in the previous position of law, but the court reiterated its stance on allowing registration in specific scenarios.

Conclusion

In conclusion, the Supreme Court’s order in M.C. Mehta vs. Union of India demonstrates a balanced approach to environmental regulations and public needs. By allowing the registration of BS-IV vehicles for public utility, essential services, and educational purposes, the court ensured that essential services and activities are not unduly hampered while also adhering to environmental standards. The court’s decision to refer private individual cases to the Amicus Curiae further underscores the need for a case-by-case evaluation in such matters.

Category:

Parent Category: Environmental Law
Child Category: Vehicular Emissions
Child Category: BS-IV Vehicles
Child Category: Public Utility Services
Child Category: Educational Institutions
Parent Category: Motor Vehicles Act, 1988
Child Category: Registration of Vehicles

FAQ

Q: What was the main issue in the M.C. Mehta vs. Union of India case on April 9, 2021?
A: The main issue was whether the Supreme Court should allow the registration of Bharat Stage-IV (BS-IV) compliant vehicles, given the implementation of stricter Bharat Stage-VI (BS-VI) emission norms.

Q: Which types of vehicles were allowed to be registered by the Supreme Court?
A: The Supreme Court allowed the registration of BS-IV vehicles intended for public utility services (like those used by municipal corporations), essential services (like fire units), and educational purposes (like school buses).

Q: What was the cut-off date for purchasing BS-IV vehicles to be eligible for registration?
A: The cut-off date was 31.03.2020. Vehicles purchased before this date were generally allowed registration, provided they met other criteria.

Q: What should private individuals do if their BS-IV vehicle registration was denied?
A: Private individuals were directed to have their cases verified by the Amicus Curiae, and may need to approach the Allahabad High Court.

Q: What was the basis of the Supreme Court’s decision?
A: The Supreme Court’s decision was based on balancing environmental regulations with the practical needs of public services and essential activities. The court also considered its previous order dated 18.09.2020.