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ENVIRONMENTAL LAW

Topic: MC MEHTA V UNION OF INDIA- JUDICIALINTERPRETATION

OF THE TAJ TRAPEZIUM CASE (1997) 2 SCC 353

Class Teacher
Ms Jayati Kharga

NAME: ARKAPRAVA BHOWMIK

ROLL NO - 31
COURSE:LL.B. 3YEARS (3rd SEMESTER)

INDIAN INSTITUTE OF LEGAL STUDIES

2017
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ACKNOWLEDGEMENT

With profound gratitude and sense of indebtedness I place on record my sincerest thanks to Ms Jayti

Kharga, Assistant Professor in Law, Indian Institute of Legal Studies, for his guidance, sound advice

and affectionate attitude during the course of the study work.

There is no hesitation in saying that she molded raw clay into whatever we are through his incessant

efforts and keen interest shown throughout the academic pursuit. It is due to his patient guidance that

I have been able to complete the task.

I would also thank the Indian Institute of Legal Studies Library for the wealth of information therein.

I express my regards to the Library staff for cooperating and making available the books for this

project research paper.

Finally, I thank my beloved parents for supporting me morally and guiding me throughout the project

work.

Date:
_____________________
ARKAPRAVA BHOWMIK
LL.B (3rd Semester) Roll No: 31
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TABLE OF CONTENTS
___________________________________________________________
Acknowledgement…………………………………………………….………………………1

Research Methodology……………………………………….………………………………..3- 4
A. Aims and Objectives………………………………………………..………………3
B. Statement of Problem………………………………………………….…………..3
C. Research Hypothesis……………………………….…………………….…………3
D. Research
Questions…………………………………………….….……………..……………3
E. Methodology of Research…………………………….……………….……………4
F. Scope and Limitations…………………………………………………..……………4
G. Review of Literature……………………………………..…………….……………4
H. Mode of Citation…………………………………………………….………………4

Table of Cases……………………………………………………………….………………….5

Chapter – I: Introduction……………………………………………..…………………………6-7
Chapter II: Background…………………………… …………………………………………….8

Chapter III: Case Analysis………………………………………………………………………9-14

Chapter IV: Case Comment…………………….………………………………………………15-16
Chapter V: Conclusion……………...…………………………………………………………17-18

Bibliography………………………………………………………………………………………19
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RESEARCH METHODOLOGY
___________________________________________________________
A. AIMS AND OBJECTIVES
The aim of this paper is to analyze the core issues related to the Taj Trapezium case and to
get an insight to how much vulnerability is imposed on this world renowned monument due
to environmental pollution. It also strives to critically analyse the judgement of the Taj
Trapezium case and its relevance in the modern day.

B. STATEMENT OF PROBLEM

The current systems do not give an equal chance to access and flourish. Though we have
various Laws /Statutes/Case laws, yet essential things are missed out and very few literates know the
proper meaning and nature of the said project Topic. As such many of us are still in dark as to what
the basic terminologies mean and why was it enacted. Also what is the current status of the said
Topic with respect its implementation.

C. RESEARCH HYPOTHESIS
1. Environmental pollution resulted in the degradation of Taj Mahal.

2. The judgement given by the honourable Supreme Court in the Taj Trapezium case is not
adequate.

D. RESEARCH QUESTIONS

 How the framed monument marbles of Taj Mahal turned yellow?

 What are the active contributors of pollution in TTZ?

 Is the judgement given by the court in the Taj Trapezium case complete?
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E. METHODOLOGY OF RESEARCH

“Methodology” implies more than simply the methods the researcher used to collect data. It is often
necessary to include a consideration of the concepts and theories which underlie the methods. The
methodology opted for the study on the topic is Analytical and Doctrinal. Doctrinal research in law
field indicates arranging, ordering and analysis of the legal structure, legal frame work and case laws
by extensive surveying of legal literature but without any field work.

F. SCOPE AND LIMITATIONS

The scope of the study refers to the parameters under which the study is operating. An extensive
attempt has been made in order to search for the quest with regard to the topic under this paper.
Though there is ample scope to highlight on the principle of good faith and duty of disclosure
according to different Statutes, but the scope of research work is limited to a particular area in search
of answer. Therefore, the researcher confines to the materials which are available and widely
accepted.

G. REVIEW OF LITERATURE
The researcher while writing this project has taken recourse to various primary and secondary
sources. Primary sources would include various laws. Secondary sources would include books and
articles, reports and websites.

H. MODE OF CITATION
A Blue Book system of citation has been adopted throughout the project.
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TABLE OF CASES

1. M.C Mehta v. Union of India (1997)2 SCC 353

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CHAPTER I - INTRODUCTION

It is interesting to note that natural resource shad been stored virtually untouched in the Earth for
millions of years. But since the start of the industrial revolution vast amounts of these resources had
been exploited within a period of just a couple of hundred of years at unimaginable rates, with all the
waste from this exploitation going straight in the environment (air, water, land) and seriously
damaging its natural processes. Although pollution had been known to exist for a very long time (at
least since people started using fire thousands of years ago), it had seen the growth of truly global
proportions only since the onset of the industrial revolution during the 19th century.

Environmental degradation in India has been caused by a variety of social, economic, institutional
and technological factors. Rapidly growing population, urbanization and industrial activities have all
resulted in considerable deterioration in the quality and sustainability of the environment.
Environmental ethics have also formed an inherent part of Indian religious precepts and philosophy.
Worship of nature - Sun, Moon, Earth, Air and Water - was not merely a primitive man's response to
the fear of the unknown, but it arose from the deep reverence shown to the forces of nature which
sustained and preserved human life on earth. The basic tenet that underlies this deep reverence for
nature is the belief that life is a singular, continuous and uniform phenomenon and even a small
change in one part of the eco-system is likely to reverberate throughout. Guru Nanak (Founder of the
SikhReligion, 1469-1539), said ‘Pawan Guru, Pani Pita Mata Dhart Mahat, Divis RaatDoi Daia,
Khele Sagal Jagat' (Air is like God, Water is father and Earth is themother. It is through the
harmonious interaction of all these three vital ingredients that the whole universe is being sustained).
The ancient Greeks, onthe same reasoning, revered the Earth as Gaia, the Earth Goddess.(1)

The importance of Judiciary in a democratic setup for protection of life and personal rights can
hardly be overestimated. India has a highly developed judicial system with the Supreme Court
having plenary powers to make any order for doing complete justice in any cause or matter and a
mandate in the Constitution, to all authorities, Civil and Judicial, in the territory of India to act in
aide of the Supreme Court. The scope of Writ Jurisdiction of the High Courts is wiser than
traditionally understood and the judiciary is separate and independent of the executive to ensure
impartiality in administration of justice. The judiciary has a central role to play in this thriving
democracy and shuns arbitrary executive action. The higher judiciary has been empowered to
pronounce upon the legislative competence of the lawmaking bodies and the validity of a legal
provision. The range of judicial review recognized in the higher judiciary in India is the widest and
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most extensive known to any democratic set up in the world. Liberty and Equality have well
survived and thrived in India due to the pro-active role played by the Indian judiciary.

In considering the role of the judiciary in environmental governance, there are two issues that need to
be considered. The first is the role the judiciary in the interpretation of environmental law and in law
making and the second is the capability of jurists to effectively interpret the increasingly cross-linked
issues brought to their attention. For the judiciary, probably the burden of implementation is greater,
as they must not only interpret laws that incorporate the Rio Principles of sustainable development,
including the polluter pays principle, the precautionary principle, and the principle of continuous
mandamus in the corpus of international and national law; inter- and intra-generational equity;
importance of traditional values and ideas; interpretation of constitutional rights including the right
to life and the right to a healthy environment, etc., but also have to weigh these against economic and
political principles.

1. A. Das & R. Caprihan, "A rule-based fuzzy-logic approach for the measurement of
manufacturing flexibility" , Int. J. Adv. Manuf. Technol., Vol. 38, 2008, pp. 1098
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CHAPTER II - BACKGROUND

The Taj Mahal in Agra is one of the most beautiful monuments on the earth. It was built by
the Mughal ruler Shah Jahan in memory of his deceased wife Mumtaz Mahal. It is built entirely of
white marble and was declared as a UNESCO World Heritage Site in 1983. It attracts scores of
tourists from all over the world. But now the monument has developed a yellowish tinge (and in
some areas ugly brown and black spots) owing to the increased levels of pollution around the area.
The main pollutant was sulphur dioxide released by the industries which later on reacted with rain
water to give acid rain. Suspended Particulate Matter (SPM) was also one of the culprits. This case
is commonly referred to as ‘Taj Trapezium Case’. The ‘Taj Trapezium Zone’ (TTZ) referred to by the
court is a 10,400 sq.km trapezium-shaped area covering the five districts of the Agra region. The
TTZ comprises over 40 protected monuments including three World Heritage Sites — the Taj Mahal,
Agra Fort and Fatehpur Sikri.

“In early 1984, M.C. Mehta, a public interest attorney, visited the Taj Mahal for the first time. He
saw that the famed monument’s marble had turned yellow and was pitted as a result of pollutants
from nearby industries. This spurred Mehta to file his first environmental case in the Supreme
Court of India.”(2)

2. H.N.Das. 1999 A Critical analysis of environmental Crimes in India . Unpublished

Ph.D. Thesis, University of Gauhati. pp. 28-29
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CHAPTER III – CASE ANALYSIS

MC MEHTA ( Taj Trapezium Matter) V. UNION OF INDIA

Citation:- (1997) 2 SCC 353

FACTS:-

 In this case a petition was filed the threat to the deteriorating beauty of Taj Mahal to invoke
the Air (Prevention And Control Of Pollution) Act 1981 and Water ( Prevention And Control
Of Pollution) Act 1974 and Environmental Protection Act 1986 for the purpose of relocation
of 292 factories to prevent emission by coal consuming factories having a damage effect on
taj living in the taj trapezium zone, and further to direct them to change into natural gas as
industrial fuel.
 According to the petitioner the foundries, chemical/ hazardous industries and the refinery at
Mathura were the major sources to damage to the Taj. The sulphur dioxide emitted by
Mathura refinery and other industries when combined with oxygen with the aid of oxygen in
the atmosphere formed suiphuric acid called acid rain which has a corroding effect on the
gleaming white marble. Industry/Refinery emissions, brick kilns, vehicular traffic and
generator set were all responsible for polluting the air around the Taj Trapezium Zone.
 In this case Four NEERI Reports, Two Varadharajan Reports and Several Reports by the
State Pollution Control Board were presented. After examining all the reports and taking into
the consideration other material on the record, the court has no hesitation in holding that the
industries in TTZ were active contributor to the pollution in the said area.
 Principle applied here are-
 Sustainable development– the object behind this litigation is to stop the pollution while
encouraging the development of the industries because development of industry is essential
for economy but at the same time environment has to be protected.
 Precautionary principle– the pollution created as a consequence of development so the state
must anticipate, prevent and attack the harm caused to the environment.
 Polluter pays principle– the court interpreted the principle in order to mean that the absolute
liability to harm the environment is not only to compensate the victims of pollution but also
for restoring the cost of environmental degradation.
 Article referred in this case of Constitution Of India are Article 21, 48A, 49.
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ISSUES:-

 The Mathura Oil Refinery and other nearby industries pushed into atmosphere pollutants that
contain oxides of sulphur qand nitrogen which causes acid rain.
 The deposition of SPM on the Shimmering White Marble Of Taj Mahal imparts yellow tinge
to the marble surface and causes marble cancer.
 Taj’s discolouration which was mainly caused by equally deposition of dust particles and
carbonaceous particles such as black and brown carbon which is light absorbing organic
carbon.

JUDGEMENT:-

The final judgment in this case was given on 30th of December 1996 and the bench consisted
of Justice Kuldip Singh and Justice Faizan Uddin. The court was of the view that The Taj Mahal
is a masterpiece and has international reputation. It is also an important source of revenue to the
country because of the huge tourist attraction it commanded. So, its beauty could not be
compromised. The following guidelines are (3)

(1) The industries (292 listed) shall approach/apply to the GAIL before February 15, 1997 for grant
of industrial gas-connection.

(2) The industries which are not in a position to obtain gas connections and also the industries which
do not wish to obtain gas connections may approach/apply to the Corporation UPSIDC)/Government
before February 28, 1997 for allotment of alternative plots in the industrial estates outside TTZ.

(3) The GAIL shall take final decision in respect of all the applications for grant of gas connections
by March 31, 1997 and communicate the allotment letters to the individual industries.

(4) Those industries which neither apply for gas connection nor for alternative industrial plot shall
stop functioning with the aid of coke/coal in the TTZ with effect from April 30, 1997. Supply of
coke/coal to these industries shall be stopped.

3. MC MEHTA V UNION OF INDIA (1997)2SCC 353

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(5) The GAIL shall commence supply of gas to the industries by June 30, 1997. As soon as the gas
supply to an industry commences, the supply of coke/coal to the said industry shall be stopped with
immediate effect.

(6) The Corporation/Government shall finally decide and allot alternative plots, before March 31,
1997, to the industries which are seeking relocation.

(7) The relocating industries shall set up their respective units in the new industrial estates outside
TTZ. The relocating industries shall not function and operate in TTZ beyond December 31, 1997.
The closure by December 31, 1997 is unconditional and irrespective of the fact whether the new unit
outside TTZ is completely set up or not.

(8) The Deputy Commissioner, Agra and the Superintendent (Police), Agra shall effect the closure of
all the industries on December 31, 1997 which are to be relocated by that date as directed by court.

(9) The U.P. State Government/Corporation shall render all assistance to the industries in the process
of relocation. The allotment of plots, construction of factory buildings, etc. and issuance of any
license/permissions, etc., shall be expedited and granted on priority basis.

(10) In order to facilitate shifting of industries from TTZ, the State Government and all other
authorities shall set up unified single agency consisting of all the departments concerned to act as a
nodal agency to sort out all the problems of such industries. The single window facility shall be set
up by the U.P.State Government within one month. The Registry shall communicate this direction
separately to the Chief Secretary, Secretary (Industries) and Chairman/Managing director, UPSIDC
along with a copy of the judgment, no further time shall be allowed to set up the single window
facility.

(11) The State Government shall frame a scheme for the use of the land which would become
available on account of shifting/relocation of the industries before June 30, 1997. The State
Government may seek guidance in this respect from the order of the court.
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(12) The shifting industries on the relocation in the new industrial estates shall be given incentives in
terms of the provisions of the Agra Master Plan and also the incentives which are normally extended
to new industries in new industrial estates.

(13) The workmen employed in the above-mentioned 292 industries shall be entitled to the rights and
benefits as indicated hereunder:

(a) The workmen shall have continuity of employment at the new town and place where the industry
is shifted. The terms and conditions of their employment shall not be altered to their detriment.

(b) The period between the closure of the industry in Agra and its restart at the place of relocation
shall be treated as active employment and the workmen shall be paid their full wages with continuity
of service.

(c) All those workmen who agree to shift with the industry shall be given one year’s wages as
‘shifting bonus’ to help them settle at the new location. The said bonus shall be paid before January
31, 1998.

(d) The workmen employed in the industries who do not intend to relocate/obtain natural gas and opt
for closure, shall be deemed to have been retrenched by May 31, 1997, provided they have been in
continuous service (as defined in Section 25-B of the Industrial Disputes Act, 1947) for not less than
one year in the industries concerned before the said date. They shall be paid compensation in terms
of Section 25-F(b) of the Industrial Disputes Act. These workmen shall also be paid, in addition, six
years’ wages as additional compensation.

(e) The compensation payable to the workmen in terms of this judgment shall be paid by the
management within two months of the retrenchment.

(f) The gratuity amount payable to any workman shall be paid in addition.

With this court has also stopped the operation of all the brick kilns in the TTZ with effect from
August 15, 1996 this would be a useful step to eliminate the pollution caused by fly-ash. This Court
is separately monitoring the following issues for controlling air pollution in TTZ by:-
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(a) The setting up of 50 bed hospital and two mobile dispensaries by the Mathura Refinery to provide
medical aid to the people living in the surrounding areas.

(b) Construction of Agra bypass to divert all the traffic which passes through the city. Under
directions of this Court, 24 kms’ stretch of the bypass shall be completed by the end of December
1996 (Court order dated April 10, 1996).

(d) Additional amount of Rs. 99.54 crores sanctioned by the Planning Commission to be utilized by
the State Government for the construction of electricity supply projects to ensure 100 per cent
uninterrupted electricity in the TTZ. This is necessary to stop the operation of generating sets which
are major source of air pollution in the TTZ.

(e) The construction of Gokul Barrage, water supply work of Gokul Barrage, roads around Gokul
Barrage, Agra Barrage and water supply of Agra Barrage, have also been undertaken on a time
schedule basis to supply drinking water to the residents of Agra and to bring life into river Yamuna
which is next to the Taj.

(f) Green belt as recommended by NEERI has been set up around Taj. Pursuant to continuous
monitoring of this Court, the Green Belt has become a reality.

(g) This Court suggested to the Planning Commission to consider sanctioning separate allocation for
the city of Agra and the creation of separate cell under the control of Central Government to
safeguard and preserve the Taj, the city of Agra and other national heritage monuments in the TT.

(h) All emporia and shops functioning within the Taj premises have been directed to be closed.

(i) Directions have been issued to the Government of India to decide the issue, pertaining to
declaration of Agra as heritage city within two months.

Apart from this constitutional mandate are also there to protect and improve the environment. The
relevant enactments for this purpose are:

The Water (prevention and Control of pollution) Act, 1974

The Air (Prevention and Control of Pollution) Act, 1981

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The Environment protection Act, 1986.

Whereas 292 factories were ordered to change-over to the natural gas as an industrial-fuel. The
industries which were not in a position to obtain gas connections for any reason were ordered to stop
functioning with the aid of coke/coal in the TTZ and relocate themselves as per the directions given
by the court.

Thus the court gave its orders based on the “Precautionary Principle” and “Polluter Pays
Principle” as was defined in Vellore Citizens Welfare Forum v. Union of India. The court was of
the view that “the precautionary principle” and “The polluter Pays” principle are essential
features of “Sustainable Development“
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CHAPTER IV– CASE COMMENT

As through this judgment there is reduction in the level of Suspended Particulate Matter which is one
of the major pollutants causing discolouration of the Taj Mahal as well as respiratory problems in
human has been lowered between 1991-1994 due to the closure of 212 coal based industrial units and
shifting of thermal plant in 1993 but after1994 there was a steady increase in the emissions from the
Mathura oil refinery, use of diesel based generators during power cuts and vehicles according to the
Uttar Pradesh Pollution Control Board which was neither taken into consideration by the plaintiff nor
by court in its order.(4)

With this the order was only extended to 292 industries out of the 510, whose names were put
forward by the pollution control board in the court. However the rest of the industries also
contributed to the pollution in some way or the other resulting in the yellowing of the marble but the
court not consider all the aspect and relocated only those industries who refuse to accept natural gas
as an alternative fuel or to whom it is not available due to some technical defect. According to me all
510 industries should be taken into consideration and all the industries should have been relocated as
it would eliminate total pollution as compared to only small reduction in the pollution level as by
relocating only limited industries.

Taj Mahal is known as Crown of the World and more than two million tourists visit taj mahal every
year so while preserving it the country is destroying it on the other hand our judicial system is also
creating the damage by deteriorating the atmosphere while scrutinizing the situation and given
judgement instead of this prompt decision should be given by the court while spreading the pollution
for three more years because the objective was to stop the pollution not to encourage the
development of industry.

Further the judgment only talks of coke and coal as the pollutants, there is not much emphasis on the
pollution caused by the brick kilns, chemical industries, bangle and glass factories, excessive traffic
on the roads of Agra and the waste being thrown by the road side shops and restaurants. It’s does not
talk about restoring the quality of water of Yamuna because the monument rests on huge wooden
slabs placed inside the deep wells that need perennial water. It is built on a riverbank and wells were
dug up 50 meters above the riverbed to form its base. It is feared that the monument could suffer
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4. Madhav Khosla, Bitter PIL, Indian Express, November 18, 2008

serious structural damage if Yamuna becomes waterless.

There is no mentioning of the harm caused to the workers working in the factory and other ordinary
citizen who losing their life by causing harm to their lungs due the pollution and also failed to restore
the original quality of the marble, only prevention and control of pollution finds its place in the
judgment. No pollution standard was given by the court for the industries whether they are allowed
to use coke and coal in the relocated areas or not and concept of compensation is ignored by the
court.(5)

However we can say that the judgement is incomplete thus the judgement is not effective for the
nature as described above.

5. K. Lal Gauri and C. C. Holdren, Jr., “Pollutant effects on stone monuments”,

Environmental Science 8 Technology, Vol. 15, No. 4, 1981, pp 386-392
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CHAPTER V -CONCLUSION

‘Taj Mahal’ the ‘Crown of all Monuments’ is not only one of the wonders of the world but of our
country also. The Taj Mahal, the mother of all monuments, is the finest structure built in the history
of India. It was built by Shah Jahan in the memory of his beloved wife Mumtaz Mahal and since then
the centuries old marvel stands as a monument of love.

Taj Mahal is the most beautiful creation that the Mughals gave to India. Shah Jahan spent years to
build this beautiful structure and used the best material to create it. The finest white marble was used
to build the Taj Mahal that stands right in the middle of lush green gardens, as it was believed by the
Mughals that heaven alone was said to have such gardens. Unfortunately, we could not respect the
existence of Taj Mahal. This symbol of eternal love now stands polluted, losing its romantic
character. It suffers from what is termed as ‘Marble Cancer’ and has lost its sheen due to the air
borne particles that are being deposited on it giving a yellow tinge to its pure white marble. The
pollutants that are emitted by the industries such as the Mathura Refinery, iron foundries, glass
factories & brick kilns situated in and around Agra react with the marble forming of a fine layer of
dust over it. There is fungus in its interiors and exteriors. Pollutants such as sulphur dioxide and
nitrous oxide combine with moisture and settle on the walls of the monument. Added to this the
pollution from the vehicles, the dirty graffiti being made on the walls by the tourists, decreasing
green belt around the area all imply the negligence on the part of the Uttar Pradesh Pollution Control
Board, NEERI and the Ministry of Environment.

The judgement given by the court is incomplete according to me.The court directed that only those
industries would be relocated who refuse to accept natural gas as an alternative fuel or to whom it is
not available due to some technical difficulties. In my opinion all the industries should have been
directed to relocate themselves as even when natural gas would be used by the industries it would
lead to only a small reduction in the pollution level and would not eliminate pollution in totality.

The judiciary scrutinized the situation for about three years from 1993 to 1996, during these three
years of pendency of litigation a lot of harm was already done by the industries adding on to the
existing pollution levels. A prompt action should have been taken by the court instead of spreading it
over for three long years, as this was a case involving our national heritage.

There is no mentioning of restoring the original quality of the marble, only prevention and control of
pollution finds its place in the judgment.
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Further, it does not talk about restoring the quality of water of Yamuna. The park built by ASI is not
helping the beautification of Taj Mahal but destroys the structure. Historical maps and geographical
information show Yamuna flowing close by the Taj Mahal to the extent of even touching its rear
walls. The Emperor Shah Jahan built it because of the existence of the huge water body in the
background. The Taj’s foundation is water borne; the monument rests on huge wooden slabs placed
inside the deep wells that need perennial water. It is built on a riverbank and wells were dug up 50
meters above the riverbed to form its base. It is feared that the monument could suffer serious
structural damage if Yamuna becomes waterless.

In the judgment there is no mention of the harm being caused to the lives all those workers and
children below the age of 12 years working in the hazardous industries causing harm to their lungs.

Any activity or substance involving human intervention causing irreparable harm to the environment
or the individuals needs to be eliminated. This result in absolute liability to compensate not only the
harm done to the environment but also to the individuals under the polluter pays principle. The
judgment no where talks about any compensation being made by these factory owners for the harm
caused to the environment and their workers.

There is also no talk of the pollution standards for the industries which will be relocated whether
they are allowed to use coke and coal in the relocated areas.

Thus this judgment is not a very effective one in nature. It is limited to only Air pollution and not
water pollution and land pollution. Because of the above mentioned flaws it is not a very
comprehensive judgment leading to various other follow up of Taj Mahal Trapezium Cases.
 19

BIBLIOGRAPHY

A. PRIMARY SOURCES

I. STATUTES:

i. Article 21 , 48A, 49 of the Indian Constitution

B. SECONDARY SOURCES

A. BOOKS

 P.Leelakrishnan ,Environmental Law in India , LEXIS NEXIS 3rd edition

2010

II. WEBSITES

- https://www.slideshare.net/mdharoonrasheed/mc-mehta-case-the-famous-taj-
trapezium-matter

- https://www.youthkiawaaz.com/2011/01/taj-mahal-environment-pollution/

- https://www.lawteacher.net/free-law-essays/european-law/this-case-is-commonly-
referred-to-as-taj-trapezium-case-law-essay.php