## Facts

- A public-interest petition sought nationwide measures to improve public awareness and education on environmental protection after serious pollution incidents and industrial disasters.
- The petition relied on the constitutional duty of citizens to protect and improve the natural environment and argued that environmental laws were ineffective without public understanding and acceptance.
- The petitioner requested directions requiring (i) environmental messages in cinema halls, (ii) regular environmental programming on radio and television, and (iii) compulsory environmental education in schools and colleges.
- The case was heard in the Supreme Court’s original writ jurisdiction, focusing on whether affirmative directions could be issued to executive and educational authorities.

## Issues

1. Whether the Court could direct government agencies and state-controlled media to disseminate environmental information through cinema, radio, and television.
2. Whether the Court could direct educational authorities to implement compulsory environmental education in schools and consider compulsory environmental study at the college level.
3. Whether constitutional obligations concerning environmental protection justified detailed, affirmative directions to implement public awareness and education measures.

## Decision

- The Court granted relief and issued binding directions to governmental and related authorities to implement environmental awareness and education measures.
- It required licensing authorities to make it a condition of cinema hall licences that at least two environmental slides/messages be exhibited free of cost during each show.
- It directed the responsible ministry to begin producing short environmental information films without delay.
- It directed national television and radio authorities to broadcast daily short environmental messages (about five to seven minutes) and to run a regular weekly programme on environmental protection.
- It directed educational boards to take steps to enforce compulsory environmental education up to matriculation starting the next academic year.
- It directed the university regulator to consider feasibility of making environmental study a compulsory subject at each level of college education.

## Legal Principles

- Environmental legislation and regulation are ineffective without public awareness and social acceptance; compliance depends in part on education about the reasons for legal requirements.
- The constitutional scheme supporting environmental protection permits judicially ordered, affirmative measures to inform citizens and facilitate performance of their environmental duties.
- Mass media under governmental control may be used as an instrument for disseminating environmental information as part of state obligations related to environmental protection.
- Environmental education can be required as a systemic measure within formal schooling to support effective implementation of environmental norms.

## Conclusion

The Court held that environmental protection requires more than statutes and enforcement and ordered nationwide environmental awareness initiatives through cinema and state media while requiring compulsory environmental education in schools and directing consideration of compulsory environmental study in higher education.


M.C. Mehta v. Union of India, A.I.R. 1992 S.C. 382 (India 1992)