## Facts

- The Taj Mahal, a UNESCO World Heritage Site, is primarily built of white marble and is valued for its historical, cultural, aesthetic, and architectural importance.
- The “Taj Trapezium Zone” (TTZ) is an area of about 10,400 sq. km. around the Taj Mahal, covering Agra and surrounding districts.
- Coal- and coke-based industrial activity in the TTZ was associated with significant sulphur dioxide (SO₂) emissions.
- SO₂ emissions were linked to acid rain, which corroded and degraded the Taj Mahal’s marble surface and contributed to discoloration and surface decay.
- M.C. Mehta, a lawyer and environmental activist, filed a public-interest petition under Article 32 of the Constitution against the Union of India and other public authorities, seeking immediate measures to stop air pollution in the TTZ from further damaging the Taj Mahal and affecting public health.
- The petition relied on official and technical material (including government reporting) identifying coal-burning industries in the TTZ as primary drivers of the relevant air pollution affecting the monument.
- The case proceeded as a continuing public-interest matter, with the Supreme Court considering technical assessments and the need for enforceable steps rather than nonbinding recommendations.

## Issues

1. Whether air pollution from coal/coke-based industrial activity in the Taj Trapezium Zone was materially contributing to corrosion and deterioration of the Taj Mahal.
2. Whether the Supreme Court should direct industries in the TTZ to switch to a cleaner fuel (natural gas) or, failing that, relocate outside the TTZ to protect the monument and public health.
3. Whether constitutional and statutory duties required public authorities to take effective, time-bound action to control industrial air pollution affecting a nationally and internationally significant monument.

## Decision

- The Court accepted that industrial emissions in the TTZ, especially from coal/coke use producing SO₂, posed a serious risk to the Taj Mahal and the surrounding environment.
- Industries in the TTZ using coal/coke were directed to stop using those fuels and to switch to natural gas where supply and connectivity were made available.
- Industries that did not switch to natural gas within the time allowed, or that could not be supplied with gas, were required to relocate outside the TTZ to designated areas developed for that purpose.
- Units that failed to comply with the fuel-switching or relocation directions within the prescribed schedule were liable to be closed/stopped from operating.
- Government agencies and public bodies were directed to take implementation steps, including facilitating gas supply arrangements and creating relocation sites and infrastructure.
- The Court included protections for affected workers tied to closure or relocation, such as payment-related directions and continuity-related measures linked to relocation, to reduce hardship.
- The Court maintained ongoing oversight through compliance reporting and further orders, treating the matter as requiring continuing judicial supervision to secure implementation.

## Legal Principles

- The right to life under Article 21 includes the right to live in a clean and healthy environment; serious air pollution affecting health and the environment can justify relief under Article 32.
- The State has affirmative obligations to protect public health and the environment (Articles 47 and 48A) and citizens have a duty to protect and improve the natural environment (Article 51A(g)); these constitutional norms support strong remedial directions.
- Precautionary principle: where there is a credible threat of serious or irreversible environmental harm, protective action should not be delayed for want of complete scientific certainty.
- Polluter pays principle: industries responsible for pollution must bear the costs of preventing and controlling pollution, including costs tied to cleaner technology, fuel conversion, and other compliance measures, rather than shifting those burdens to the public.
- Sustainable development: industrial activity may continue only subject to conditions that prevent unacceptable damage to the environment and cultural heritage; cleaner fuel use and relocation were treated as mechanisms to reconcile industrial activity with environmental limits.
- Continuing mandamus in environmental public-interest cases: the Court may issue staged directions and require periodic reporting to ensure execution by public authorities and regulated entities.

## Conclusion

In *M.C. Mehta v. Union of India (Taj Trapezium Matter), 2 SCC 353 (1997)*, the Supreme Court treated industrial air pollution in the TTZ as a direct threat to the Taj Mahal’s marble and to public health, and ordered coal/coke-using units to switch to natural gas or relocate outside the TTZ, backed by closure for noncompliance, worker-protection measures, and continuing court supervision grounded in precaution, polluter-pays liability, and the Article 21 right to a healthy environment.
