M.C. Mehta v. State of Tamil Nadu
Rule established
State has a constitutional obligation to eliminate child labour in hazardous industries. Prohibition must be accompanied by rehabilitation (education fund, alternative employment for parents).
Facts
- M.C. Mehta filed PIL highlighting widespread child labour in Sivakasi (Tamil Nadu)
- Children (under 14) employed in match factories, fireworks units, and allied industries
- Hazardous, life-threatening conditions: chemical exposure, fire risk, explosions
- State government failed to enforce Article 24 (prohibition of child labour in hazardous employment)
- Thousands of children employed in violation of the Child Labour (Prohibition and Regulation) Act, 1986
Issues
- Whether the State has a constitutional obligation to eliminate child labour in hazardous employment
- What framework should be adopted for rehabilitation of child workers
Held
- State has an absolute constitutional obligation under Article 24 to eliminate child labour in hazardous industries
- Prohibition alone is insufficient; must be accompanied by rehabilitation
- Five-point framework directed:
- Survey and identification of all child workers in hazardous employment
- Withdrawal of children from hazardous work
Ratio Decidendi
The State is constitutionally bound under Article 24 to eliminate child labour in hazardous industries. Prohibition must be paired with a rehabilitation framework: education for the child and livelihood support for the family.
How to use it in an exam
- The primary authority for child labour problems in Part C
- Use the five-point framework in any child labour exam answer
- Also relevant for Part B on Child Labour Act
- Key line: "In M.C. Mehta v. State of Tamil Nadu (1996), the Supreme Court held that the State has an absolute constitutional obligation under Article 24 to eliminate child labour in hazardous industries, and laid down a five-point rehabilitation framework."
Source
Source: AIR 1997 SC 699; verified from chapter frontmatter
This is an educational summary, not the judgment itself. Cite the reported version in professional or academic work.