Beyond M.C. Mehta: Constitutionalizing Climate Justice and State Accountability Under Article 21

The jurisprudential terrain of Indian environmental law has been changed radically, near seismically, into a less reactive paradigm of pollution control and more expansively and intricately into the constitutionalization of climate justice. For a few decades, the principles set in the landmark case of M.C. Mehta v. Union of India - in particular, the principles of absolute liability, the deep pocket principle, and the factoring environment into the right to life enshrined in Article 21 of the Constitution of India were the unquestioned sources of environmental law. But the existential, diffuse threat of climate change has inexorably revealed the limitations of this traditional highly localized jurisprudence of the environment. This study is an in-depth examination of the paradigm shift which was ushered in by the Supreme Court of India in the landmark of 2024 judgment of M.K. Ranjitsinh v. Union of India, the first of its kind to clearly and explicitly acknowledge a fundamental right against the harmful impact of climate change. Through a clever combination of Article 14, which ensures the right to equality, with Article 21, which ensures the right to life, the courts have in effect made climate vulnerability a burning constitutional crisis. This ideological gimmick places positive obligations on the State, which are justiciable, not only to reduce the effects of climate but also to actively defend the communities that are marginalized and significantly subjected to it. The paper uses a strict doctrinal and comparative research design to examine the mechanisms of state accountability under the glaring lack of an overall statutory climate framework. It critically evaluates the inadequacies of old legislations, i.e. the Environment (Protection) Act of 1986 that does not have greenhouse gas measures and accountability mechanisms and consequently compels the courts to intervene, possibly unwillingly, as emergency constitutional measures. Moreover, the study places the judicial activism in India into a cross-national conversation, and makes comparative conclusions related to international climate litigation, such as the Urgenda and KlimaSeniorinnen cases, to question the fragile fabric of the separation of powers. Their results indicate that, though the articulation of climate rights by the judiciary is a monumental stride in ecocentric constitutionalism, the practical effectiveness of such a move is cripplingly limited by constitutional legislative blank spaces, the complications of polycentric governance, and structural remnants, though diminished, of sovereign immunity. The paper ends with specific legal reform recommendations, which propose the immediate implementation of the overall climate law and mandatory carbon budgeting, which would make the judicial directives a practical measure of state responsibility.