Supreme Court -M.C. Mehta Case on Delhi Master Plan and Urban Development

Case Name: M.C. Mehta v. Union of India & Ors.

Citation: I.A. Nos. 203615 & 218080 of 2024 and I.A. No. 210981 of 2025 in W.P.(C) No. 4677 of 1985
Date of Judgment/Order: 31 October 2025
Bench: Hon’ble Mr. Justice B. R. Gavai (CJI) and Hon’ble Mr. Justice K. Vinod Chandran

Held:  The Supreme Court of India, in this 2025 judgment on the Delhi Master Plan, ruled that only the ground floor of Shop No. 106, New Rajinder Nagar Market (LSC), Delhi, could be used commercially. The upper floors were sanctioned as residential and can be converted to commercial use only after payment of statutory conversion and penalty charges. The Court emphasized adherence to the Delhi Master Plan 2021 and sustainable-development norms.

Summary: In this continuation of the long-running M.C. Mehta environmental PIL, the applicant sought de-sealing of his premises citing a 2023 Judicial Committee order. The Supreme Court Judgment 2025 examined the Delhi Master Plans (1962, 2001 and 2021) and the limits of the Monitoring Committee’s authority. It held that factual review of each property is essential and that the Judicial Committee’s general findings cannot override individual compliance.

After scrutinizing lease deeds, L&DO records and sanctioned plans, the Bench found no proof that upper floors were ever authorized for commercial use. The 2005 sanctioned plan itself described residential facilities—kitchen and bedrooms—clearly classifying them as residential. Under MPD-2021, New Rajinder Nagar is a designated shop-cum-residence Local Shopping Centre (LSC); conversion to full commercial usage requires payment of conversion charges and rectification of deviations.

Decision: Applications dismissed. The Supreme Court Judgment 2025 directed the Municipal Corporation of Delhi (MCD) to issue a fresh inspection notice, identify non-compoundable portions, compute conversion/penalty charges, and permit regularisation only after compliance. The ruling reinforces lawful use of property under the Delhi Master Plan and sets precedent for similar urban-development cases.