Supreme Court strikes down Maharashtra's methanol additive rules

The brief in 7 cards

1. Context1 / 7
   • In 1991, about 250 people in Andheri, Mumbai drank spurious liquor at Chhaya Bar. It contained methanol, and 93 of them died.
   • A committee led by P.R. Parthasarthy studied the tragedy. In 2011, Maharashtra used one of its ideas to add Rules 18A and 18B to its Poisons Rules, 1972.
   • Methanol-using manufacturers, including Balaji Formalin Pvt. Ltd., challenged the rules.
   • On 18 September 2026, a bench of Justices J.B. Pardiwala and K. Vinod Chandran struck both rules down.
   • The court held they violated Article 14 (equality) and Article 19(1)(g) (the freedom to carry on trade or business).
2. Key highlights2 / 7

   What Rule 18A did: Sellers had to check the buyer's licence. Except for drug makers, every 100 litres of methanol needed 1 g of a red dye and 4 g of a bitter chemical.

   What Rule 18B did: Methanol held without a Form A licence could be confiscated.

   Aim accepted: The court agreed that preventing deaths from methanol-laced liquor is a legitimate goal.

   Means rejected: The additives did not stop methanol from being diverted through illegal channels. They only controlled lawful sales.

   Real harm to industry: One maker said its product, paraformaldehyde, is sold as white crystals, so a red dye made it unacceptable to buyers.

   Unworkable licensing: Form A did not record how the buyer would use methanol. Demanding it also made the separate Form B permit pointless.

3. Key concepts3 / 7
   1. The doctrine of proportionality

   • Proportionality is a test courts use to check whether a restriction on a right goes too far.
   • The Supreme Court set out its four steps clearly in K.S. Puttaswamy v. Union of India (2017):
   • Legitimate aim: Is the goal valid?
   • Suitability: Does the measure actually help achieve it?
   • Necessity: Is there a less restrictive way that works as well?
   • Balancing: Is the harm to the right out of proportion to the benefit?
   • Analogy: closing an entire highway because a few drivers speed. The aim is valid, but speed cameras would do the job with far less harm.

   News connection: The rules passed the first step but failed suitability and necessity. Stock tracking and licence checks were gentler options.

   2. Article 19(1)(g) and reasonable restrictions

   • Article 19(1)(g) gives every citizen the freedom to practise any profession or carry on any occupation, trade or business.
   • Article 19(6) lets the State impose reasonable restrictions on this freedom in the interest of the general public.
   • A restriction is reasonable only if it is connected to its purpose and does not go beyond what is needed.

   News connection: The court found the additive rules placed an unreasonable, continuing burden on lawful methanol users.

   3. Article 14 and manifest arbitrariness

   • Article 14 guarantees equality before the law and equal protection of the laws.
   • Courts have held that a law or rule that is manifestly arbitrary also violates Article 14. That means a rule that is irrational, excessive or made without an adequate reason.
   • A rule with no sensible link, or rational nexus, to its objective fails this test.

   News connection: The court held that the rules lacked a reasonable link to their goal, making them arbitrary.

   4. Delegated legislation and judicial review

   • Delegated (subordinate) legislation means rules made by the executive under power given by an Act of Parliament or a State legislature.
   • Here, the parent law is the Poisons Act, 1919. Maharashtra made its rules under it.
   • Courts can strike down such rules if they exceed the parent Act or violate Fundamental Rights. This power is part of judicial review.
   • Analogy: a manager given authority by the company board must still follow company rules and the law.

   News connection: Rules 18A and 18B were delegated legislation, and the court struck them down for violating Fundamental Rights.

4. Way forward4 / 7

   Track methanol from factory to user: Require purchase, stock and use records, so unexplained shortages point to diversion.

   Act together: Police, excise, transport, industry and health departments should coordinate against illicit liquor networks.

   Treat the demand side: Expand de-addiction and counselling services, since bans alone push drinking underground.

5. Note5 / 7

   The court's suggested framework

   The court suggested targeted measures that focus on where methanol actually leaks, not on every lawful user:

   Licensing: Verify licences properly and review them periodically.

   Traceability: Keep records of every purchase, stock and use.

   Returns: Industrial users should return unused or excess methanol.

   Secure transport: Use dedicated tankers, supervision and tamper-proof seals.

   Penalties: Suspend or cancel licences for violations, and investigate suspected diversion.

   The principle: Regulation should target the point of diversion, rather than burdening every legitimate user in the same way.

6. Note6 / 7

   The science: why methanol kills

   Two alcohols: Ethanol (C₂H₅OH) is the alcohol in drinks. Methanol (CH₃OH) is an industrial chemical used to make formaldehyde, paints and resins.

   Hard to tell apart: Methanol is colourless and smells like drinking alcohol. That makes it easy to mix into illicit liquor.

   How it harms: The body breaks methanol down into formaldehyde and formic acid. These can cause blindness and death.

   Denaturation: Adding dyes or bitter chemicals to make alcohol unfit to drink is called denaturation. The bitter chemical used here is also added to some household products to stop accidental swallowing.

   Why it failed here: A dye and a bitter taste warn honest users. They do little when criminals obtain methanol through illegal channels.

7. Note7 / 7

   Prohibition and the Constitution

   Article 47: A Directive Principle asks the State to try to prohibit intoxicating drinks, except for medicinal purposes.

   Directive Principles are not enforceable: Courts cannot compel the State to impose prohibition.

   A State subject: "Intoxicating liquors" falls in the State List of the Seventh Schedule. Each State decides its own liquor policy.

   The court's warning: The bench observed that total alcohol bans often push the liquor trade underground. This raises the risk of unregulated, deadly brews.

   Forced temperance: The court said that enforced abstinence alone does not solve alcoholism.

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