A law was made by Parliament on a State Subject, for giving effect to an International agreement signed by India. The law was challenged as Violative of Scheme of Centre-State Relations. Decide with reasons.

Facts of the Case

1. The Government of India entered into an international agreement with several foreign countries concerning environmental protection and regulation of industries causing pollution.
2. To implement this international obligation, the Parliament of India enacted a law that imposed certain restrictions on industries and business operations within the States.
3. The law primarily dealt with subjects falling under the State List, particularly public health, sanitation, industries, and environment, which are matters ordinarily under the State’s legislative jurisdiction.
4. One of the affected States challenged this Parliamentary enactment before the Supreme Court, arguing that the Union Parliament encroached upon the State’s legislative powers, thereby violating the federal structure and distribution of legislative powers under the Constitution.
5. The central issue for determination is whether the Parliament can make a law on a State subject in order to fulfil an international obligation undertaken by India.

Issues in the Case

1. Whether Parliament has the constitutional power to legislate on a State subject when it is necessary to implement an international treaty or agreement.
2. Whether such legislation violates the federal distribution of powers under Articles 245 and 246 read with the Seventh Schedule.
3. Whether the international obligations of India can override the ordinary distribution of legislative competence between the Centre and the States.
4. Whether the State’s autonomy in its sphere of legislation is compromised by such Parliamentary action.

Legal Principles Covered

A. Constitutional Provisions

1. Article 245 – Extent of laws made by Parliament and State Legislatures.
   • Parliament may make laws for the whole or any part of the territory of India.
   • A State Legislature may make laws for the whole or any part of the State.
2. Article 246 – Distribution of legislative powers.
   • List I (Union List): Exclusive power of Parliament.
   • List II (State List): Exclusive power of the State Legislature.
   • List III (Concurrent List): Power shared by both.
3. Article 253 – Legislation for giving effect to international agreements.
   • Parliament has power to make any law for the whole or any part of India for implementing any treaty, agreement, or convention with any other country, notwithstanding anything in the distribution of legislative powers under Article 246 or the Seventh Schedule.
4. Article 51(c) – Directive Principle of State Policy.
   • The State shall endeavour to foster respect for international law and treaty obligations.

B. Judicial Precedents

1. Maganbhai Ishwarbhai Patel v. Union of India (1969) 3 SCC 202
   • The Supreme Court held that Parliament is empowered under Article 253 to make laws even on State subjects to implement international obligations undertaken by India.
2. Union of India v. H.S. Dhillon (1972) 2 SCC 779
   • The Court emphasized that Article 253 confers overriding power on Parliament to legislate in matters even falling under the State List if required to fulfil international obligations.
3. State of West Bengal v. Kesoram Industries Ltd. (2004) 10 SCC 201
   • The Court reaffirmed that while federalism is a basic feature, the Constitution provides certain exceptions where the Union may legislate in the State field, including for implementing international treaties.

C. Principle of Federal Supremacy

• When there is a conflict between Union and State laws, the Union law prevails under Article 246(1) and Article 254.
• Article 253 acts as an exception to the normal distribution of powers, allowing Parliament to override the State List to ensure international obligations are implemented uniformly.

Possible Judgement

1. The law made by Parliament is constitutionally valid under Article 253 of the Constitution.
2. Although the subject matter ordinarily falls under the State List, Parliament can legislate on it to implement an international agreement.
3. The federal structure is not violated, as the Constitution itself expressly permits this in order to uphold India’s international commitments.
4. The challenge by the State government fails, since international cooperation and implementation of treaties require uniform national legislation, which cannot be effectively achieved through individual State laws.
5. The Supreme Court would therefore uphold the validity of the Parliamentary law as intra vires (within its powers) and consistent with India’s constitutional framework.

Final Opinion:
The law enacted by Parliament is valid. The power under Article 253 overrides the normal scheme of Centre-State legislative distribution when the object is to implement an international treaty or agreement signed by India.

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