Supreme Court strikes down Maharashtra rule forcing bitterant and colourant into industrial methanol
A Division Bench holds the 2011 Maharashtra Poisons Rules amendment violates Articles 14 and 19(1)(g), finding it a disproportionate restriction on manufacturers who use methanol as raw material.
The Supreme Court has struck down a Maharashtra rule that required a bitterant and a colourant to be added to methanol before it could be sold to non-drug manufacturers. In M/s Balaji Formalin Pvt. Ltd. v. Union of India, decided on 18 September 2026, a Division Bench of Justice J.B. Pardiwala and Justice K. Vinod Chandran held that the 2011 notification amending the Maharashtra Poisons Rules was violative of Articles 14 and 19(1)(g) of the Constitution. The petitions were allowed and a connected civil appeal disposed of in the same terms, with the Court directing its judgment to be circulated to every High Court and Chief Secretary.
A rule aimed at hooch, applied to a raw material
By the notification dated 21 January 2011, issued by the Medical Education and Drugs Department, the Maharashtra Poisons Rules were amended so that a denaturant — a bitterant together with a colourant — had to be mixed into methanol before its sale, except where methanol was being purchased for the manufacture of drugs as certified by the Food and Drug Administration. The stated object was to curb the drinking of methanol, a poisonous alcohol whose illicit consumption causes deaths.
The petitioners, including manufacturers of formaldehyde and formalin and an industry association, use methanol not as a beverage but as a key feedstock. Methanol is a raw material in products such as formaldehyde, paraformaldehyde, disinfectants, decorative laminate, paint and resin. Their case was that once a colourant and bitterant were forced into the methanol, the contaminated input degraded their final products, sounding what the Court described as the death knell of an industry that depends on clean methanol.
The proceedings below
The challenge had earlier failed. The High Court dismissed the writ petitions and upheld the validity of the notification, leaving the manufacturers to carry the matter to the Supreme Court. The batch before the Supreme Court included writ petitions filed directly, along with a civil appeal arising from a special leave petition against a decision of the High Court of the State of Maharashtra, all heard analogously and disposed of by the common judgment.
The State defended the rule as a measure to protect life, arguing that it regulated only sale, not the manufacture or import of methanol, and that adding a bitterant made accidental or intentional consumption less likely. It asked the Court to vacate the interim protection that had suspended enforcement of the notification.
Why the rule failed the proportionality test
The Court framed the question as whether the impugned rules could be said to be arbitrary, disproportionate and unreasonable. It found that they were. Adulterating methanol with a bitterant and colourant, the Bench observed, would not quell the craving that drives illicit consumption, so the measure did not squarely serve its own object. At the same time it inflicted serious harm on legitimate users for whom methanol is a raw material, since the mandated denaturant would carry through into their manufactured products.
Applying a proportionality analysis, the Court held the restriction to be excessive: the State’s object could have been achieved by a less drastic restriction, and the notification went wider than necessary while leaving the real mischief unserved. Measured against the standard for striking down subordinate legislation — that it be manifestly arbitrary, irrational or disproportionate — the rule crossed the line. It was therefore held to violate the guarantee of equality under Article 14 and the freedom to carry on trade or business under Article 19(1)(g).
What the Court preserved
The judgment did not disturb the State’s power to regulate genuinely poisonous substances; it faulted the specific means chosen. The carve-out for methanol purchased for certified drug manufacture illustrated, in the Court’s reasoning, that the State itself recognised legitimate industrial use — yet the rule burdened other legitimate users of methanol as a raw material without a corresponding gain in safety.
Order
Holding the impugned rules violative of Articles 14 and 19(1)(g), the Court allowed the petitions in those terms and disposed of the pending applications. The connected civil appeal was disposed of in the same terms. The Registry was directed to forward a copy of the judgment to all the High Courts and to the Chief Secretaries of the respective States.