Discuss the doctrine of proportionality as applied by the Supreme Court in reviewing subordinate legislation, with reference to a recent judgment on industrial chemical regulation.

Proportionality asks whether a restriction on a right goes further than the objective requires. Formalised for Indian law in Modern Dental College v. State of M.P. (2016) [2], it was applied to strike down state rules on methanol in M/s Balaji Formalin Pvt. Ltd. v. Union of India (2026 INSC 1009) [1].

The four-pronged test

• Legitimate goal — the restriction must pursue a proper public purpose [2].
• Rational connection — the measure must be a suitable means to that goal [2].
• Necessity — no equally effective, less restrictive alternative should exist [2].
• Balancing — the harm to the right must not outweigh the public gain; Article 19(6)'s "reasonable restrictions" itself embeds this idea [2].

Why it binds subordinate legislation

• Rules framed under a parent statute — here, State rules under Section 2 of the Poisons Act, 1919 [3] — must stay within the delegation and satisfy Articles 14 and 19.
• Judicial review has thus moved from mere Wednesbury deference to structured scrutiny, testing manifest arbitrariness in the rule's design [1].

Application in the methanol case

• Rules 18A and 18B, Maharashtra Poisons Rules, 1972 (inserted 2011 after the 1991 Mumbai hooch tragedy) required a colourant and bitterant in methanol sold to non-drug manufacturers [1].
• The goal — preventing deaths from spurious liquor — was legitimate, but the Court found no sufficient nexus: the rules did not check the real problem of diversion and pilferage [1].
• They imposed a continuing compliance burden on lawful users of methanol as feedstock for formaldehyde, resins and paints — held disproportionate, violating Articles 14 and 19(1)(g) [1].
• The Court simultaneously directed coordinated, multi-department action by States and UTs against illicit liquor [1].

Proportionality therefore disciplines regulation without disarming it: the State may still act on public health, provided the means are targeted, evidence-based and least restrictive. Rule-making departments should build such impact assessment into delegated legislation, aligning regulatory design with both Article 19(6) and the ease-of-doing-business objective.