Three babies have been named on a petition urging India's top court to ban air-polluting fireworks in New Delhi, saying the city's choking smog poses a "clear and present danger" to their health.

The parents of the three babies, all residents of the world's most polluted capital aged six months and under, argue that they have a constitutional right to breathe clean air -- a hot topic ahead of UN-led talks in Paris on reducing greenhouse gas emissions.

They say children are particularly vulnerable to air pollution, which can cause a range of problems from lung disease to retarded development of the nervous system, and want the court to ban the sale and use of smoke-belching firecrackers.

India's Supreme Court allows minors to file petitions through their parents where there is a threat to their fundamental rights.

The petition was filed on Tuesday, six weeks before the Hindu festival of light known as Diwali, when Delhi neighbourhoods traditionally fill with acrid smoke from celebratory firecrackers set off day and night.

"The imminent advent of festivals that involve widespread fireworks are a clear and present danger to the health of the applicants and the other children who are residents of Delhi," it said.

"The ill-effects on the lungs and the central nervous systems of the applicants will be irreversible as against the ephemeral and superficial joy that obtains when a firecracker is employed."

A World Health Organization study of 1,600 cities released last year showed Delhi had the world's highest annual average concentration of small airborne particles known as PM2.5 -- higher even than Beijing.

These extremely fine particles of less than 2.5 micrometres in diameter are linked to increased rates of chronic bronchitis, lung cancer and heart disease as they penetrate deep into the lungs and can pass into the bloodstream.

India will on Thursday unveil its carbon emissions pledges before the start on November 30 of the Paris conference, which aims to seal a far-reaching new global climate agreement.