Pollution control and public health are largely matters that the Constitution leaves to the States under the State List, which makes sense given how closely they are tied to local conditions and local administration. But air pollution does not respect state boundaries, and by the late 1970s it was clear that a patchwork of different state laws would not adequately address it, so there needed to be a route for Parliament to step in with a single, uniform law.
The Constitution actually provides more than one such route, and it matters which one was used. Article 253 lets Parliament legislate to implement an international treaty or agreement, bypassing the usual Union-State division of powers entirely; this was the route used later for the Environment (Protection) Act, 1986, which followed directly from India's commitments after the Stockholm Conference. Article 252 works differently: it lets Parliament legislate on a State List subject only if two or more State Legislatures pass resolutions specifically asking Parliament to do so, and the resulting law then applies to those consenting states, with others free to adopt it later by their own resolution.
The Air (Prevention and Control of Pollution) Act, 1981 followed the Article 252 route: several states passed resolutions requesting Parliament to legislate uniformly on air pollution, and Parliament acted on that basis. Article 233 is entirely unrelated, since it only concerns how district judges are appointed, and since Article 252 is the applicable provision, there is no basis for saying no article applies at all.
So the primary legislative basis for the Air Act, 1981 is Article 252, resting on the state resolutions Parliament received under that provision.