Landmark Environmental Judgments in India: Part 2
Landmark Environmental Law Cases in India
Environmental protection and sustainable development are no longer just policy matters—they’re a constitutional necessity. The judiciary in India has played a pivotal role in strengthening environmental jurisprudence through landmark rulings.
This blog brings a simplified yet insightful overview of key cases that shaped India’s environmental legal framework.
1. Vellore Citizens Welfare Forum v. Union of India[1]
The Supreme Court heard this PIL under Article 32, filed by the Vellore Citizens Welfare Forum against pollution caused by tanneries in Tamil Nadu. Untreated chemical waste discharged into the Palar River—main drinking water source—had rendered around 35,000 hectares of farmland unfit for use.
The court acknowledged that while tanneries contributed to employment and export revenue, their environmental damage couldn’t be ignored. Each tannery was fined ₹10,000 and the State was directed to award ₹50,000 to M.C. Mehta for his environmental activism.
This case introduced the Precautionary Principle and the Polluter Pays Principle into Indian law. The Supreme Court also advocated for creating special Green Benches for faster disposal of environmental cases.
2. M.C. Mehta v. Union of India (Ganga Pollution Case)[2]
M.C. Mehta filed a PIL addressing the pollution in the Ganga near Kanpur, where tanneries and open drains dumped untreated waste directly into the river. The court rejected the defense that tanneries lacked funds to set up treatment plants.
The court held that just as industries must pay minimum wages, they must also bear the cost of pollution control. Orders included: closing non-compliant tanneries, expanding sewer networks, banning disposal of dead bodies in the river, and public awareness measures in theatres.
3. Andhra Pradesh Pollution Control Board v. M.V. Nayudu[3]
This case revolved around denial of consent by the A.P. Pollution Board to a Red Category industry proposed near Hyderabad’s drinking water sources. The High Court allowed the project, but the Supreme Court reversed that decision.
The Court emphasized the Precautionary Principle, stating that in cases of scientific uncertainty, the burden lies on the project proponents. It warned that unchecked industrialization could lead to irreversible ecological harm.
4. S. Jagannath v. Union of India[4]
This PIL challenged commercial shrimp farming near coastal zones, citing groundwater contamination and displacement of traditional fishing.
The Court observed that shrimp farms violated environmental norms and infringed on the right to livelihood. It banned such aquaculture near the coast, directed compensation for affected persons, and mandated environmental clearance under EPA, 1986.
5. Goa Foundation v. Konkan Railway Corporation[5]
Though filed to prevent rail construction without proper Environmental Impact Assessment (EIA), the Court balanced development needs with environmental concerns.
Acknowledging ecological risks, the Court dismissed the petition, stating development projects must aim to reduce, not eliminate, environmental impacts, and such assessments are best left to experts.
6. Narula Dyeing and Printing Works v. Union of India[6]
Here, the Gujarat government directed closure of dyeing units for violating effluent treatment norms. The petitioners challenged these directions.
The Court upheld the government’s decision, stating that under Section 25 of the Water Act, industries must comply with pollution control conditions. Environmental protection cannot be compromised for industrial convenience.
7. Indian Council for Enviro-Legal Action v. Union of India[7]
Five chemical factories in Rajasthan released toxic H-acid waste, damaging water and soil across 350 hectares. The Court ordered closure of these units and imposed a ₹4 crore compensation.
This case applied the Absolute Liability principle (beyond strict liability) and highlighted the failure of the Pollution Control Board to act under multiple environmental statutes. It led to strong directives, including the establishment of Green Benches.
8. Bombay Environmental Action Group v. State of Maharashtra[8]
The petitioner challenged clearance for a thermal power plant near an ecologically sensitive zone. The court, while acknowledging environmental risks, emphasized balancing ecological protection with energy needs in a developing country.
Although the MoEF’s clearance violated CRZ norms, the court upheld the project, noting that national interest required uninterrupted electricity supply.
9. M.C. Mehta v. Union of India (Oleum Gas Leak Case)[9]
After oleum gas leakage from Shri Ram Fertilizers in Delhi, M.C. Mehta filed a PIL demanding accountability. The Court introduced the doctrine of Absolute Liability, holding hazardous industries fully liable for any damage, regardless of negligence.
It also directed the creation of a Green Belt around such industries and mandated ₹20 lakh security deposit for compensating victims. This case remains a cornerstone in Indian environmental law.
Conclusion
These cases reflect how Indian courts have evolved environmental principles such as sustainable development, public trust, precautionary approach, and absolute liability. The judiciary has repeatedly affirmed that while development is vital, it cannot come at the cost of nature and human life.
Endnotes
[1] Vellore Citizens Welfare Forum v. Union of India, AIR 1996 SC 2715.
[2] M.C. Mehta v. Union of India, 1987 SCR (1) 819.
[3] A.P. Pollution Control Board v. M.V. Nayudu, AIR 1999 SC 812.
[4] S. Jagannath v. Union of India, (1997) 2 SCC 87.
[5] Goa Foundation v. Konkan Railway Corporation, AIR 1992 Bom 471.
[6] Narula Dyeing and Printing Works v. Union of India, AIR 2000 Guj 20.
[7] Indian Council for Enviro-Legal Action v. Union of India, (1996) 3 SCC 212.
[8] Bombay Environmental Action Group v. State of Maharashtra, AIR 1992 Bom 301.
[9] M.C. Mehta v. Union of India (Oleum Gas Leak Case), AIR 1987 SC 965.
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