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Environment Law Project

Submitted by: - Yasharth Kant Srivastava Roll No: - 154 Semester VI Section B
Dr Ram Manohar Lohiya National Law University

1. DefinitionPage 2 2. History of Sustainable DevelopmentPage 2 3. Sustainable Development in IndiaPage 3 4. Precautionary Principle.Page 4 5. Polluter Pays PrinciplePage 4 6. Mechanism for assessment of sustainable development..Page 5 7. Sustainable Development as part of our Constitution.Page 6 8. Judicial Approach...Page 8 9. Conclusion...Page 12 10. BibliographyPage 14


Sustainable Development is a process in which development can be sustained for generations. It means improving the quality of human life while at the same time living in harmony with nature and maintaining the carrying capacity of the life supporting ecosystem. Development means increasing the societys ability to meet human needs. Economic growth is an important component but cannot be a goal itself. The real aim must be to improve the quality of human existence to ensure people to enjoy long, healthy and fulfilling life. Brundtland Commission puts it as development that meets the needs of the present meets without compromising the ability of future generations to meet their own needs. The needs. field of sustainable development can be conceptually broken into three constituent parts: parts: (i) environmental sustainability, (ii) economic sustainability and (iii) socio-political sustainability. socio-political


The sustainability idea emerged in a series of meetings and reports during the 1970s and 1980s, besides there is a timeline of some important sustainable development events in the United Nations, the Government of Canada and Human Resources Development Canada. In 1972, the UN Stockholm Conference on the Human Environment marked the first great international meeting on how human activities were harming the environment and putting humans at risk. The 1980 World Conservation Strategy, prepared by the International Union for the Conservation of Nature along with the UN Environment Program and the World Wildlife Fund, promoted the idea of environmental protection in the selfinterest of the human species. 3|Page

In 1987, the UN-sponsored Brundtland Commission released Our Common Future, a report that captured widespread concerns about the environment and Future, poverty in many parts of the world. The Brundtland report said that economic development cannot stop, but it must change course to fit within the planet's ecological limits. It also popularized the term sustainable development. World attention on sustainability peaked at the 1992 UN Conference on Environment and Development, in Rio de Janeiro. It brought together the 179 nations and included the Earth Summit, the largest-ever meeting of world leaders. Rio produced two international agreements, two statements of principles and a major action agenda on worldwide sustainable development.1 In the year 2002, that is ten years after the Earth Summit in Rio, the World Summit for Sustainable Development was held in Johannesburg. Here Canada submitted a document reflecting the progress of all federal departments.


Although India has traditional institutions, practicing Sustainable Development, the Rio Summit 1992 and WSSD 2002 commitments have changed our policy and plan. To achieve sustainable development, the National Conservation Strategy (NCS) formulated in 1990 has six primary principles. They are - (i) Stabilization of population growth; (ii) Integrated land use and water management; (iii) Conservation of biological diversity; (iv) Sustainable energy and resource utilization; (v) Pollution control; and (vi) Improvement of human habitats. Followed by NCS, Environmental Action Program (EAP) and National Forestry Action Plan (NFAP) were formulated towards the objective of Sustainable Development of India. Three important government contributions to environment and sustainable development over the past one and half decades are summarized below: Establishment of basic infrastructure and institutions at Central and State levels;


Formulation and enforcement of policy and legal instruments. Example: Conservation Strategy, Amendment of outdated Acts or Enactment of comprehensive new ones like the Forest Conservation Act and the Environment (Protection) Act; and Implementation of programs and projects for SD. During the late 1970s and early 1980s, many people argued that development must take priority over environmental concerns and that environment was an elitist concern -meant only for the rich. In 1982, the first citizens report on the State of Indias Environment, which Agarwal conceptualised and edited, provided the social rationale for Environment, developing countries to take environmental concerns into account. It resolved the environment vs. development debate globally and finally evolved into the concept of sustainable development in the Brundtland Commission report. The interest in sustainability that flourished during that period was spurred by a series of incidents and discoveries, including the leak of poisonous gas from a chemical plant at Bhopal, India, the explosion and radioactive release from Chernobyl, Ukraine, the hole in the Antarctic ozone layer, leaking toxic chemical dumps, such as Love Canal, general fears about chemical contamination and conflicts over decreasing natural resources such as forests and fisheries.2

The principles states that the Government and the statutory bodies must take environmental measures to anticipate prevent and attack the causes of environmental degradation. Where there are threats of serious and irreversible damage, lack of scientific certainty should not be used as a reason for postponing measures to prevent environmental degradation. In these circumstances the onus of proof is on the actor or the developer/industrialist to show that his action is environmentally benign.3


2 3 MC Mehta vs. Union of India, AIR 1997 SC 734


Polluter Pays Principle (PPP) has been developed by the Organisation of Economic Cooperation and Development (OECD) as one of the principles for allocation of entitlements. The principle basically means that the producer of goods or other items should be responsible for the costs of preventing or dealing with pollution which the process causes. This includes environmental costs as well as the direct costs to property or people. PPP finds a prominent place in the Rio Declaration of 1992. Principle 16 of the Declaration proclaims that national authorities should endeavour to promote the internalisation of environmental costs and the use of economic instruments, taking into account the approach that the polluter should, in principle, bear the cost of pollution, with due regard to the public interest and without distorting international trade and investment.4 As per this principle once the activity carried on any person or industry is hazardous or inherently dangerous, the person carrying on such activity is liable to make good the loss caused to any other person by his activity irrespective of the fact whether he took reasonable care while carrying on his activity.5 Thus the purpose of Sustainable Sustainable development is to ensure that the developmental activities must be carried on but at the development same time if they adversely affect the environment or the ecology in any manner then the consequence is the polluting industries are absolutely liable to compensate for the harm caused by them to people in the affected area, to the soil and to the underground water and hence, they are bound to take all necessary measures to remove sludge and other pollutants lying in the affected areas.6


ENVIRONMENT IMPACT ASSESTMENT Environment Impact Assessment (EIA) is a technique to ensure that the likely effects of development activity on the environment will be taken into consideration before the development activity is authorised to proceed.

4 5

Gurdip Singh, Environmental Law in India, (McMillan India Ltd., Delhi, 1st Edn., 2005), pg. 31 Enviro-Legal Action v. Union of India, MANU/SC/1112/1996 6 Indian Council for Environ-Legal Action v. Union of India, MANU/SC/1189/1996


ENVIRONMENT AUDIT Environment audit means self-assessment of the environmental performance of the developer. It is concept which enables the developers to produce environmental strategies after reviewing their environmental performance i.e., whether there has been compliance of legal or fiscal environmental regulations, conformity to developers environmental policies, what reductions in wastes have been brought about, and what efficiency has been achieved in the use of energy and the raw material. The precautionary principle is applicable as a part of the audit system. The continual nature of the concept requires that developers must draw up annual environment statement which shall be audited by independent auditors. To implement precautionary principle which strengthens the edges of environmental jurisprudence, environmental audit must be made mandatory at the international as well as national levels.7


Judiciary in India has played a pivotal role in interpreting those laws to suit the doctrine of Sustainable Development. Before dealing with the case laws with respect to the environmental matters as appreciated by the Indian Judiciary we must first look into the various laws and provisions laid down by the legislatures to protect the environment and maintain the ecology vis-a-vis promoting the developmental aspectsARTICLE 14 Article 14 of the Constitution of India ensures the equality before law and equal protection of the laws. While awarding the sanction to the industrial projects or granting license to these units the government must not act arbitrarily thus granting the permission to them without even considering the environmental impact of these projects and proper assessment report.8 Right to healthy environment is the legitimate expectation, an aspect protected under Article 14 of the Constitution of India.

Shyam Divan, Armin Rosencranz, Environmental Law and Policy in India, (Oxford University Press, New Delhi, 5th ed., 2004), pg.43 8 Ramgopal Estates Pvt. Ltd. vs. The State of Tamil Nadu, MANU/TN/7948/2007


ARTICLE 21 As per this article every citizen has the right to life and personal liberty. Slow poisoning by polluted atmosphere should also be regarded as amounting to violation of article 21 of Indian constitution.9 In Virender Gaur v. State of Haryana,10 it was observed that article Haryana, 21 protects right to life as a fundamental right, enjoyment of life including the right to live human dignity encompasses within its ambit, the protection and preservation of environment, ecological balance free from pollution of air and water, sanitation, without life cannot be enjoyed. Environmental pollution therefore should be regarded as amounting to violative of article 2111 as the right to life includes right to live in pollution free environment. ARTICLE 39 This article contemplates that the State shall direct its policy towards securing that the operation of the economic system does not result in the concentration of wealth and the means of production to the common detriment. ARTICLE 47 It refers to the duty of the State to raise the level of nutrition and standard of living and to improve the public health. ARTICLE 48A This article states that the State shall endure to protect and improve the environment. As laid down in the case of T. Godavarman v. Thirumal Pad, Tamil Nadu,12 there is no doubt about the fact that there is a responsibility bestowed upon the Government to protect and preserve the environment, as undoubtedly, hygienic environment is an

T. Damodar Rao v. M.C Hyderabad, AIR 1987 AP 171 1995 (2) SCC 577 11 Kharag Singh v. State of UP, AIR 1963 SC 1295 12 MANU/SC/1317/2002


integral facet of the right to a healthy life and it would be impossible to live without a humane and healthy environment. ARTICLE 51A (G) This article points the out the obligation of the citizen to protect and improve the natural environment including forests, lakes, rivers and wildlife, and to have compassion for living creatures. THE ENVIRONMENT (PROTECTION) ACT 1986 The Environment Act was enacted under art. 253 of the Constitution of India with the purpose of environmental protection, regulation of discharge of environmental pollutants and handling of hazardous substances speedy response in the event of accidents threatening environment and deterrent punishment to those who endanger human environment, safety and health.13 Further for the fulfilment of above tasks by exercising the power conferred under Sections 6 and 25 of the Act, the Environment (Protection) Rules, 1986 (The Environment Rules) were made by the Central Government. THE WATER (PREVENTION AND CONTROL OF POLLUTION) ACT, 1974 The Water Act enacted under art. 252 of the Constitution of India provides for the constitution of the Central Pollution Control Board by the Central Government and the constitution of the State Pollution Control Boards by various State Governments in the country.14 The Boards function under the control of the Governments concerned. The Water Act prohibits the use of streams and wells for disposal of polluting matters. It also provides for restrictions on outlets and discharge of effluents without obtaining consent from the Board. Prosecution and penalties have been provided which include sentence of imprisonment.


Research Foundation for Science Technology National Resource Policy v. Union of India, MANU/SC/1211/2003 14 Research Foundation for Science Technology and Natural Resource Policy vs. Union of India, 2007(11)SCALE75


THE AIR (PREVENTION AND CONTROL OF POLLUTION) ACT, 1981 The Air Act enacted under article 253 of the Constitution of India provides that the Central Pollution Control Board and the State Pollution Control Boards constituted under the Water Act shall also perform the powers and functions under the Air Act. The main function of the Boards, under the Air Act, is to improve the quality of the air and to prevent, control and abate air pollution in the country.

In Vellore Citizens Welfare Forum v. Union of India.,15 and M.C Mehta v. Union of India., India16it was observed that the balance between environmental protection and developmental activities could only be maintained by strictly following the principle of sustainable development. In Essar Oil v. Halar Utkarsh Samiti,17 the Court thus Samiti, interpreted that in order to achieve a more rational management of resources and thus to improve the environment, States should adopt an integrated and coordinated approach to their development planning so as to ensure that development is compatible with the need to protect and improve environment for the benefit of their population. Further in the above cases the court discussed that these days the concepts of The Precautionary Principle and The Polluter pays Principle have become the essential features of sustainable development as are clear from articles 47, 48A and 51 A (g) of the Constitution of India and various environmental statutes, such as the Water Act, 1974 and other statutes, including the Environment (Protection) Act, 1986, these concepts are already implied.

15 16

MANU/SC/0686/1996 2002 (4) SCC 353 17 MANU/SC/0037/2004

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In the cases of Indian Council of Enviro-Legal Action v.Union of India, India,

and Goa

Foundation vs. Diksha Holdings Pvt Ltd.,19 various industries were established illegally Ltd., in the CRZ notified areas thereby causing serious damage to the environment and ecology of the coastal areas. It was observed by the Court that the task of the government is not restricted to framing the laws thus making it as passive tool but implementing it properly to ensure that the people are provided with the clean and pollution free environment. Various authorities like National Institution of Oceanography, Vohra Committee, Central Institute of brackish water Aquaculture are established which from time to time analyse the coastal areas. In MC Mehta vs. Union of India,20 and Delhi Bottling Co. Pvt. Ltd. v CPCB21 it was India, observed by the Courts that the need of development by the industries and even the construction of some other plants etc. cannot be denied as the development also come under the fundamental rights of the Constitution but at the same time balancing in with

1996 (5) SCC 281. The issue was as to the establishment of Tourism and Hotel industry near the coastal area and for this purpose the government was given wide discretionary powers to relax the coastline, it was observed by the Courts that there was a need of having sustainable development of tourism in coastal areas which was essential from the point of view of the development and balancing it with the protection and preservation of the environmental factors and fragile coastal ecology. It was observed by the courts that in both the cases the establishments of Tourism and Hotel Industry in the relaxed area and construction of Beach Resorts respectively has caused serious damage to the coastal ecology like there are mangrove forests that need protection and which stretch to more than 100 meters from the river bank and also the construction of beach resort destroys the sand dunes which are very important part of the coastal ecology as they help by protecting the coastal residents from the High tides. 19 (1999)2 Bom CR 550 20 AIR 1988 SC 1115. The issue of pollution of Ganga river water by the trade effluents, sewage and other waste material coming out from the city Kanpur came up. The Apex Court criticised the efforts taken by the government. The Court looked into various Environmental laws like Environmental Protection Act, Water Act and Utter Pradesh Nagar Mahapalika Adhiniyam and criticised the Municipality and Mahapalika that the legislatures have made enough laws and regulations to protect the environment by controlling the discharge of the trade and other effluents, by setting up national standards, creating the Pollution Control Boards under sec 3 and sec 4 of the Water Act for performing all the necessary function under sec 16 and sec 17 (Water Act) that are required to control and prevent the water pollution and at the same time these Boards have all the powers to collect the sample (sec 21) and obtain information (sec 22) and look into the matter and can even take precautionary and preventive measures to prevent any person or industry from polluting the water pollution. 21 1986 Del 152. In this case the court observed that the petitioner (Delhi Bottling Ltd.) was discharging trade effluents into the river Yamuna after obtaining the consent of the CPCB under sec 25 and sec 26 of the Water Act. But a complaint was filed against them under sec 33 (1) by the Board on the ground that the petitioner industry has neither put up the treatment plan nor has started any preliminary steps in this regard and even the sample taken by the Board shows that the petitioner was not conforming to the parameters of the consent orders.

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the environment is also important to prevent pollution. The concept of sustainable development does not in all the cases presumes the guilt of the company or industries but the Board has to adduce the proper evidences.22 Development project like dams, thermal power stations, port, railways etc. have raised various environmental issues as the construction of big projects generally requires large lands or area thus affects the people living in the locality, they have a large impact on the environmental factors like air, water and land (discharge of trade effluents) 23 that is the reason why when these project are approved by the government they have to pass the EIA tests24 and various other environmental tests and it is only after such environmental clearance certificate obtained from the government that any project can be executed as discussed in the case of N.D. Jayal v. Union of India (UOI) and Ors.25 Ors. In the case of Tehri Bandh Virodhi Sangarsh Samiti v. State of U.P.26, it was held that U.P. hydel projects are very important from the point of view of development. What is to be seen is that if the environment is likely to suffer, then certain steps may be taken to offset the same. Merely because there will be a change is no reason to presume that there will be an ecological disaster.
22 23

Intellectuals Forum, Tirupathi vs. State of A.P. and Ors., AIR2006SC1350 Trade effluents discharged on the lands make then barren and unfertile. 24 But such test are not made mandatory but mere directory. 25 (2004)9SCC362 26 1992 (supp) 1 SCC 44. In this case the issue was raised on the construction of Tehri dam for hydel power generation constructed at the confluence of the Bhagirathi and Bilangana, close to the Garhwal town of Tehri. The main issues that were raised in this case was firstly, the petitioners asked the Supreme Court for directions to conduct further safety tests so as to ensure safety of the dam as it has been urged that structure of the dam is not safe and its existence increases the seismic vulnerability of the entire Himalayan region and also it affects the ecology of the entire region. But the court observed that studies related to site specific assessment of seismicity, testing of fill materials for determining dynamic properties and detailed dynamic analysis, were carried out independently by two agencies; that they are the Department of Earthquake Engineering, University of Roorkee, and Hydro Project Institute (HPI), Moscow; that the result of their studies indicated that earth and rock fill type dams as chosen for Tehri are the safest man-made structures in earthquake prone zones due to their large inertia, high damping and high flexibility, thus Tehri Dam is a fail-safe structure and the design has been found safe against the worst earthquake scenario of the area, even when very conservative and severe seismic parameters were assumed for these tests. Further it was observed that the Court cannot sit in judgment over the cutting edge of scientific analysis relating to the safety of any project and it is the policy decision of the government to give approval to any project like dams, power projects etc. after taking into account report furnished by the experts as to the safety of the project, its impact on the environment and the rehabilitation schemes framed for the people. Here the only point to consider by the Court is whether the decision-making agency took a well-informed decision or not.

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As observed in Narmada Bachao Andolan vs. Union of India,27 the right to development India, cannot be treated as a mere right to economic betterment. It encompasses much more than economic well being, and includes within its definition the guarantee of fundamental human rights. Even in cases of Thermal power projects the environmentalists have shown great concern as the location of any power station which draws on sea water to cool its turbine is bound to impact the marine environment. The warm water discharged by the plant alters the local ecology. Some species thrive in the warm water whilst others perish in the changed environment.28 As per the studies conducted by various organizations, to ensure ecological stability, 30 percent of the nation should be under adequate forest cover. But today large industrial units use forests as the source of raw material for paper, pulp and rayon mills. Export of timber products generates foreign revenue. Small businesses depend on forests as a source wood for a myriad product.29 In addition to above forests are home to many tribal people. Therefore there is a need to protect the environment. In A. Chowgule and Co. Ltd. vs. Goa Foundation,30 the Court after looking into the Forest Conservation Act, 1980, Forest (Conservation) Rules, 1981 and Environment Protection Act held that the no forest land can be diverted to use it for any other purpose except with prior permission of Central government. The sustainable development has to be maintained keeping in mind the importance of the forests land. 31 The Principle was further discussed in the case of T.N. Godavaraman Thirumulpad vs. Union of India32 The Court observed that adherence to the principle of Sustainable Development is now a adherence

MANU/SC/0640/2000. The issue was as to construction of Sardar Sarovar Project also, four conditions were imposed to ensure the sustainable development: (i) NCA will ensure that environmental safeguard measures are planned and implemented pari-passu with progress of work on project; (ii) The detailed surveys' studies assured will be carried out as per the schedule proposed and details made available to the Department for assessment; (iii) The attachment area treatment programme and the rehabilitation plans be so drawn as to be completed ahead of reservoir filling; and, (iv) The Department should be kept informed of progress on various works periodically. 28 Shyam Divan Armin Rosencranz, Environmental Law and Policy in India, (Oxford University Press, New Delhi, 2nd ed.) 2001 29 ibid 30 MANU/SC/3578/2008 The issue of diverting the forest land for granting the lease to the appellants for establishing a 100 percent export oriented unit was raised. 31 T.N. Godavarman Thirumulkpad v. Union of India and Ors. MANU/SC/0278/1997 32 (2008)2SCC222

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constitutional requirement. Courts are required to balance development needs with the protection of the environment and ecology.33 It is the duty of the State under our Constitution to devise and implement a coherent and co-ordinated programme to meet its obligation of Sustainable Development based on inter-generational equity.34 In the case of Essar Oil Ltd. vs. Halar Utkarsh Samiti35, mining as held in the above case is an important revenue generating industry. However, it is unacceptable to place our national assets in the hands of companies without proper mechanism and without ascertaining the credibility of the User Agency. The answer came on the form of Sustainable Development.

We do not inherit the land from our forefathers. We borrow it from our children. - Native American Proverb Sustainable development is defined as a pattern of social and structured economic transformations (i.e. development) which optimizes the economic and societal benefits available in the present, without jeopardizing the likely potential for similar benefits in the future. A primary goal of sustainable development is to achieve a reasonable and equitably distributed level of economic well-being that can be perpetuated continually for many human generations. Sustainable development implies using renewable natural resources in a manner which does not eliminate or degrade them, or otherwise diminish their usefulness for future generations. It further implies using non-renewable (exhaustible) mineral resources in a manner which does not unnecessarily preclude easy access to them by future generations.
33 34

K.M. Chinnappa and T.N. Godavarman Thirumalpad vs. Union of India (UOI) and Ors.,AIR2003SC724 A.P. Pollution Control Board v. Prof. M.V. Nayudu, MANU/SC/0032/1999 35 AIR2004SC1834. The Refinery was totally dependent on mining of bauxite from Niyamgiri Hills, Lanjigarh, which was the only vital wildlife habitat. It constituted part of the elephant corridor. The mining project would have additionally caused problems to the proposed wildlife sanctuary and the residence of tribes like Dongaria Kandha. According to CEC, the Project would also destroy flora and fauna of the entire region and it would result in soil erosion. Also use of forest land in an ecologically sensitive area like Niyamgiri Hills should not be permitted. However poor tribal live in Lanjigarh Tehsil and have little chance of development if not allowed to mine.

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Sustainable development also requires depleting non-renewable energy resources at a slow enough rate so as to ensure the high probability of an orderly society transition to renewable energy sources. The concept of sustainable development has emerged as an endeavour to address the environmental problems caused by economic growth in contemporary India. There are varied interpretations of the theory of sustainable development but its main objective is to achieve a process of economic development without an indiscriminate destruction of our environment. However much needs to be done if we want to save our land from imminent peril. Sustainable development as endorsed by the likes of Sunderlal Bahuguna is the answer to not only our future but also our present existence on the planet.

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BOOKS: Shyam Divan, Armin Rosencranz, Environmental Law and Policy in India, India, (Oxford University Press, New Delhi, 5th ed., 2004) Stuart Bell & Donald McGillivray, Environmental Law,(Oxford University Press, Law,(Oxford New Delhi, 5th ed., 2004) Gurdip Singh, Environmental Law in India, (McMillan India Ltd., Delhi, 1st Edn., India, 2005) Stuart Bell & Donald McGillivray, Environmental Law,(Oxford University Press, Law,(Oxford New Delhi, 5th ed., 2004) ARTICLES:

Making Sustainable Development Happen: From Johannesburg To Albany 8 ALBLEOJ 173, as cited from

WEBSITES: CASES: A.P. Pollution Control Board v. Prof. M.V. Nayudu MANU/SC/0032/1999 Chowgule and Co. Ltd. vs. Goa Foundation and Ors. MANU/SC/3578/2008

Delhi Bottling Co. Pvt. Ltd. Vs. CPCB, 1986 Del 152

Enviro-Legal Action v. Union of India MANU/SC/1112/1996 Essar Oil Ltd. vs. Halar Utkarsh Samiti and Ors., AIR2004SC1834

Essar Oil v. Halar Utkarsh Samiti, MANU/SC/0037/2004 Samiti, Goa Foundation vs. Diksha Holdings Pvt Ltd., (1999)2 Bom CR 550 Ltd.,

Indian Council for Environ-Legal Action v. Union of India, MANU/SC/1189/1996 16 | P a g e


Indian Council of Enviro-Legal Action v.UOI, 1996 (5) SCC 281 v.UOI,

Intellectuals Forum, Tirupathi vs. State of A.P. and Ors., AIR2006SC1350 K.M. Chinnappa and T.N. Godavarman Thirumalpad vs. Union of India, AIR2003SC724 Kharag Singh v. State of UP, AIR 1963 SC 1295 M.C Mehta v. Union of India, 2002 (4) SCC 353

MC Mehta vs. Union of India, AIR 1988 SC 1115 N.D. Jayal v Union of India (UOI) and Ors., (2004)9SCC362 Bachao Andolan vs. Union of India (UOI) and Ors., MANU/SC/0640/2000

MC Mehta vs. Union of India, AIR 1997 SC 734


Ramgopal Estates Pvt. Ltd. vs. The State of Tamil Nadu, MANU/TN/7948/2007 Research Foundation for Science Technology and Natural Resource Policy vs. Union of India, 2007(11)SCALE75 Research Foundation for Science Technology National Resource Policy v. Union of India, MANU/SC/1211/2003 T. Damodar Rao v. M.C Hyderabad, AIR 1987 AP 171 T. Godavarman v. Thirumal Pad, Tamil Nadu, MANU/SC/1317/2002










MANU/SC/0278/1997 Tehri Bandh Virodhi Sangarsh Samiti v. State of U.P. and Ors., 1992 (supp) 1 Tehri SCC 44

Vellore Citizens Welfare Forum v. Union of India., MANU/SC/0686/1996 Virender Gaur v. State of Haryana,1995 (2) SCC 577 Haryana,1995

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