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A PROJECT REPORT ON ROLE OF SUPREME COURT IN ENVIRONMENT

PROTECTION

Submitted by:

Submitted to:

Ayushi

Mr. abhishek Kumar

201224

Environment Law Faculty

VII sem

CONTENT

ACKNOWLEDGEMENT
TABLE OF CASES
RESEARCH METHODOLOGY
INTRODUCTION
MEANING OF ENVIORNMENT
WHY THE NEED FOR ENVIRONMENTAL LAWS?
JUDICIAL REMEDIES FOR ENVIRONMENT POLLUTION
THE CONSTITUTIONAL ASPECTS ON ENVIRONMENTAL LAW
ENVIRONMENTAL PROTECTION: THE JUDICIAL APPROACH
SOME REMARKABLE PRINCIPLES AND DOCTRINE PROPOUNDED BY THE

INDIAN JUDICIARY:
FUTURE CHALLENGES: NEED TO COMBAT
CONCLUSION/ SUGGESTION
REFRENCES

ACKNOWLEDGEMENT
Words may not suffice to express my gratitude to all those who rendered help and cooperation to
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me in every possible way in completing this project. Still an attempt has been made here to thank
from the bottom of my heart all those people involved in the successful completion of my
project.
I take this opportunity to express my profound gratitude and deep regards to my guide Mr
Abhishek Kumar for his guidance, monitoring and constant encouragement throughout the
course of this semester on project role of supreme court in environment protection. The
blessing, help and guidance given by him time to time have only made it possible the successful
completion of the project.

And last, but not the least, I am thankful to my parents from the bottom core of my heart, for
their immense encouragement and help whenever so required.
Though I have tried out best at the same time I know that there is nothing called perfection so I
would like to have all valuable suggestion for future.

TABLE OF CASES
1. Enviro-Legal Action v. Union of India, 1996(3) SCC 212.
3

2. Charan Lal Sahu v. Union of India AIR 1990 SC 1480.


3. M.C. Mehta v. Union of India (1998) 9 SCC 93 (Taj Mahal case).

4. M.C. Mehta v. Union of India 1991 (2) SCC 137.


5. M.C. Mehta v. Union of India, 1992 Supp (2) SCC 633 (Ganga Pollution Case)

6. M.C. Mehta v. Union of India, AIR 1987 SC 965 (Delhi gas leak case).

7. M.C.Mehta v. Kamal Nath and Others (1997)1 SCC 388.

RESEARCH METHODOLOGY
Aims and objectives:
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Present paper aims to look at the contribution of the Supreme Court of India in environmental
protection and what possible role it can play in todays context with respect to the new emerging
threat.
Scope and Limitations

Scope of the present paper is to explore the contribution of the Supreme Court in protecting the
environment through leading judgments and the availability of various legal protections at the
domestic and international level. The scope of the project is limited due to paucity of time.
Research Questions

This paper has attempted to answer the following questions:

What is the role of Supreme Court of India in protection of the environment?

Why is there a need for environmental laws?

What are the judicial remedies available for environment pollution?

What are the new emerging threats?

Sources of Data

Primary sources in the form of UN Charter and secondary sources in the form of Articles and
books have been used to answer the various research questions.
Hypothesis
Since the protection of the environment is no longer contained within the domestic spectrum and
has spilled outside it, right now it is the matter of the global concern. There is a need for
effective protection of the environment to meet future challenges.
Methodology
Method of writing of this project is Analytical as well as Descriptive.
Mode of citation
A uniform mode of citation has been followed throughout the project

INTRODUCTION
Environment is the source of life on earth like water, air, soil, etc., and it is also determines the
existence, growth and development of mankind and all its activities. The concept of
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environmental protection and conservation is nothing new. It has been intrinsic to many ancient
civilisations. Ancient India recognised that one can take from the earth only so much as one puts
back into it. In the 'Atharva Veda', the ancient Hindu Scepters stated What of
thee I dig out let that quickly grow over. 1
But right now new technology like, thermal power, nuclear plant etc. without any adequate
environmental protection pose a new threat to the environments, the result of which is some
problem like climate change, global warming, acid rain, etc. Moreover, as per trend of Indian
legislature to create a numbers of legislation instead of addressing the reason for failure, and
passing a new bill every day is just like as old wine in new bottle. Therefore, it is requirement
for a comprehensive analysis of the protection of the environment. In recent years, there has been
a sustained focus on the role played by the higher judiciary in devising and monitoring the
implementation of measures for pollution control, conservation of forests and wildlife protection.
Many of these judicial interventions have been triggered by the persistent incoherence in policymaking as well as the lack of capacity-building amongst the executive agencies. Devices such as
Public Interest Litigation (PIL) have been prominently relied upon to tackle environmental
problems, and this approach has its supporters as well as critics.2
MEANING OF ENVIORNMENT
Einstein once remarked: The environment is everything that is not me.
The word environment relates to surroundings. It includes virtually anything. Indeed We can
also define environment as anything which may be treated as covering the physical

1 McMehta,GROWTHOFENVIRONMENTALJURISPRUDENCEININDIA,p.71,1999.availableathttp://heinonline.org
(visitedonSeptember25,2015).

2 FormerChiefJusticeMr.K.G.Balakrishnan,THEROLEOFTHEJUDICIARYINENVIRONMENTALPROTECTIONIN
D.PSHRIVASTAVAMEMORIALLECTURE,p.1,March20,2010.availableat
supremecourtofindia.nic.in/.../dp_shrivastava_memorial_lecture_20.(LastvisitedonSeptember25,2015).

surroundings that are common to all of us, including air, space, waters, land, plants and wildlife.3
THE ENVIRONMENT (PROTECTION) ACT, 1986
Section 2(a) environment includes water, air and land and the inter- relationship which
exists among and between water, air and land, and human beings, other living creatures,
plants, micro-organism and property4.
According to the Webster Dictionary, as the Aggreg ate of all the external condition and
influences affecting the life and development of an organism. 5
So after considering all the above definition, the basic idea can be concluded that environment
means all the surrounding, which is essential for lives constitute the environment.
WHY THE NEED FOR ENVIRONMENTAL LAWS?
Today we are living in nuclear arena. Nobody can forget the damage caused by the atomic
bombs, dropped by aircrafts belonging to United States on the Japanese cities of Hiroshima and
Nagasaki during the final stages of World War II in 1945. Day to day advance of technology,
apart from development also increases the threat to human life. In the 21 st century various kinds
of advance weapons have been developed like Chemical and Biological Weapons, all these
technology extend our abilities to change the world. All these things compel us to reconsider the
the protection of the environment in accordance with the fast changing world. Therefore, there is
an acute need of the law, so it keeps pace with the need of the society and has respect for human
3 Dr.JaiJaiRamUpadhyay,ENVIRONMENTALLAW,p.2,Allahabad:CentralLawAgency,(2005).

4 Availableatenvfor.nic.in/legis/env/env1.html(visitedonSeptember28,2015).

5 R.M.Lodha,ENVIRONMENTALRUIN:THECRISESOFSURVIVAL,P.364.NewDelhi:IndusPublishingCompany,
(1993).

beings. So now the question of environment protection is matter of global concern, it is not
isolated problem of any area or nation.
JUDICIAL REMEDIES FOR ENVIRONMENT POLLUTION
The remedies available in India for environmental pollution comprise of statutory as well as
tortuous law remedies. The tortuous remedy available for environmental protection is nuisance,
trespass, negligence and strict liability. The statutory remedies includes: Citizens suit, e.g., an
action brought under section 19 of the Environmental (Protection) Act, 1986, an action under
section 133, Criminal Procedure Code, 1973.And under Indian Penal Code,1860 action can be
brought under the Section 268 for public nuisance. Apart from this, a writ petition can be file
under Article 32 in the Supreme Court of India or under Article 226 in the High Court. The
descriptions of all remedies are as follows:
TORTUOUS LIABILITY
Tort law being judicially developed law, the Indian judiciary has developed the following
tortious remedy.
Damage: Recently, In Shriram Gas Leak case, involving a leakage of Oleum gas which resulted
in substantial environmental harm to the citizens of Delhi, the Apex court held that the quantum
of damages awarded must be proportionate to the magnitude and capacity of the polluter to pay.
However, the Apex Court has deviated from this test in the bhopal gas tragedy.6
Injunction: The purpose of this legal remedy is to prevent continuous wrong. The grant of
perpetual injunction is governed by Sec.37 to 42 on the Specific Relief Act, 1963.
Nuisance: In simple terms, Nuisance means the act which creates hindrance to the enjoyment
of the person in form of smell, air, noise, etc. According to Stephen, nuisance is anything done to
6 ROLEOFTHESUPREMECOURTINTHEPROTECTIONOFTHEENVIRONMENT,availableat
urisonline.in/2010/.../roleofsupremecourtinenvironmentprotecti.(VisitedonOctober25,2015).

hurt or annoyance of lands, tenements of another and not amounting to trespass. Nuisance can be
divided into two categories:
Private Nuisance- It is a substantial and unreasonable interference with the use and enjoyment of
ones land.
Public Nuisance- It is an unreasonable interference with a general right of the public.
Trespass -It means intentional or negligent direct interference with personal or proprietary
rights without lawful excuses. The two essential requirements for trespass are:

1) There must be intentional or negligent interference with personal or proprietary rights.


2) The interference with the personal or proprietary rights must be direct rather than
consequential.
Negligence: Simply it connotes failure to exercise the care that a reasonably prudent person
would exercise in like circumstances.
Strict Liability: The rule enunciated in Rylands v. Fletcher by Blackburn J. is that the person
who for his own purpose brings on his land and collects and keeps there anything likely to be a
mischief, if it escapes, must keep it as its peril, and if he does not do so is prima facie even
though, he will be answerable for all the damage which is the natural consequence of its escape.
The doctrine of strict liability has considerable utility in environmental pollution cases especially
cases dealing with the harm caused by the leakage of hazardous substances.7
THE CONSTITUTIONAL ASPECTS ON ENVIRONMENTAL LAW
7 Availableaturisonline.in/2010/.../roleofsupremecourtinenvironmentprotecti.(Visitedon
October,25,2015).
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India's Constitution is one of the few Constitutions in the world that contains specific provisions
pertaining to the protection of the environment and thereby accords Constitutional status to
environmental protection8. Originally, before 1976 Indian Constitution having no specific
provision regarding the environmental protection, it has found place after (Forty Second
Amendment) Act, 1976 , which incorporated Article 48-A (directive principles of state policy)
and Article 51-A (g) as fundamental duty to protect the environment .Which are as follows
THE CONSTITUTION FORTY- SECOND AMENDMENT:
It was the first time when responsibility of protection of the environment imposed upon the
states through Constitution (Forty Second Amendment) Act, 1976,
Article 48-A9 the provision reads as follows: The State shall endeavor to protect and improve
the environment and to safeguard the forest and wildlife of the country. The Amendment also
inserted Part VI-A (Fundamental duty) in the Constitution, which reads as follows:
Article 51-A (g)10 It shall be duty of every citizen of India to protect and improve the natural
environment including forests, lakes,, and wildlife and to have compassion for living creature.
In Sachida Nand Pandey v. State of West Bengal, the Supreme Court , relying upon the
Constitutional directives concerning protection of environment observed whenever a problem of
ecology is brought before the court , the court is bound to bear in mind Article 48-A and Article
51-A(g).When the court is called upon to give effect to the Directive Principles and the
Fundamental Duties , the court is not to shrug its shoulder and say that priorities are a matter of
policy and so it is a matter of the policy making authority.11
8 PeggyRodgersKalas,ENVIRONMENTALJUSTICEININDIA,P.106availableat(http://heinonline.org)
(VisitedonOctober25,2015).
9 THECONSTITUTIONOFINDIA,1950
10 Id.3

11 Supranote2

11

Fundamental Rights vis--vis Environment: Part III of the Constitution of India incorporates
fundamental rights which have been made judicially enforceable. An attempt here is being made
to examine this perspective in the context of environmental protection. Our judiciary attempted
to expand the scope and ambit of Article 21, through various cases. Right now everything which
is pertinent to the life covered by Article 21, some cases are as follows:
ENVIRONMENTAL PROTECTION: THE JUDICIAL APPROACH
A judge is not a mimic. The greatness of the Bench lies in its creativity. When a law comes
before a judge, he has to invest it with meaning and content and in the process of
interpretation, he makes the law. It is, therefore, to my mind, essential that a judge must be in
tune with social needs and requirements.... 12
There are numbers of the following judgments which clearly documented the active role of
judiciary in environmental protection these are follows:
DELHI GAS LEAK CASE: In M.C. Mehta v. Union of India, AIR 1987 SC 965
Popularly known as the Delhi Gas Leak or Oleum Gas Leak Case ,In instant the Supreme Court
laid down two important principles of law: First, the power of the Supreme Court to grant
remedial relief for a proved infringement of a fundamental right (in case if Article 21) includes
the power to award compensation. Thus, the court not only widened the scope of Article 21 by
including in it protection of environment but also included a liability in tort for those harmed
others by pollution. Second, the judgment opened a new frontier in the Indian jurisprudence by
introducing a new no fault liabi lity standard (absolute liability) for industries engaged in
hazardous activities which has brought about radical changes in the liability and compensation
laws in India. The new standard makes hazardous industries absolutely liable from the harm
resulting from its activities.
12 JusticePNBhagwati,'JUDICIARY:HOLDINGTHESCALES',p.49,TheHindu15August(1977).Availableat
www.ancl-radc.org.za/.../Judicial%20Activism%20in%20Africa.pdf( Visited on October 23,
2015).

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RIVER POLLUTION CASE:


M.C.Mehta v. Kamal Nath and Others (1997)1 SCC 388
The case involved encroachment of forest land and an attempt to change the course of the River
Base to facilitate the construction of a motel by a company reportedly having direct links with
the family of Kamal Nath, former Minister of Environment and Forests. The Supreme Court took
notice of a news item regarding the above developments and proceeded to quash the approval
granted by the central government, court gave the order for restitution of the environment and
ecology of the area and to prohibit from discharging untreated effluents into the river. While
directing the company to construct a boundary wall separating the building from the river basin,
the Court made it clear that the river bank and the river basin were to be left open for public use.
The Court pronounced in categorical terms: "The public trust doctrine, as discussed by court in
this judgment is a part of the law of the land."13
M.C. Mehta v. Union of India, 1992 Supp (2) SCC 633 in the (Ganga Pollution Case)
This was perhaps one of the earliest cases where the activities of tanneries were brought to the
attention of the Supreme Court. This case was a public interest litigation presented before a
Division Bench of the Honble Supreme Court comprising of E.S. Venkataramiah and K.N.
Singh, JJ. The petitioner M.C. Mehta, who was an active social worker had filed this petition
inter alia for the issue of a writ/order/direction in the nature of mandamus to the respondents
restraining them from letting out the trade effluents into River Ganga until the time they put up
necessary treatment plants for treating the trade effluents in order to arrest the pollution of water
on the said river.
The Supreme Court declared that the financial capacity of the Kanpur tanneries is irrelevant in
directing them to establish primary-treatment plants to pre-vent any further pollution of the
Ganga. The Court held that tanneries which have no financial means of establishing primary13Availableatwww.nlsenlaw.org/live/.../environmental(VisitedonOctober30,2015.).

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treatment plants cannot be allowed to operate. By its firm and bold pronouncements, the
Supreme Court has enforced the Polluter Pays Principle (PPP) which is widely accepted in
OECD countries14
Taj Mahal case 9 (1997) 2 SCC 353.
In order to save the Taj Mahal, one of the wonders of the world, and other cultural and historical
monuments at Agra, the Supreme Court of India gave directions that no coal-based industry
could operate in the Taj 'Trapezium', an rea of 10,400 square kilometres around the Taj Mahal.
The polluting industries have been directed either to switch over to gas fuel or to relocate outside
the Taj 'Trapezium' and the State Government has been directed to provide assistance and
incentives to such relocating industries. The Court has also directed that the Government of India
and the State of Uttar Pradesh should develop a 'Green Belt' around the Taj Mahal and provide
uninterrupted power supply to Agra to curb the use of diesel generators
SOME REMARKABLE PRINCIPLES AND DOCTRINE PROPOUNDED BY THE
INDIAN JUDICIARY:

Doctrine of Absolute Liability


Polluter Pays Principles
Precautionary Principles
Public Trust Doctrine
Doctrine of Sustainable Development

DOCTRINE OF ABSOLUTE LIABILITY


THE BHOPAL CASE: In Union Carbide Corporation v. Union Of India 1989 SCC (2)
540 1989 SCALE (1)93215
14 HarGovindjn,RECENTDEVELOPMENTINENVIRONMENTPROTECTIONININDIA:POLLUTIONCONTROL,p.432,
Vol.18.,No.8(1989),availableathttp://www.jstor.org/stable/4313633(visitedonOctober30,2015,).

15 C.M.ABRAHAMandSUSHILAABRAHAM,THEBHOPALCASEANDDEVELOPMENTOF
ENVIRONMENTALLAWININDIA

14

In instant case court held that, where an enterprise is engaged in a hazardous or inherently
dangerous activity and harm results to anyone on account of an accident in the operation of such
hazardous or inherently dangerous activity resulting, for example, in escape of toxic gas, the
enterprise is strictly and absolutely liable to compensate all those who are affected by the
accident and such liability is not subject to any exceptions. Therefore, SC Court developed a
new trend of Absolute Liability without any exception.
POLLUTER PAYS PRINCIPLES (PPP)
"If anyone intentionally spoils the water of another ... let him not only pay damages, but purify
the stream or cistern which contains the water... Plato
Polluter Pays Principle has become a popular in recent times. 'If you make a mess, it's your duty
to clean it up'- this is the main basis of this slogan. It should be mentioned that in environmental
law, the 'polluter pays principle' does not refer to "fault." Instead, it favors a curative approach
which is concerned with repairing ecological damage. It's a principle in international
environmental law where the polluting party pays for the damage done to the natural
environment. It is regarded as a regional custom because of the strong support it has received in
most Organization for Economic Co-operation and Development (OECD) and European
Community (EC) countries. International environmental law itself mentions little about the
principle.16In Vellore Citizens Welfare Forum v. UOI (1996) 3 SCC 212. The Supreme Court
has declared that the polluter pays principles are an essentials feature of the sustainable
development.
PRECAUTIONARY PRINCIPLES
p.364.Availableathttp://heinonline.org(visitedonOctober25,2015).

16 Availableatwww.legalserviceindia.com/.../l54InterpretationofPolluterPaysPri..(Visitedon
October29,2015).
15

Supreme Court developed following three concept of Precautionary Principles:

Environmental measures must anticipate, prevent and attack the causes of environmental

degradation
Lack of scientific certainty should not be used as a reason for postponing measures
Onus of proof is on the actor to show that his action is benign

(Supreme Court in Vellore Citizens Welfare Forum)17


PUBLIC TRUST DOCTRINE
The Public Trust Doctrine primarily rests on the principle that certain resources like air, sea,
waters and the forests have such a great importance to people as a whole that it would be wholly
unjustified to make them a subject of private ownership18.
M.C.Mehta v. Kamal Nath and Others (1997)1 SCC 388.
The public trust doctrine, as discussed by court in this judgment is a part of the law of the
land."19
DOCTRINE OF SUSTAINABLE DEVELOPMENT
The world commission on Environment and development (WCED) in its report popularly known
as the Brundtland Report named after the Chairman of the Commission Ms. GH Brundtland.
According to Brundtland Report, Sustainable developments mean development that meets the
needs of the present without compromising the ability of the future generations to meet their own
17 ShirazRustomjee,GLOBALENVIRONMENTALLAWANDINDIA,September2009availableat
scholarship.law.cornell.edu/cgi/viewcontent.cgi?Article=1144...ijli(VisitedonOctober29,2015).
18 Ibid

19 Availableatwww.nlsenlaw.org/live/.../environmental(VisitedonOctober29,2015).

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needs. 24
The courts are often require to strike a balance between development and environment. In
Rural Litigation and Entitlement Kendra v. State of UP, court first time came across the issue
relating to the environment and development; and held that, it is always to be remember that
these are the permanent assets of mankind and or not intended to be exhausted in one generation.
Vellore Citizens Welfare Forum (1996) 5 SCC 647. In this case Supreme Court observed that
sustainable development has come to be accepted as a viable concept to eradicate poverty and
improve the quality of human life while living within the carrying capacity of the supporting
eco- system.20
FUTURE CHALLENGES: NEED TO COMBAT
Today, we are concerned with a different kind of threat that lurks on our environment. Rapid
Industrialization, mechanization, motorization and chemicalisation of agriculture caused the
massive threat. Which have resulted in poisoning the air, the rivers and the soil itself. This not
only endangers human beings and animal life but also seriously affects vegetation on earth.
Some are as follows:
THERMAL POWER PLANTS: NUCLEAR PLANT
Development without destruction
Increasing industrialization and rapid urbanization increases energy demands. The rising global
demand for energy has been met to an increasing extent by the use of fossil fuels. Furthermore,
energy production by fossil fuels leads to many types of environmental pollution such as air,
water, noise, thermal and nuclear. In order to reduce the damage the sitting of the thermal power
is very important. The Selection of site for thermal power is very important in the view of
resource linkages such as, availability of land, water, cost of the power etc. but equally it should
be viewed with respect to its environmental impact.21
20 Ibib
21 PradeepP.Joshi,ENVIRONMENTALPOLLUTIONBYTHERMALPOWERPLANTS,p.85CitedinEnvironmental
Ruins:TheCrisesofsurvival,NewDelhi:IndusPublishingCompany.,(1993).

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THE ASIAN HAZE OR ASIAN BROWN CLOUD


Recently, Scientist have been came a crossed the new emerging threat to the world climate . a
UN study , commissioned by United Nation Environment Programmee ( UNEP) conducted by
about 200 scientist including Indians, have discovered a 3 Km. thick deep blanket of brownish
lawyer of pollution name as Asian Haze of Asian Brown cloud (ABC). This Haze consists of
deadly cocktail of ash, acid, Sulphates, Nitrate, Black Carbon and so on.
ACID RAIN
Acid rain is matter of great global concern and has become one of the major environmental
problems.22 The best example of effect of acid rain we can see on Taj Mahal "The milky white
marble of the Taj Mahal is turning pale,"
ENVIRONMENTAL WARFARE
Using weather as a weapon and manipulating the environment for military purpose is common
and has come to focus in the Gulf War. The United States is the first to use weather modification
as a weapon in Indo- China region from 1967-72. The invention was to increase normal
monsoon rainfall and disrupt Vietnamese logistics marking the emergence of the use of the
environment as a weapon in warfare. Artificial triggering of earthquake and tidal waves ,
modifying hurricanes or hailstorms to change their course, creating artificial fog to impede
enemy traffic, etc. the use of the chemical weapons are not only harmful to people and other
organisms but to ecosystem also. The Gulf crises (1990) have brought it back to the forefront.
Dumping millions of barrels of crude oil in sea to hamper naval operations and foul up
desalination plants supplying drinking water, marked the beginning of environmental warfare. 23
ENVIRONMENTAL EDUCATION
There is no means of any law, unless its effective implementation, and for effective
22H.MSaxena,ENVIRONMENTALGEOGRAPHY,p.244NewDelhi:RawatPublication,(1999).

23 Ibid 258 259


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implementation public awareness is indispensible condition, Therefore, it is necessary that there


should be appropriate awareness. This contention is also upheld by the Apex Court in the case of
M.C. Mehta v. Union of India in instant case Court directed to the Union Government was
required to issue directions to all the State governments and the union territories to enforce
through collectors as a condition for license on all cinema halls, to compulsory exhibit free of
cost at least two slides/messages on environment during each show. Furthermore, Law
Commission of India in its 186th report made a proposal for the constitution of the environment
court. Hence, there is an urgent need to strengthen the hands of judiciary by creating separate
environmental courts, with a professional judge to deal with the environmental cases /crimes, so
that the judiciary can perform its role more.

CONCLUSION/ SUGGESTION
Thus we find after analysis of above cases that, the Supreme Court is now in the process of
expanding the various legal provision for environmental protection. In this way judiciary try to
fill all the gapes where there is laciness of the legislation. These new developments and
innovation in India by the judicial activism open the many ways to meet the social and political
needs of the country. In India, the courts are very conscious and alert about the special nature of
environmental rights, considering that the loss of natural resources cannot be replenished.

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REFRENCES
ARTICLES

M.ABRAHAMandSUSHILAABRAHAM,THEBHOPALCASEANDTHE

DEVELOPMENTOFENVIRONMENTALLAWININDIA(Heinonline).

FormerchiefJusticeMr.K.G.Balakrishnan,THEROLEOFTHEJUDICIARYIN

ENVIRONMENTALPROTECTIONIND.PSHRIVASTAVAMEMORIALLECTURE.

HarGovindjn,RECENTDEVELOPMENTINENVIRONMENTPROTECTIONININDIA:POLLUTION
CONTROL,(Jstor).
BOOKS
20

Dr.JaiJaiRamUpadhyay,ENVIRONMENTALLAW,Allahabad:CentralLawAgency,(2005).

M.VRangaRao,ROLEOFJUDICIARYINENVIRONMENTALPROTECTION,Supreme
CourtJournal,SeptemberDecember,(2001).
WEBSOURCES

envfor.nic.in/legis/env/env1.html(visitedonNovember28,2011).

lawcommissionofindia.nic.in/reports/186th%20report.pdf(VisitedonOctober30,2015).
http://heinonline.org(visitedonOctober30,2015).

http://www.jstor.org/stable/4313633(visitedonOctober30,2015).
http://www.manupatrafast.in/pers/Personalized.aspx.legalsutra.org/.../examiningtherolesof
mcmehtasundarlalbahugu..(VisitedonOctober30,2015).

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