INTRODUCTION:-

“The Sky is like Father

The Earth is like Mother and

The space as Their Son

The Universe consisting the Three is like a family and

Any kind of damage done to any one of the Three

Throws the Universe out of Balance”

Environmental pollution is a matter of life and death. We, who live and breathe, drink and
eat, play and enjoy the bountiful gifts of nature today, must consider it our duty not to pollute
air, water, and soil but leave this earth a cleaner and safer place to live in for the flesh of our
flesh and blood of our blood i.e. we must care for the nature then only nature will care for us.
Our mother earth is the most precious gift of the Universe.

Environment is not a single subject; it is an integration of several subjects that include both
science and social studies. There are several national or internationally non environmental
thinkers. Among those who have made landmarked contributions, the names that are usually
mentioned are Henry Thoreau, Rachel Carson, EO Wilson, Salim Ali’s, Indra Gandhi, M.C.
Mehta, Madha Patkar, etc.

“Environmental problem is not the problem of an individual or a nation but is a problem

which’ no nation, no continent, no hemisphere, no race, no system can handle alone’. It is a
problem of entire human race which requires joint action”. The former Prime Minister of
India, Mr. Rajiv Gandhi, said that “Every country should contribute 0.1% of its domestic
income towards this end, and if it done we will be able to raise the amount for this fund by 18
Billion Dollars. It is a blunt truth that the promise of a better tomorrow must be fulfilled
today; day after tomorrow it runs the risk of being conveniently forgotten.

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Use of Criminal Law Machinery for Environment Protection:-

In Indian Penal Code, 1860 Chapter IXV deals with the offences affecting public health,
safety, convenience, decency & morals. While section 268 defines Public Nuisance, there are
two specific sections dealing with the fouling of water (section 277) and making the
atmosphere noxious to health (section 278) which could be used against perpetrator of water
and air pollutions.

Section 277 of IPC define fouling water of public spring or reservoir-

 The water in question was of a public spring or reservoir;

 The accused corrupted or fouled such water;
 That the accused did so voluntary; and
 That the accused’s action rendered the water less fit the purpose.

If the above conditions are satisfied then the person will be punished under this section.

Fouling water of a private well will not make the act punishable.1 The offence is cognizable,
bailable and tribal by any Magistrate. It is punishable with imprisonment which may extend
to a period of three months, or fine which may extend to five hundred rupees, or both. The
word ‘fouls’ means some act which physically defines the water. Bathing in a tank 2 or
spitting into a public well3 fouls drinking water. But drawing water from the public well by a
low cast person cannot be said to corrupt or foul the well4. The word ‘public spring’ does not
include a continuous stream of water running along the bed of a river5.

Section 278 of IPC define the making atmosphere noxious to health-

 This section punishes the public nuisance of vitiating the atmosphere of a place in
such a manner as to make it noxious to the health of the people in general living or
carrying on business in the neighborhood or passing along a public way.

1
Ramkewal Singh v. State of Bihar, AIR 1954 Pat.309.
2
Bhugi (1900) 2 Bom LR 1078.
3
Muthian, (1897) I Weir 229.
4
Ram Karanal, (1916) 13 NLR 68: AIR 1916 Nag. 15: 1917.
5
Vitti Chokkan, (1816) ILR 4 Mad 229.

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To attract the provision this section it must be proved that:-

 The accused vitiated the atmosphere;

 The accused did so voluntarily; and
 Such vitiating was noxious to health.

The offence is non-cognizable, bailable, and non-compoundable and may be tried by any
Magistrate. The above provisions have direct relevance to environmental protection as they
seek to prevent water and air pollution through Penal strategy. However, their application
towards achieving this objective is doubtful, because the technicalities of Indian Criminal
Law require a complete satisfaction of the ingredients of the offence as stipulated in the Penal
provisions. Take for instance, the provision relating to fouling of water.

Church of God (Full Gospel in India) v. K.K.R Majestic Colony AIR 2000 SC 2773:- in
this case the Apex Court rules that nobody could be permitted to cause noise or violets nice
pollution norms in the name of religion, tradition, or festivals.6

Now; we have to study section 425 of IPC so, we can understand the section 430 & 431
of IPC which is related to environmental criminal law.

Section 425 of IPC define mischief-

Whoever with intend to cause, or knowing that he is likely to cause, wrongful loss or damage
to the public or to, any person, causes the destruction of any property or any such damage in
any property or in the situation thereof as destroys or demises its value and utility or effects
injuriously, commits “mischief”.

Explanation- Mischief may be committed by an act affecting property belonging to the

person who commits the act or to that person and others jointly causing diminution of water
supply has been treated as mischief in section 430 of the Code and the possible direct cause
may also be pollution. Adulteration of food or drink so as to make it noxious has also been
make punishable7.

6
AIR 2000 SC 2773: 2000 (5) ALT 22 (SC): JT 2000 (9) SC 575: 2000 (3) KLT 651 (SC): 2000 (6) SCALE
163: (2000) 7 SCC 288: 2000 CrLJ 4022.
7
L.M. Mathur, “A federal Legislative History of Control of Water Pollution in India.

3
Section 430 of IPC define mischief by injury to works of irrigation or by wrongfully
diverting water-

 The accused committed mischief;

 The mischief caused or was likely to cause diminution of supply of water;
 Such supply was for agricultural purposes or for drinking purposes of human
beings and animals.

Section 431 of IPC define mischief to public road, bridge, river or channel-

 The accused commits mischief;

 The mischief consists of an act which renders or which he knows to be likely to
render any public road, bridge, navigable river, navigable channel impassable;
 Such mischief was done with knowledge that it would or was likely to cause such
injury.

The offence is cognizable, bailable but not compoundable and tribal by a Magistrate
of first class. Punishment may extend to five years of imprisonment, or fine, or both.

The Indian Criminal Procedure Code of 1973 (CrPC):-

The Indian Criminal Procedure Code of 1973 has a significant chapter on maintenance of
public order and tranquility. The most relevant section in CrPC is section 133, which has
been resorted to an effective remedy to abate public nuisance in instances of environmental
harm. The provisions in the old Indian Law, which have a bearing on the Environment, have
hardly been used in the past. The consciousness to protect the environment was not as strong
then, as it is today.

4
Brihanmumbai Municipal Corporation (BMC) could court trouble on
failure to clean drains:-

With the monsoons ready to lash Mumbai, many citizens are worried that they will again
have to undergo the annual misery of wading through flooded homes and streets only because
the BMC failed to clean up choked drains and nullahs. People feel helpless in trying to get the
municipality to act and find themselves stonewalled by red tape. The answer may lie in the
use of a little known but powerful provision of the Criminal Procedure Code (CrPC), under
which a common man can knock on the doors of the local magistrate and get a judicial order
asking the municipality to do its job.

Section 133 of the CrPC empowers a magistrate to pass an order for "removal of nuisance''.
Thus, if citizens of a locality believe that constant dumping of debris in a nearby nullah or an
obstruction to a drain is going to result in flooding and loss, then they can approach a
magistrate under this section to get the BMC to put an end to such a nuisance. “It is a
powerful provision in hands of the people,'' said advocate Pradeep Havnur.”It can be used to
force the BMC to take action,'' he added. Lawyers pointed out that by resorting to this
provision, citizens will not have to approach the Bombay high court by filing a writ or a
Public Interest Litigation (PIL) every time they want the BMC to clean up a drain. On
receiving a complaint, the magistrate is likely to order a preliminary inquiry and ask the BMC
to submit a report on the citizens' grievances. Thereafter, he can also pass a conditional order
asking the BMC to clean up the choked drain or nullah.

The Municipal Corporation of Greater Mumbai & Ors. v.Dalamal Tower Premises Co-
operative Society Limited & Anr, September 11, 2012.
In a landmark case decided by the Supreme Court, the Municipal Corporation of Ratlam, a
town in Madhya Pradesh, was ordered to construct drains and toilets, provide proper
sanitation and hygiene after residents filed a complaint under section 133 of the CrPC that the
stench in their vicinity was unbearable.
Interestingly, the term `nuisance' is not capable of an exact definition under the law and
broadly means an act or omission which causes injury, danger or annoyance to common
public. Thus, recently actress Kunika Lal used section 133 of CrPC to take action against

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vehicles that were parked illegally in her locality and were cause of trouble for motorists and
residents alike.8

Different types of Environmental Crimes:-

Environmental crime covers a wide range of violations that results in harm befalling the
environment and human life, from errors at the administrative or record keeping level to the
actual illegal dumping of pollutants into the environment.

Environmental crimes may include but are not limited to the following:-
a) Littering.
b) Improper waste disposal.
c) Oil spills.
d) Destruction of wetlands.
e) Dumping into oceans, stream, lakes, or rivers.
f) Improperly handling pesticides or other toxic chemicals.
g) Burning garbage.
h) Falsifying lab data pertaining to environmental regulations.

Punishment- Environmental law violators are usually hit with the criminal fines, probation,
jail time, or a combination of these punishments. While jail time may be the most formidable
punishment for individuals who commit environmental crimes, fines are intended to catch
large corporations from violating environmental laws and regulations. Without the threat of
heavy monitory punishment, some corporations might find that noncompliance is more cost
effective than obeying the law. At the federal level, the Environment Protection
Agency (EPA) has enforcement authority over environmental law violations.

8
http://timesofindia.indiatimes.com/city/mumbai/BMC-could-court-trouble-on-failure-to-clean-
drains/articleshow/4598774.cms.

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Environmental Law and the Indian Constitution-

Environmental Law
A variety of protections with the goal of protecting the environment. Environmental law is a
“belt-and-suspenders” collection of laws that work together and often overlap in areas.

The National Environmental Policy Act (NEPA) was passed in 1970 along with the
Environmental Quality Improvement Act, the National Environmental Education Act, and the
Environmental Protection Agency (EPA). The main objective of these federal enactments
was to assure that the environment be protected against both public and private actions that
failed to take account of costs or harms inflicted on the eco-system.

The EPA is supposed to monitor and analyze the environment, conduct research, and work
closely with state and local governments to devise pollution control policies. The basic
purpose of NEPA is to force governmental agencies to consider the effects of their decisions
on the environment.9

The Environment Protection Act, 1986 was enacted to provide for the protection and
improvement of the quality of environment and preventing, controlling and abating
environmental pollution. The Act came into existence as a direct consequence of the Bhopal
Gas Tragedy. It has given vast powers to the Central Government to take measures with
respect of planning and execution of a nation- wide programme for prevention, control and
abatement of environmental pollution.10

National Green Tribunal (‘NGT’)

The National Green Tribunal (‘NGT’) was established on 18th October, 2010 under the
National Green Tribunal Act 2010. The Tribunal is dedicated to the effective and expeditious
disposal of cases relating to the subject of forest, environment, biodiversity, air and water. It
is a specialized body equipped with the necessary expertise to handle environmental disputes
involving multi-disciplinary issues. The National Green Tribunal started functioning since
4th July, 2011. The Principal Bench is based at New Delhi with circuit benches at Chennai,

9
https://www.law.cornell.edu/wex/environmental_law
10
http://tex-warrier.in/2013/08/constutional-provisions-and-india/.

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Bhopal, Pune and Kolkata so that it can reach remoter parts of India. The principal bench and
the regional benches are all currently functional.

In the year that the National Green Tribunal has functioned, it has delivered a number of
significant judgments on range of issues from across the country. This Tribunal is therefore
an important step in the access to justice on matters concerning the environment and its
mandate is much wider than earlier environmental Courts and Authorities and other such
Courts.
Access to information, public participation and access to justice are important elements of
environmental democracy and the Centre for Environmental Law (CEL) actively works on
these components to strengthen engagement in environmental law and policy. CEL will play
a critical role in addressing the strategic requirement for legal research to be done on many of
the issues being heard in National Green Tribunal. WWF – India will assist the environment
counsels in taking up the matter before the tribunal and to give its inputs as and when
required by the green tribunal.

In this context, the CEL is creating and providing an information depository of the judgments
and orders given by the National Green Tribunal since it became functional. CEL believes
that the effective implementation of environmental law through easily accessible information
is an effective tool to ensure protection of areas of vital ecological concern.11

Judgement of the National Green Tribunal (Central Zonal Bench, Bhopal) in the matter of
Chhattisgarh Nagrik Sangarsh Samiti Vs Principal Secretary, Nagariya Parishashan and
Vikas Vibhag & Others dated 27/09/2016 regarding imposing a ban on the use of DJs and
loudspeakers along with the all types of processions including rallies, Chhattisgarh. The
Applicant has further said that erection of pandals and welcome gates on public properties
and on roads leads to congestion and blockages of traffic which also causes high levels of air
pollution and noise pollution as such permissions should not be accorded.

National Green Tribunal directs the State of Chhattisgarh to ensure that sufficient number of
monitoring stations in urban areas with specialized equipments for monitoring air and noise
pollution levels be installed with the data being made available at the level of the CECB for
taking effective steps in this behalf.12

11
http://www.wwfindia.org/about_wwf/enablers/cel/national_green_tribunal/
12
http://www.indiaenvironmentportal.org.in/content/436363/judgement-of-the-national-green-tribunal-
regarding-banning-use-of-djs-and-loudspeakers-along-with-the-all-types-of-processions-chhattisgarh-27092016/

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Judgement of the National Green Tribunal (Eastern Zone Bench, Kolkata) in the matter of
Madan Lal Vs Ministry of External Affairs & Others dated 21/09/2016 regarding severe
pollution of the river Churni (Nadia District, West Bengal) resulting in huge fish-kill. The
applicant submitted before the Court that a factory named “Karo and Company” located at
Darshana in Bangladesh manufacturing sugar, wine, chemicals etc. releases its stored waste
water from Lagoon into the river Mathabangha which ultimately finds its way into the river
Churni thereby polluting the water significantly.

National Green Tribunal directs the Ministry of External Affairs to continue negotiating with
the Govt. of Bangladesh on setting up of an Effluent Treatment Plant with funding by Govt.
of India for the industries contributing to the pollution of river Mathabanga which
subsequently flow into river Churni in West Bengal13

Part IV Directive Principles of State Policy:-

Article 48A says that, the state shall endeavor to protect and improve the environment and to
safeguard the forests and wildlife of the country. The parliament had considerable debate
over the wording of the draft Article 48A. Several amendments were moved in both the
houses of the parliament. H.M.seervai has correctly pointed out; Article 48A reflects an
increasing awareness of people all over the world of the need to preserve the environment
from pollution, especially in urban areas. Article 48A rightly emphasis the fact that the State
should try not only to protect but to improve the environment.14

Article 39(e), 47 and 48A of Directive Principles of State Policy have a definite bearing of
environmental problems. They, by themselves and collectively impose a duty on the State to
secure the health of the people, improve public health and protect and improve the
environment. Environmental pollution may damage the monuments of national importance,
the protection of which is a duty of the State under Article 49 of the Constitution.

Part IVA Fundamental Duties of the Citizens related to Environmental Crime-

Article 51A(g)- It shall be the duty of every citizen of India to protect and improve the
natural environment including forests, lakes, rivers, wildlife, and to have compassion for
living creatures. In the words of Ranganath Mishra, J: "Preservation of environment and

13
http://www.indiaenvironmentportal.org.in/content/436104/judgement-of-the-national-green-tribunal-
regarding-severe-pollution-of-the-river-churni-nadia-district-west-bengal-resulting-in-huge-fish-kill-21092016/

14
Hormasji Maneckji Seervai, Constitutional Law of India: A Critical Comentary, (2019)2 1993.

9
keeping the ecological balance unaffected is a task which not only Government but also every
citizen must undertake. It is a social obligation and let is remind every citizen that it is his
fundamental duty as enshrined in Article 51A (g) of the Constitution.15

Part III Fundamental Rights related to Environmental Crime-

The Part III of the Indian Constitution was interpreted widely by Hon'ble Judges like
P.N.Bhagwati, Kuldeep Singh, V.R.Krishna Iyer, and H.R. Khanna who recognized the 'third
generation rights ' (environmental rights) as a constitutional mandate and applied them
remarkably. The interpretation given by the Supreme Court in Maneka Gandhi's case16 had
added new dimensions to the concept of personal liberty of an individual. In other words,
environmental pollution which spoils the atmosphere and thereby affects the life and health
of the person has been regarded as amounting to violation of Article 21 of the Indian
Constitution.17 In M.C. Mehta v. Union of India, 18 the apex Court invariably spelt out the
citizens ' Right to Clean Environment 'which was in turn derived from the protection of life
and liberty enumerated in Article 21.The indirect approval of the right to health environment
by the supreme court continued further in the Oleum Gas leake case.19

Freedom of Trade - Article 19 (1) (g) of the Constitution guarantees to all citizens of India,
the right to practice any profession or to carry on any occupation or trade or business. The
freedom however, is not uncontrolled. The aggrieved industrialist may resort to Article 19 in
case his trade and business interests are affected by the action of governmental agency in the
name of the environmental protection.

Department of Environment for Planning, Promotion and Coordination of

Environment Programmes in India:-

At the beginning of the IVth Five Year Plan, problems related to environment received
explicit attention of our Government. A National Committee on Environmental Planning and
Coordination (NCEPC) was setup in 1972 at the initiative of the Prime Minister Smt. Indira
Gandhi. The mandate of the NCEPC was to identify and investigate the problems of
15
Rural and Entitlement Kendra v. State of U.P. AIR 1987 SC 359, 364.

16
Maneka Gandhi v. Union of India, AIR 1978 SC 597.
17
Kailash Thakur Environment Protection Law and Policy in India.
18
(1996) 4 SCC 750.
19
M.C. Mehta v Union of India & Ors 1987 SCR (1) 819 (Oleum Gas Leak Case)

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preserving or improving the environment in India. Thus, in November, 1980, a separate
Department of Environment was setup to act as the pivotal agency in the administrative
structure of the central government for planning, promotion and coordination of
environmental programs.

Actions Taken For Prevention and Abatement of Pollution:

* for monitoring water quality 480 stations have been setup all over the Country. Similarly,
188 air quality monitoring stations have been setup.
* The identification of 22 critically polluted areas and highly polluted zones of the country
for better control and monitoring.
* Rules have been formed for Manufacture, Storage, Transportation, Handling and Disposal
of Hazardous substances including Waste and Micro-organism.

National Crime Report Bureau Data for Environmental Crime: Before, study the NCRB
records it is important to know, that how the NCRB defines an environment related offences,
it includes violations under five Acts:-
* The Forest Act, 1927.
* The Wildlife Protection Act, 1972.
* The Environment Protection Act, 1986.
* The Water Prevention and Control of Pollution Act, 1974; (as amended in 1988).
* The Air Prevention and Control of Pollution Act, 1981.

NCRB says over 50% of environment - related offences in Rajasthan.

In 2016, the NCRB began compiling data on environment related offences. The data
declared the following details: -
* Total, all- India environment related offences registered in 2016 are 5,835.
* Rajasthan recorded the most environmental crimes. Rajasthan, with 2,927 cases, accounts
for half of all environmental crimes committed in India in 2016.
* 8,765 people were arrested across India during 2014 on account of environmental crimes.
Of those 8,765 people, nearly 75% (6,601) were from Rajasthan and Uttar Pradesh (3,281)
alone.
* The next highest number of people arrested was from Karnataka at 393 cases.
* Most cases and arrests were regarding violations of the Forest Act 1927, because violations

11
under this Act, such as cutting trees, are easier to record.20
* The data released by NCRB has revealed that environment crimes across the country fell in
2017 with 5,156 offences compare to 5,835 incidents.
* In 2017, a total of 8,034 people were arrested across India on account of Environmental
crimes.
* Another interesting revelation made by data is that of the 8,034 people arrested from
environmental crimes in 2015, 99.71% (8,011) were men and only 23 were women.21
* In 2016 environmental crimes in India shows an 11% drop in comparison to last two years.

Some Related Case Laws:-

Maulana Mufti Syed Md. Nourur Barkati v. State of West Bengal, AIR1999 Cal 15, that
Schedule III of the Environmental (Protection) Rules, 1986 is ultra vires Articles 14 and 25 of
the Constitution. By the Judgment dated 1st of April, 1996, certain restrictions and conditions
on the use of microphones in the State of West Bengal were imposed. One of the important
conditions that was laid down was that there will be no user of any; the writ application has
been filed by Moulana Mufti Syed Md. Noorur Rehman Barkati, Imam and Khatib. Tipu
Sultan; Shahi Masjid, Dharamtala and Chairman Gharib Nawaz Educational and Charitable
Society, Calcutta and eight others for a declaration that Rule 3 of the Environmental
(Protection) Rules, 1986 vis a vis Schedule III of the said Rule do not apply in case of
Mosques more particularly at the time of call of Azan from the Mosques and for the further
declaration microphones between 9 p.m. to 7 a.m. except by the public authorities for
discharging their emergent public duties and/or obligations and that the West Bengal
Pollution Central Board was directed to maintain noise level register indicating the level of
noise which could be permitted by use of microphones on any occasion or in any area. This
Court passed an order in disposing of the writ application, inter alia, holding that Freedom of
Speech and Expression of a citizen guaranteed under Article 19(1)(a) of the Constitution
cannot be interfered with save and except in accordance with the provisions of Article 19(2)
of the Constitution.

20
http://www.insightsonindia.com/2015/12/26/insights-into-editorial-the-gap-in-environmental-crime-statistics.
21
http://gurumauin.com/environment-crimes-decrease-inindia-ncrb/.

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Union of India v. Raghubir Singh 1989 AIR 1933, 1989 SCR (3) 316,

Pomal Kanji Govindji v. Vrojlal Karsandas Purohit. 1989 AIR 436, 1988 SCR Supl. (3)
826,
National Workers' Union v. P.R. Ramkrishnan1983 AIR 750, 1983 SCR (3) 12:
The Supreme Court held that where a law of the past does not fit in the present context,
the Court should evolve a new law and if the law fails to respond to the needs of the changing
society, then either stifle the growth of the society and choke its progress or if the society is
vigorous enough it will cast way the law which stands in its way of its growth. Law must,
therefore, constantly be on the move adopting itself with the fast changing society and not lag
behind. Being conscious of and for giving effect to this legal position this Court directed the
State Pollution Control Board by its order dated 30th September, 1996 to take suitable
measure to stop creating sound pollution by means of other than use of microphones, such as
by use of electric air horn in the public vehicles and fireworks and other sources of sound
nuisance.22

M.C Mehta v. Union of India, AIR 1997 SC 734 In the TAJ Case the National
Environment Engineering Research are institute (NEERI) gave overview reporting 1990
implying that the pollution levels are quite high around the Taj and this was seriously a very
major problem for Taj as well as the ecosystem in the area.

22
https://indiankanoon.org/doc/738693/.

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Reference:-

Books:

1. Jaiswal, P.S., Common Law and other Statutory Remedies, Environmental Law,
Pioneer Publications, New Delhi.
2. Sadasivan Nair, G., Environmental Offences-Crimes against Humanity and the
Environment, Cochin University Law Review, School of Legal Studies, Volume 11.
3. The Indian Pena Code, K.D Gaur Fourth Edition, Forward by Justice V.N.Khare,
Chief Justice of India.
4. Diwan, Shayam and Armin, Constitutional and Legislative Provisions, Environmental
Law and Policy in India-Cases; Materials and Statutes, Oxford University Press, New
Delhi.
5. Jaiswal, P.S., Constitutional Provissions and Environmental Protection in India,
Environmental Law, Pioneer Publications, Delhi.

Web Article:

1. Singh, Jaspal, Constitutional Safeguards for Environment and Heritage.

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Conclusion & Suggestions:-

Environmental crimes continue to impact society. The significance of environmental

harms, particularly with regard to public health and sustainability, is real. Much
progress has been made in the short time that major environmental laws, and the EPA,
have been in existence. While it is easy to draw attention to the limitations of
environmental protection efforts, one must consider the progress that has taken place
since 1970. Fifty years ago, there was no EPA. There were no substantial
environmental laws. Environmental protection was a non-issue to many. Now,
consider the shape of the environment 50 years into the future. Is enough being done
to ensure that the generations to come will not suffer the ill effects of today’s
neglectful environmental practices? Continued development with regard to
environmental protection will undoubtedly result in a safer, healthier environment for
those who follow. The future of environmental protection is full of hope. Progress
toward a better environment demands consideration of the complexities inherent in
environmental crime. For example, progress will require law enforcement and
regulatory agencies to become increasingly familiar with enforcement practices
related to environmental crime. Legislation will need to continuously emerge and
develop, society must maintain its interest in environmental protection, and
sustainability will hopefully be the status quo and not simply a buzzword. Further,
researchers will need to extend beyond their academic boundaries, and countries will
need to work collaboratively as expansive efforts are required for environmental
protection. Anything less would be a step backward in the evolution of environmental
protection and contribute to the ignorance of environmental crime. NCRB’s new
move to compile data on environment- related offences can be cell as a fantastic step
and a good starting point it is a very good, that environmental Crime data is being put
out in public domain. In our opinion, Environment Protection can be more effective
when NCRB’s consider beyond the all Acts which they usually consider while the
violation of Environment, when they will consider other Acts and collectively enforce
all that to the general Public the Offence regarding the Environment definitely
decrease. Justice V.R. Krishna Iyer said that, “It is not how many Laws we have, it
is how effectively we implement”.

15