Authored By: Devyani Suryawanshi
Manikchand Pahade Law College Aurangabad
Case Title
Rural Litigation & Entitlement Kendra, Dehradun & Others v. State of Uttar Pradesh & Others 1985 AIR 652
Court: Supreme Court of India.
Judges: Justices P. N. Bhagwati, Amarendra Nath Sen, and Rangnath Misra.
Bench: Constitutional Bench.
Date of Judgement: March 12, 1985
Parties Involved
Petitioners: Rural Litigation & Entitlement Kendra (RLEK), Dehradun, and others (villagers and environmental activists)
Respondents: State of Uttar Pradesh, lessees, quarry miners and other governmental bodies (mining department, forest department etc.)
Facts of the Case
- The Doon Valley and its ecological importance
The Doon Valley, also called the Dehradun Valley, lies between the Shivalik hills and the Himalayan ranges in Uttarakhand[1]. It is known for its rich forests, biodiversity, natural springs, and limestone deposits[2]. The Mussoorie Dehradun belt became a hotspot for limestone mining because the stone was used in cement, iron, and steel industries[3]. Originally, quarrying was seen as economically beneficial[4]. However, the fragile ecosystem of the valley was delicate, uncontrolled making unchecked mining soon led to widespread ecological degradation[5]. - Mining leases and environmental degradation started from the 1950s and 1960s onward, successive governments granted numerous leases for limestone quarries in the valley[6]. Over time, the number of quarries multiplied, many of them operating in a haphazard and unscientific manner[7]. Forests were cleared for mining roads and excavation areas, resulting in deforestation and loss of biodiversity[8]. The removal of vegetation destabilized hill slopes, leading to soil erosion and frequent landslides especially during monsoon[9]. Many perennial springs and streams dried up or got polluted, depriving villagers of drinking water and irrigation[10]. The natural beauty and ecological balance of the valley were threatened, affecting local agriculture, tourism, and the very quality of life of people living there[11]. The cumulative effect was that what began as an economic activity soon became an ecological crisis[12].
- Petition to the Supreme Court in 1983 the Rural Litigation and Entitlement Kendra (RLEK), a Dehradun-based NGO working for the rights of villagers wrote a letter to the Supreme Court highlighting the severe damage caused by indiscriminate quarrying[13]. The Court treating this letter as a public interest litigation (PIL) under Article 32 of the Constitution, converted it into a writ petition[14]. This was significant because it showed how the judiciary was willing to step in directly when fundamental rights, such as the right to life under Article 21, were endangered by environmental harm[15].
- Appointment of expert committees recognizing that technical expertise was necessary to assess the ecological impact, the Supreme Court directed the Union Government to conduct an investigation[16].
- Two expert bodies were formed- The Bhargava Committee (headed by D. N. Bhargava, a senior geologist) Tasked with physically inspecting the quarries, studying their environmental impact, and classifying them into categories based on whether they were suitable or unsuitable for further operation[17].
The Working Group: Assisted in technical analysis, applying scientific criteria such as slope stability, distance from forests, proximity to water sources, and risk of landslides[18]. These committees introduced a more scientific and evidence-based framework into the legal proceedings, bridging the gap between environmental science and constitutional law[19].
- Classification of quarries after extensive fieldwork, the committees placed quarries into three broad categories: Category A quarries located in comparatively stable areas where controlled mining could be allowed under strict conditions and modern techniques[20].
Category B quarries that might be operated only with significant safeguards and corrective measures[21].
Category C quarries that posed severe risks to forests, water sources, or slope stability, and whose operation would lead to irreversible environmental damage[22].
The reports revealed that a large number of quarries fell into Category C[23]. These were often located in ecologically fragile zones where even small disturbances could cause landslides or loss of groundwater[24]. Based on these, the Supreme Court ordered the closure of all Category C quarries, while allowing Category A and B quarries to function only under strict regulatory oversight[25].
Issues Raised
The ongoing quarrying operations in the Doon Valley were causing irreversible environmental and ecological damage that violated constitutional rights, especially the right to life under Article 21[26]. The case was that the question of whether uncontrolled mining was more than just an administrative or economic concern[27]. The petitioners argued it was a fundamental rights violation of the Indian Constitution that guarantees the right to life and personal liberty[28]. The Supreme Court had interpreted “life” broadly to include the right to live with dignity, clean water, clean air, and a healthy environment[29]. The quarrying in the Doon Valley slopes was causing landslides, silting of rivers, and drying up of water springs that villagers depended on[30]. These harms were not temporary but irreversible once forests and aquifers were destroyed and they could not easily be restored[31]. Therefore, the Court had to decide whether continuing mining operations amounted to violating people’s fundamental right by threatening their environment and survival[32].
- Whether the State’s granting or renewing leases for quarries without proper inspection, classification, or conditions were lawful, the case raised the question of whether the State government acted within its legal authority when it granted and renewed mining leases[33]. Many quarries were allegedly sanctioned without adequate scientific studies or environmental assessments[34]. The officials renewed leases without considering whether the area was already damaged or whether the leaseholder had followed safety norms[35]. The petitioners argued that such actions were arbitrary, violative of statutory requirements and inconsistent with the duty of the State under Article 48A of the Directive Principle requiring the State to protect the environment[36]. The Court had to evaluate whether the State was complicit in allowing harm to ecology by failing to regulate mining activity properly[37].
- What should be the criteria for allowing certain quarries to operate vs closing others e.g. safety, health, ecological balance, distance from forests, water sources etc[38]. Since mining was also an economic activity that generated employment and industrial raw materials, the Court had to balance the development with environmental protection[39]. The core issue here was on what basis should a quarry be considered safe or unsafe[40]. For which the Expert committees suggested the stability of the slope and risk of landslides, proximity to water springs, rivers, forests and the impact on soil fertility, agriculture, and groundwater recharge and to compliance with safety norms under the Mines Act and the use of scientific mining techniques[41]. The Court needed to decide whether mining should be completely banned or whether it could continue in selected sites under strict regulations[42]. Eventually, they opted for a differentiated approach closing high-risk quarries that is Category C while allowing others under conditions[43].
- Whether leases should expire or not and whether to continue mining after the expiry of lease was valid and the renewals were automatic or subject to conditions[44]. Another important legal issue was about property rights vs environmental duties[45]. Quarry owners argued that they had rights to continue mining even after lease expiry, claiming renewals were routine and should be granted[46]. Petitioners countered that once a lease expires, the lessee has no legal right to continue mining unless the State renews the lease in accordance with law and environmental safeguards[47]. The Court agreed that renewals are not automatic, they depend on fresh evaluation of ecological impact and compliance with statutory conditions[48]. This principle prevented the notion of mining leases becoming perpetual entitlements[49].
- Applicable of legal and statutory framework Mines Act, Forest Conservation, rules about renewal, environmental standards etc. Also whether authorities had followed due process[50]. Several laws and rules were relevant to the dispute[51]:
- The Mines Act, 1952 imposed obligations on quarry operators regarding safety of workers, working conditions, and mining methods[52]. Many quarries were not following scientific mining practices[53].
- The Forest (Conservation) Act, 1980 required prior approval from the central government for use of forest land for non-forest purposes[54]. Quarrying in forest areas without such approval was unlawful[55].
- The Environment (Protection) principles under Article 48A & 51A(g) though not yet fully codified in law (since the Environment Protection Act, 1986, came later), these constitutional provisions obligated both the State and citizens to protect the environment[56].
- Government rules on mining leases renewal had to be based on compliance, not just on past practice[57].
- The Court examined whether the State authorities followed due process while granting or renewing leases[58]. The finding was that in many cases, there was negligence, absence of environmental consideration, and failure to enforce laws[59].
Arguments of the Parties
Petitioners of the Rural Litigation and Entitlement Kendra, villagers, environmental activists started their arguments by stating the points:
- Serious ecological degradation that threatens human life and livelihood of the villagers[60]. Petitioners argued that the large-scale and unregulated limestone quarrying in the fragile Doon Valley was causing irreversible damage to the ecosystem[61]. Specific harms which included frequent landslides, loss of forest cover, drying up of perennial springs, and soil erosion that destroyed agricultural land[62]. These effects had a direct bearing on people’s daily lives and the loss of clean water for drinking and irrigation, declining crop yields, air pollution from blasting, and even loss of shelter due to landslides[63]. The villagers stressed that these harms were not merely environmental but were linked to the fundamental right to life under Article 21[64].
- Illegal and irregular operations of quarries stated by the petitioners highlighted that many quarries were operating without valid leases, or had continued to mine beyond their lease period with the connivance or negligence of State authorities[65]. Some quarries were being run in forest areas without central government clearance, violating the Forest Conservation Act, 1980[66]. They pointed to a lack of proper monitoring, inspection, or enforcement by government officials, which made the entire system arbitrary and unlawful[67].
- Environment takes priority over economic profits while acknowledging the industrial importance of limestone, the petitioners argued that economic gains cannot justify ecological destruction[68]. They relied on the constitutional principles of Article 48A that is The State’s duty to protect the environment and Article 51A(g) states that its citizen’s duty to protect the environment and to argue that preservation of nature must come first[69]. They also stressed the precautionary principle that once natural resources like forests, springs, and soil are destroyed, no amount of money can bring them back[70].
- Demand for classification and regulation. Petitioners did not argue for an outright ban on all mining but sought scientific classification of quarries based on ecological sensitivity[71]. They asked the Court to order closure of mines in fragile zones such as hill slopes and forest areas and impose strict conditions on others that might be allowed to continue[72]. Renewal of leases should be strictly conditional and not a matter of routine administrative practice[73].
- Petitioners framed mining as a constitutional and ecological crisis, a direct assault on the right to life and the natural balance of the valley[74].
Respondents State of Uttar Pradesh, quarry operators ,mining companies stated their response as:
- Economic importance of quarrying activity, quarry operators and the State argued that limestone was an essential raw material for cement, iron, steel, and chemical industries, which were vital to India’s economic development[75]. They stressed that the closure of quarries would have a severe economic impact, loss of revenue for the State, loss of employment for hundreds of workers, and disruption of industrial supply chains[76]. The State also contended that mining leases were granted to promote regional development, as quarrying provided livelihoods in the otherwise hilly and less industrialized Doon Valley[77].
- Right to lease renewal and expectations of lessees in mining companies argued that they had invested substantial capital in setting up quarrying operations and machinery[78]. They claimed that the renewal of leases had been routine[79]. Hence, lessees had a legitimate expectation or vested right to continuation[80]. By denying renewal abruptly, would amount to arbitrary state action and cause severe economic loss to private parties[81].
- Not all quarries are equally harmful. Respondents disputed the sweeping claim that all quarrying was destructive[82]. They argued that some quarries were located in relatively stable geological areas or far from forests and water springs[83]. They claimed that scientific mining techniques such as controlled blasting and slope management could mitigate potential damage[84]. They also challenged the classifications made by expert committees, saying that the methods used were not uniform or that some quarries were wrongly categorized as harmful[85].
- Procedural compliance and legality of operations. Quarry owners argued that most operations had been conducted under valid licenses and leases granted by the State[86]. They pointed out that the State itself had recognized their legal right to mine[87]. If the government now sought to revoke or refuse renewals, it should do so through proper legal channels and provide compensation where appropriate[88]. The State also defended itself by saying that it had begun steps to regulate quarrying through committee reports and classification, and thus it was not ignoring its environmental duties[89].
- Respondents framed it as an economic necessity essential for development, employment, and industrial growth while claiming legality and disputing the extent of damage[90].
Judgement of the Court
- Administrative Level (Pre-litigation stage)
For decades 1950 to 1970, the State of Uttar Pradesh granted mining leases for limestone quarrying in the Mussoorie Doon Valley region[91]. Local forest and mining officials were supposed to regulate them under the Mines Act, 1952, the Indian Forest Act, and related rules[92]. However, regulation was extremely lax[93]. Many quarries operated without renewal of lease once the original period expired[94]. Expanded beyond their sanctioned boundaries[95]. Flouted basic safety of environmental measures[96]. The state machinery largely failed to prevent ecological destruction[97]. This administrative inaction laid the groundwork for judicial intervention[98].
- High Court level (Allahabad High Court)
There were scattered proceedings in local forums and High Court concerning particular leases, but they remained fragmented[99]. Some quarry owners challenged attempts by authorities to stop their operations, others demanded renewals as a matter of right[100]. The High Court often dealt with narrow lease contractual disputes and did not treat the matter as one of environmental constitutional rights[101]. Because of this piecemeal approach, the larger ecological crisis remained unaddressed[102].
- Supreme Court (PIL under Article 32)
In 1983, the NGO Rural Litigation and Entitlement Kendra (RLEK), on behalf of local villagers, wrote a letter to the Supreme Court complaining about unscientific and illegal quarrying in the Doon Valley[103]. The Court converted this letter into a Writ Petition under Article 32, invoking its jurisdiction to enforce Fundamental Rights of Article 21 Right to Life[104] . Unlike the High Court cases, the Supreme Court treated the problem as a systemic environmental and human rights issue, not just an administrative or contractual dispute[105].
- Supreme Court’s Directions During Proceedings (1983–1987)
Instead of giving an instant ruling, the Court adopted a fact-finding and supervisory role, Appointed the Bhargava Committee and the Working Group to inspect the quarries[106]. Classified mines into categories of Category A relatively safe. Category B conditional and intermediate. Category C unsafe, ecologically harmful[107]. The Court issued interim orders, some quarries were closed temporarily while awaiting final classification[108].
- Final Decision of the Supreme Court (1987)
After reviewing committee reports and hearing both sides, the Court delivered its landmark judgment[109]: Closed all Category C quarries unsuitable for continuance[110]. Allowed with strict conditions some Category A and B quarries[111]. Clarified leases, Expired leases cannot be renewed as a matter of right renewal depends on environmental clearance and compliance with law[112]. Established monitoring continued oversight by authorities under the Court’s watch[113].
- Continuing Mandamus (Post-judgment supervision)
Even after the 1987 judgment, the Court kept the matter pending for monitoring compliance, a concept later known as “continuing mandamus”Rural Litigation and Entitlement Kendra v State of Uttar Pradesh (1987) Supp SCC 487, at [28].[114]. This meant the Supreme Court was not just adjudicating but also regulating the enforcement process, calling for reports, and issuing further directions if needed[115]. The Court thus became a long-term guardian over quarrying in the Doon Valley[116].
Legal Reasoning-Ratio Decidendi
Right to Life (Article 21) includes a right to a healthy environment[117]. The Supreme Court read environmental protection into Article 21, declaring that the “right to life” is not restricted to mere animal existence but includes the right to live with dignity, health, and ecological balance[118]. Degradation of the Doon Valley’s forests, springs, and slopes threatened the very survival of villagers and their livelihoods[119]. Thus, quarrying that damaged ecology was not just a regulatory violation but a constitutional violation[120]. This principle became a cornerstone of Indian environmental law, influencing later cases like Subhash Kumar v. State of Bihar 1991 and Vellore Citizens’ Welfare Forum v. Union of India 1996[121]. Precedential Value for Indian Environmental Jurisprudence The Doon Valley case is often cited as one of the earliest PIL based environmental cases[122].
Conclusion
The Doon Valley case (RLEK v. State of U.P./M.C. Mehta v. Union of India) is one of the earliest and most important environmental PILs in India, which made it clear that the right to life under Article 21 of the Constitution also means the right to live in a clean and healthy environment[123]. The Court relied on expert committees like the Bhargava Committee to base its decision on scientific facts, and it set clear standards by deciding which quarries had to be shut down and which could continue under conditions[124]. The Court also took a balanced view to acknowledge the need for limestone as an industrial raw material and for local employment, but made it clear that economic benefits cannot come at the cost of irreversible damage to nature[125]. Another strength of the case was the Court’s firm stand on accountability, making it clear that mining leases are not automatic or permanent rights but privileges that depend on following environmental and legal rules[126]. The case showed some challenges like the carrying out the Court’s directions on the ground was difficult due to political and economic pressures, there was often confusion about which quarries were safe or unsafe, and shutting down mines, while necessary for the environment, left many workers without proper support or alternative livelihoods[127]. Even with these problems, the legacy of the case is very strong. It expanded Article 21 to include environmental rights, stressed the need for environmentally sensitive decisions in granting and renewing leases, applied a precautionary approach to stop ecological harm before it happened, and highlighted the importance of expert scientific input in legal decisions[128]. Most importantly, it made it clear that protecting the environment is not just a side issue but a central part of constitutional rights, turning this case into a landmark in India’s environmental law and a precedent used in many later decisions[129].
Reference(S):
[1] Rural Litigation and Entitlement Kendra v State of Uttar Pradesh (1985) 2 SCC 431, at [2].
[2] ibid.
[3] Rural Litigation and Entitlement Kendra v State of Uttar Pradesh (1987) Supp SCC 487, at [5].
[4] S Divan and A Rosencranz, Environmental Law and Policy in India (2nd edn, Oxford University Press 2001) 141.
[5] Armin Rosencranz and Shyam Divan, ‘Case Study: Doon Valley Litigation’ in P Leelakrishnan (ed), Law and Environment (3rd edn, Eastern Book Company 2008) 221.
[6] Rural Litigation (1985) 2 SCC 431, at [4].
[7] ibid.
[8] Rural Litigation (1987) Supp SCC 487, at [12].
[9] ibid.
[10] ibid.
[11] Divan and Rosencranz (n 4) 142.
[12] Rosencranz and Divan (n 5) 223.
[13] Rural Litigation and Entitlement Kendra v State of Uttar Pradesh (1985) 2 SCC 431, at [3].
[14] ibid.
[15] MC Mehta, Public Interest Litigation and the Environment (1996) 5 JEL 1, 5.
[16] Rural Litigation and Entitlement Kendra v State of Uttar Pradesh (1987) Supp SCC 487, at [7].
[17] ibid.
[18] ibid.
[19] S Divan and A Rosencranz, Environmental Law and Policy in India (2nd edn, OUP 2001) 145.
[20] Rural Litigation and Entitlement Kendra v State of Uttar Pradesh (1985) 2 SCC 431, at [9].
[21] ibid.
[22] Supra note 8.
[23] Supra note 8 at 14.
[24] Armin Rosencranz and Shyam Divan, ‘Case Study: Doon Valley Litigation’ in P Leelakrishnan (ed), Law and Environment (3rd edn, Eastern Book Company 2008) 225.
[25] Rural Litigation (1987) Supp SCC 487, at [16]–[18].
[26] Rural Litigation and Entitlement Kendra v State of Uttar Pradesh (1985) 2 SCC 431, at [11].
[27] S Divan and A Rosencranz, Environmental Law and Policy in India (2nd edn, OUP 2001) 147.
[28] Constitution of India 1950, art 21.
[29] Maneka Gandhi v Union of India (1978) 1 SCC 248, at [5]; applied in Rural Litigation (1985) 2 SCC 431.
[30] Rural Litigation and Entitlement Kendra v State of Uttar Pradesh (1987) Supp SCC 487, at [15].
[31] Armin Rosencranz and Shyam Divan, ‘Case Study: Doon Valley Litigation’ in P Leelakrishnan (ed), Law and Environment (3rd edn, Eastern Book Company 2008) 227.
[32] Rural Litigation (1987) Supp SCC 487, at [18].
[33] Rural Litigation and Entitlement Kendra v State of Uttar Pradesh (1985) 2 SCC 431, at [12].
[34] Rural Litigation and Entitlement Kendra v State of Uttar Pradesh (1987) Supp SCC 487, at [14].
[35] Ibid at 15.
[36] Constitution of India 1950, art 48A; S Divan and A Rosencranz, Environmental Law and Policy in India (2nd edn, OUP 2001) 150.
[37] Rural Litigation (1987) Supp SCC 487, at [18].
[38] Rural Litigation and Entitlement Kendra v State of Uttar Pradesh (1985) 2 SCC 431, at [13].
[39] Armin Rosencranz and Shyam Divan, ‘Case Study: Doon Valley Litigation’ in P Leelakrishnan (ed), Law and Environment (3rd edn, Eastern Book Company 2008) 229.
[40] Rural Litigation and Entitlement Kendra v State of Uttar Pradesh (1987) Supp SCC 487, at [11].
[41] Report of the Bhargava Committee (1983), cited in Rural Litigation (1987) Supp SCC 487, at [12].
[42] Rural Litigation (1987) Supp SCC 487, at [16].
[43] Ibid, at 18.
[44] Rural Litigation and Entitlement Kendra v State of Uttar Pradesh (1985) 2 SCC 431, at [14].
[45] Armin Rosencranz and Shyam Divan, ‘Case Study: Doon Valley Litigation’ in P Leelakrishnan (ed), Law and Environment (3rd edn, Eastern Book Company 2008) 230.
[46] Rural Litigation and Entitlement Kendra v State of Uttar Pradesh (1987) Supp SCC 487, at [13].
[47] Ibid, at 14.
[48] Ibid,at 15.
[49] S Divan and A Rosencranz, Environmental Law and Policy in India (2nd edn, OUP 2001) 152.
[50] Mines Act 1952; Forest (Conservation) Act 1980; Environment (Protection) Act 1986.
[51] Rural Litigation (1987) Supp SCC 487, at [16].
[52] The Mines Act 1952.
[53] Rural Litigation and Entitlement Kendra v State of Uttar Pradesh (1985) 2 SCC 431, at [18].
[54] Forest (Conservation) Act 1980, s 2.
[55] Ambica Quarry Works v State of Gujarat (1987) 1 SCC 213, at [11].
[56] Constitution of India, arts 48A and 51A(g).
[57] Government of India, Mineral Concession Rules 1960, rr 22–24.
[58] Rural Litigation and Entitlement Kendra v State of Uttar Pradesh (1987) Supp SCC 487, at [10].
[59] ibid.
[60] Ibid, at 12.
[61] Ibid, at 13.
[62] Rosencranz and Divan, Environmental Law and Policy in India (2nd edn, OUP 2001) 155.
[63] ibid.
[64] Subhash Kumar v State of Bihar (1991) 1 SCC 598, at [7].
[65] Rural Litigation (1987) Supp SCC 487, at [15].
[66] Supra note 54.
[67] Ambica Quarry Works (1987) 1 SCC 213, at [12].
[68] Rosencranz and Divan (n 11) 157.
[69] Constitution of India, arts 48A and 51A(g).
[70] Vellore Citizens Welfare Forum v Union of India (1996) 5 SCC 647, at [10].
[71] Rural Litigation (1985) 2 SCC 431, at [20].
[72] ibid.
[73] Mineral Concession Rules 1960 (n 6).
[74] Rural Litigation (1987) Supp SCC 487, at [16].
[75] Rural Litigation and Entitlement Kendra v State of Uttar Pradesh (1985) 2 SCC 431, at [21].
[76] ibid.
[77] Rosencranz and Divan, Environmental Law and Policy in India (2nd edn, OUP 2001) 160.
[78] Ambica Quarry Works v State of Gujarat (1987) 1 SCC 213, at [10].
[79] Ibid, at 11.
[80] ibid.
[81] State of Tamil Nadu v Hind Stone (1981) 2 SCC 205, at [9].
[82] Rural Litigation (1987) Supp SCC 487, at [18].
[83] ibid.
[84] ibid.
[85] Ambica Quarry Works (1987) 1 SCC 213, at [12].
[86] State of Bihar v Banshi Ram Modi (1985) 3 SCC 643, at [6].
[87] ibid.
[88] Hind Stone (1981) 2 SCC 205, at [12].
[89] Rural Litigation (1987) Supp SCC 487, at [19].
[90] Rosencranz and Divan (n 3) 162.
[91] Rural Litigation and Entitlement Kendra v State of Uttar Pradesh (1985) 2 SCC 431, at [5].
[92] Mines Act 1952; Indian Forest Act 1927.
[93] Rosencranz and Divan, Environmental Law and Policy in India (2nd edn, OUP 2001) 158.
[94] State of Bihar v Banshi Ram Modi (1985) 3 SCC 643, at [6].
[95] Ibid.
[96] Mines Act 1952, s 23; Forest (Conservation) Act 1980, s 2.
[97] Rural Litigation (1987) Supp SCC 487, at [10].
[98] Ibid.
[99] Rural Litigation and Entitlement Kendra v State of Uttar Pradesh (1985) 2 SCC 431, at [6].
[100] State of Bihar v Banshi Ram Modi (1985) 3 SCC 643, at [9].
[101] Shyam Divan and Armin Rosencranz, Environmental Law and Policy in India (2nd edn, OUP 2001) 162.
[102] Rural Litigation and Entitlement Kendra v State of Uttar Pradesh (1987) Supp SCC 487, at [12].
[103] Rural Litigation and Entitlement Kendra v State of Uttar Pradesh (1985) 2 SCC 431, at [7].
[104] Constitution of India, art 32; art 21.
[105] Rural Litigation and Entitlement Kendra v State of Uttar Pradesh (1987) Supp SCC 487, at [15].
[106] Rural Litigation and Entitlement Kendra v State of Uttar Pradesh (1985) 2 SCC 431, at [9].
[107] D N Bhargava Committee Report (1983) cited in Rural Litigation and Entitlement Kendra v State of Uttar Pradesh (1987) Supp SCC 487, at [18].
[108] Rural Litigation and Entitlement Kendra v State of Uttar Pradesh (1987) Supp SCC 487, at [20].
[109] Rural Litigation and Entitlement Kendra v State of Uttar Pradesh (1987) Supp SCC 487, at [22].
[110] ibid , at 23.
[111] Ibid, at 24.
[112] Ibid, at 25.
[113] Ibid, at 26.
[114] Rural Litigation and Entitlement Kendra v State of Uttar Pradesh (1987) Supp SCC 487, at [28].
[115] P Leelakrishnan, Environmental Law in India (5th edn, LexisNexis 2019) 231.
[116] Shyam Divan and Armin Rosencranz, Environmental Law and Policy in India (2nd edn, OUP 2001) 165.
[117] Constitution of India, art 21.
[118] Rural Litigation and Entitlement Kendra v State of Uttar Pradesh (1987) Supp SCC 487, at [30].
[119] Ibid, at 31.
[120] Ibid, at 32.
[121] Subhash Kumar v State of Bihar (1991) 1 SCC 598; Vellore Citizens’ Welfare Forum v Union of India (1996) 5 SCC 647.
[122] Shyam Divan and Armin Rosencranz, Environmental Law and Policy in India (2nd edn, OUP 2001) 167.
[123] Constitution of India, art 21; Rural Litigation and Entitlement Kendra v State of Uttar Pradesh (1987) Supp SCC 487, at [30].
[124] D N Bhargava Committee Report (1983), cited in Rural Litigation and Entitlement Kendra v State of Uttar Pradesh (1987) Supp SCC 487, at [18].
[125] Rural Litigation and Entitlement Kendra v State of Uttar Pradesh (1985) 2 SCC 431, at [11].
[126] Ibid, at 25.
[127] Shyam Divan and Armin Rosencranz, Environmental Law and Policy in India (2nd edn, OUP 2001) 169.
[128] Vellore Citizens’ Welfare Forum v Union of India (1996) 5 SCC 647, at [10]; P Leelakrishnan, Environmental Law in India (5th edn, LexisNexis 2019) 234.
[129] Subhash Kumar v State of Bihar (1991) 1 SCC 598, at [7].
