I-

Plant should be closed down

The counsel for the petitioners humbly submit that DML plant should be closed
down as the said plant is leading to serious irreversible damage to the environment
and it cant be allowed to function in the name of development and livelihood of the
workers.
I.1. Damage to mangrove forests

In the present case, Rhodo had extensive foliage of Mangrove Forests among which vast patches
of mangrove forests withered away and died. It is averred by the report of PCB that it was due to
this heavy discharge of pollutants in the river from the DML plant. Species of mangrove found in
South Asia has been classified as one of the most endangered species of mangrove by IUCN. 1
Mangrove forests are of great ecological importance and are also ecologically sensitive 2 since,
they remove pollutants and also act as a barrier of floods, provides nesting places for fishes 3 It is
the ultimate source of life and livelihood and its extinction can lead to severe consequences.
I.2. Irreversible damage to reverie dolphins
I.3. Violation of fundamental rights of Natives
I.3.A. By Air Pollution
I.3.B. By Water Pollution
I.4. Threat to the health of workers
I.5. Public interest should be given greater importance than interest of workers

http://www.iucn.org/news_homepage/?5025/Mangrove-forests-in-worldwide-decline

Krishnadevi Malchand Kamathia v. Bombay Environmental Action Group, [2011] 3 S.C.R.

291.
3
S. Jagannath v. Union of India and Others, W.P. (C) No. 561 of 1994.