Our Indian Constitution guarantees Right to life and liberty under Article 21, which says

that “No person shall be deprived of his life or personal liberty except according to
a procedure established by law.” Here, putting emphasis on “Life” part of the Article, will see
that how it has broad contours to substantiate this right. Life is not construed in Article
21 of the Constitution merely the physical act of breathing. It does not connote mere
animal existence. It has a much wider meaning which includes right to live with human
dignity, right to livelihood, right to health, right to pollution free air, etc. Right to life is
fundamental to our very existence without which we cannot live as human being and
includes all those aspects of life, which go to make a man’s life meaningful, complete,
and worth living. It is the only article in the Constitution that has received the widest
possible interpretation. Hence, our life sustains itself through the outside factors also
along with biological mass.

The Healthy Environment is the comprehensive term encompassing all such natural and
biotic factors that make possible to entertain Right to life in true spirit. The environment
furnishes all essentials for life and so there has been a close link between the
environment and human beings. Without a natural and congenial environment, human
existence is not possible on earth. Since time immemorial, the man had made conscious
and determined efforts to make use of the natural resources and to modify his
surroundings so that the adverse impact caused by extremes of temperature rainfall and
predators may be reduced. In the quest of making life more comfortable the man has
always exploited the nature. Agriculture, industrialization and infrastructural
developments are the causes of exploitation of natural resources. Human activities
create a variety of wastes and bye-products which accumulate over a period of time and
may become toxic to the naturally growing plants, animal and the mankind.
Indiscriminate use of fertilizers and pesticides has added to the problem. The rapid and
unplanned industrialization has given birth to factories emitting noxious gas fumes and
toxic effluents, making life more difficult on earth. These things are constantly causing
damage to environment. It is also the duty of the state to protect the environment as
embodied under article 48-A, 39 (e) and 47 of the Indian Constitution. So in order to deal
with these ever-growing problems, many acts have also been enacted by the parliament
but it is a court which always keeps a check on proper implementation of these
enactments and judiciary had played an important role in interpreting the laws to protect
the environment.

It has been recognized to be inseparable part of Right to Life under Article 21 and well
established if we take into account some other provisions of the constitutions.

At the turn of the present century, when world started to encounter the ill-effects of
industrialization, “Right to live in Healthy Environment” gained importance.
The Indian Judiciary, the custodian of constitution, has been giving beacon light for such
valuable Right while interpretation the constitution in positive manner. Judicial
Chronology is full of landmark decisions, which embarked upon that Right to life far
exceeds mere breathing and walking and developed Environment Jurisprudence.
Judiciary plays the vital role in the protection of environment. One of the main
developments in the Indian Judiciary is the Public Interest Litigation (PIL). It is the new
jurisprudence and is called “Jurisprudence of Masses”. It is started in the year 1970. Writ
petitions in the form of PILs have been accepted by the High Court’s under Article 20,
Article 47, Article 32 is right to constitutional remedies and Article 226 (Power of High
Courts to issue certain writs) of the Indian Constitution. The PILs got constitutional
sanction in the 42nd Constitution Amendment Act 1974, which introduced Article 39-A
in the Indian Constitution to provide equal justice and free legal aid. The PIL encouraged
the affected individuals (affected by any project), public minded individuals, voluntary
organizations, NGOs; Judges on their own, to start without paying any court fees. Due to
PILs, many landmark judgments are published. Many authorities are observing the
works of the Govt., whether court orders of PILs are carrying out or not. PIL of court
indicates a person, authorities or Govt., to work morally. he Supreme Court and the High
Courts have been entertaining environmental petitions under Articles 32 and 226 of the
Indian Constitution as constituting violation of Article 21. While entertaining environ-
mental litigations by environmental NGOs and enlightened public figures like M.C.
Mehta, these courts have passed landmark judgments, thereby forcing public bodies to
take action on burning environmental issues.

Judicial activism in the field of environmental protection has been applauded by people
like M.C. Mehta, Satyaranjan Sathe, Justice Kuldeep Singh and Justice Ashok Desai.
However, it is important to note that judicial activism has serious limitations, and
executive laxity and unconcern towards environment cannot be made good just by
judicial activism. Judicial activism cannot make good laxity in the enforcement of environ-
mental laws. There can be no substitute for a check on the executive by a vigilant public
and a people’s movement to save the environment.

Provisions of Indian Constitution relevant to Environment:

Article 47” Duty of the State to raise the level of nutrition and the standard of living and
to improve public health The State shall regard the raising of the level of nutrition and
the standard of living of its people and the improvement of public health as among its
primary duties and, in particular, the State shall endeavor to bring about prohibition of
the consumption except for medicinal purposes of intoxicating drinks and of drugs which
are injurious to health.
Article 48 A “Protection and improvement of environment and safeguarding of forests
and wild life The State shall endeavour to protect and improve the environment and to
safeguard the forests and wild life of the country.

Article 51A (g) “to protect and improve the natural environment including forests, lakes,
rivers and wild life, and to have compassion for living creatures;

Article 253 “Legislation for giving effect to international agreements Notwithstanding

anything in the foregoing provisions of this Chapter, Parliament has power to make any
law for the whole or any part of the territory of India for implementing any treaty,
agreement or convention with any other country or countries or any decision made at
any international conference, association or other body

Article 246 “ Subject matter of laws made by Parliament and by the Legislatures of
States:(1) Notwithstanding anything in clauses ( 2 ) and ( 3 ), Parliament has exclusive
power to make laws with respect to any of the matters enumerated in List I in the
Seventh Schedule (in this Constitution referred to as the Union List) (2) Notwithstanding
anything in clause ( 3 ), Parliament, and, subject to clause ( 1 ), the Legislature of any State
also, have power to make laws with respect to any of the matters enumerated in List III
in the Seventh Schedule (in this Constitution referred to as the Concurrent List)
(4) Parliament has power to make laws with respect to any matter for any part of the
territory of India not included (in a State) notwithstanding that such matter is a matter
enumerated in the State List

Article 32 “Remedies for enforcement of rights conferred by this Part (1) The right to
move the Supreme Court by appropriate proceedings for the enforcement of the rights
conferred by this Part is guaranteed (2) The Supreme Court shall have power to issue
directions or orders or writs, including writs in the nature of habeas corpus, mandamus,
prohibition, quo warranto and certiorari, whichever may be appropriate, for the
enforcement of any of the rights conferred by this Part (3) Without prejudice to the
powers conferred on the Supreme Court by clause ( 1 ) and ( 2 ), Parliament may by law
empower any other court to exercise within the local limits of its jurisdiction all or any of
the powers exercisable by the Supreme Court under clause ( 2 ). (4) The right guaranteed
by this article shall not be suspended except as otherwise provided for by this
Constitution.

Article 226” Power of High Courts to issue certain writs (1) Notwithstanding anything in
Article 32 every High Court shall have powers, throughout the territories in relation to
which it exercise jurisdiction, to issue to any person or authority, including in appropriate
cases, any Government, within those territories directions, orders or writs, including
writs in the nature of habeas corpus, mandamus, prohibitions, quo-warranto and
certiorari, or any of them, for the enforcement of any of the rights conferred by Part III
and for any other purpose (2) The power conferred by clause ( 1 ) to issue directions,
orders or writs to any Government, authority or person may also be exercised by any
High Court exercising jurisdiction in relation to the territories within which the cause of
action, wholly or in part, arises for the exercise of such power, notwithstanding that the
seat of such Government or authority or the residence of such person is not within those
territories

Important Interpretation of Constitution vis-à-vis Health & Environment by

Judiciary:

1. The Supreme Court of India recognized Water and air is inalienable part of “life”
under Article 21 of the Constitution in the case of Subhash Kumar Vs State of
Bihar. This was almost first step in the direction of constitutional interpretation
for the protection of healthy environment for life.
2. Supreme Court of India in case of Rural Litigation and Entitlement Kendra,
Dehradun Vs State of UP that protection and safeguarding the rights of the people
to live in healthy environment has to be done even it has some economical cost.
3. While explaining the importance of environment and health aspect of life in case
of Vellore Citizens’ case, Judges have formulated the concept of Sustainable
Development for the first time in Environmental Jurisprudence in India.
4. The Supreme Court of India, while incorporating certain features into
fundamental right of Right to life and Liberty through wide interpretation, had
developed some important principles, which were necessary to ensure
atmosphere for Right to live in healthy environment.
5. Polluter Pays Principal– it supports a remedial methodology which is concerned
with repairing natural harm. It’s a rule in international environmental law where
the polluting party pays for the harm or damage done to the natural environment.
It was made part of constitutional ruling in case of Vellore Citizen’s Welfare Forum
v. Union of India.
6. Precautionary Principle-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.
7. Public Trust Doctrine– The Public Trust Doctrine primarily rests on the principle
that certain resources like air, water, sea 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 ownership. It was established in case of M.C. Mehta Vs
Kamalnath & Others
8. Doctrine of Sustainable Development– 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 in Vellore Citizens’ case and RLEK,
Dehradun case.
9. Fundamental right of Water– In Narmada Bachao Andolan v. Union of India and
Ors., the Supreme Court of India upheld that “Water is the basic need for the
survival of human beings and is part of the right to life and human rights as
enshrined in Article 21 of the Constitution of India.
10. Compensation to Victim of Environmental degradation- The power of the
Supreme Court to grant remedial relief for a proved infringement of a
fundamental right (in case if Article21) includes the power to award
compensation. In Delhi gas Leak case “no fault” liability standard (absolute
liability) was introduced for industries engaged in hazardous activities which have
brought about radical changes in the liability and compensation laws in India.
11. In Charan Lal Sahu case, Supreme Court had said that the right to life guaranteed
by Article 21 of the Constitution includes the right to a wholesome environment.
The Court resorted to the Constitutional mandates under Articles 48A and 51A(g)
to support this reasoning and went to the extent of stating that environmental
pollution would be a violation of the fundamental right to life and personal liberty
as enshrined in Article 21 of the Constitution
12. where an enterprise is occupied with an inherently dangerous or a hazardous
activity and harm results to anybody by virtue of a mishap in the operation of such
dangerous or naturally unsafe movement coming about, for instance, in getaway
of poisonous gas, the enterprise is strictly and completely obligated to repay every
one of the individuals who are influenced by the accident and such risk is not
subject to any exemptions. Accordingly, Supreme Court created another trend of
Absolute Liability without any exemption.(Bhopal Gas Tragedy case Judgment)
13. Environmental damage will be considered as Public Nuisance and duty is cast
upon public authorities to help mitigate the effect of nuisance through Public
Interest Litigation as strong medium. (Ratlam Municipal Council v. Vardhichand)
14. As a part of Environment education, Supreme Court in M.C. Mehta case directed
the Union Government was obliged to issue directions to all the State
governments and the union territories to enforce through authorities as a
condition for license on all cinema halls, to obligatory display free of expense no
less than two slides/messages on environment amid each show.

.
Indian Judiciary’s role in development of Environmental Jurisprudence –

Professor Upendra Baxi, who has often supported the judicial activism in India, has also
said that the “Supreme Court of India” has often become “Supreme Court for Indians”.
Many observers of the Indian Supreme Court including Professor Sathe and Baxi have
rightly opined that the Indian Supreme Court is one of the strongest courts of the world.
Power and judicial activism of the Indian courts have resulted into a strong and ever
expanding regime of fundamental rights. Stockholm Conference on Human
Environment, 1972, has generated a strong global international awareness and in India
it facilitated the enactment of the 42nd Constitutional Amendment, 1976. This
amendment has introduced certain environmental duties both on the part of the citizens
[Article 51A (g)] and on the state (Article 48-A).

Under the constitutional scheme the legal status of Article 51(A)-(g) and 48-A is enabling
in nature and not legally binding per se, however, such provisions have often been
interpreted by the Indian courts as legally binding. Moreover, these provisions have been
used by the courts to justify and develop a legally binding fundamental right to
environment as part of right to life under Article 21.[1] Hereinafter, an effort has been
made to demonstrate that how both the ‘soft’ and ‘hard’ international environmental
laws have been used by the Indian courts to develop a strong environmental
jurisprudence in domestic law. The deemed Second Period of Judicial Adoption (1985-
1995) was of growing Influence of International Environmental Law globally as well as
on national level. During this period international environmental law was used to
interpret the character of state obligations with respect to the right to life (Article-21),
which has been interpreted to include the right to a healthy and decent environment.
Before 1996 there were very few references to international environmental treaties
though by 1990 India was party to more than 70 multilateral treaties of environment
significance .In Asbestos Industries Case[2] the Supreme Court extensively quoted many
international laws namely ILO Asbestos Convention, 1986, Universal Declaration of
Human Rights, 1948, and International Convention of Economic, Social and Cultural
Rights, 1966. In this case the court dealt the issues relating to occupational health
hazards of the workers working in asbestos industries. The court held that right to the
health of such workers is a fundamental right under article 21[3] and issued detailed
directions to the authorities.[4] In Calcutta Wetland Case[5] the Calcutta High Court
stated that India being party to the Ramsar Convention on Wetland, 1971, is bound to
promote conservation of wetlands.

Important disposal off Environmental cases by Indian Judiciary-

▪ Sanitation in Ratlam: In a landmark judgment in 1980, the Supreme Court
explicitly recognized the impact of a deteriorating urban environment on the
poor. It linked basic public health facilities to human rights and compelled the
municipality to provide proper sanitation and drainage
▪ Doon valley quarrying: In 1987, the Rural Litigation and Entitlement Kendra, on
the behalf of residents of the Doon valley, filed a case in the Supreme Court
against limestone quarrying. This case was the first requiring the Supreme Court
to balance environmental and ecological integrity against industrial demands on
forest resources. The courts directed the authorities to stop quarrying in the
Mussoorie hills
▪ Gas leak in Shriram factory: In the historic case of the oleum gas leak from the
Shriram Food and Fertilizer factory in Delhi, in 1986, the Supreme Court ordered
the management to pay compensation to the victims of the gas leak. The
“absolute liability” of a hazardous chemical manufacturer to give compensation
to all those affected by an accident was introduced in this case and it was the first
time compensation was paid to victims.
▪ Construction in Silent Valley: In 1980, the Kerala High Court threw out a writ filed
by the Society for the Protection of the Silent Valley seeking a ban on construction
of a hydro-electric project in the valley. However, despite an unfavorable
judgment, active lobbying and grassroots action by environmentalists stopped
the project.
▪ In 1985, activist-advocate M C Mehta filed a writ petition in the Supreme Court to
highlight the pollution of the Ganga by industries and municipalities located on its
banks. In a historic judgment in 1987, the court ordered the closure of a number
of polluting tanneries near Kanpur. Justice E S Venkataramiah, in his judgment,
observed: “Just like an industry which cannot pay minimum wages to its workers
cannot be allowed to exist, a tannery which cannot set up a primary treatment
plant cannot be permitted to continue to be in existence.”
▪ Mining in Sariska: A writ petition was filed in the Supreme Court in 1991 by the
Tarun Bharat Sangh to stop mining in the Sariska wildlife sanctuary. The court
banned mining in the sanctuary
▪ Against vehicular pollution in India the Supreme Court delivered a landmark
judgment in 1992. A retired Judge of the Supreme Court was appointed along with
three members to recommend measures for the nationwide control of vehicular
pollution. Orders for providing Lead free petrol in the country and for the use of
natural gas and other mode of fuels for use in the vehicles in India have been
passed and carried out. Lead-free petrol had been introduced in the four
metropolitan cities from April 1995; all new cars registered from April 1995
onwards have been fitted with catalytic convertors; COG outlets have been set up
to provide CNG as a clean fuel in Delhi and other cities in India apart from Euro 2
 norms. As a result of this case, Delhi has become the first city in the world to have
complete public transportation running on CNG.
▪ In the State of Himachal Pradesh, Span motel, owned by the family members of
Shri Kamal Nath, Minister for Environment and Forests, Govt. of India diverted the
Course of river Beas to beautify the motel and also encroached upon some forest
land. The apex court ordered the management of the Span motel to hand over
forest land to the Govt. of Himachal Pradesh and remove all sorts of
encroachments.
The Court delivered a land mark judgment and established principle of exemplary
damages for the first time in India. The Court said that polluter must pay to
reverse the damage caused by his act and imposed a fine of Rs Ten Lakhs (Rs
10,00,000) on the Span motel as exemplary damages. The Supreme Court of India
recognized Polluter Pays Principle and Public Trust Doctrine.
▪ Despite Coastal Zone Regulation Notification of February 1991, none of the
coastal states had formulated coastal zone management plan, with the result that
haphazard construction and industrial activity was being permitted anywhere in
the coast leading to large scale damage to coastal ecology and loss of livelihood
to lakhs of fishermen and other indigenous communities dependent on marine
resources. A writ petition was filed on behalf of Indian Council for Enviro- Legal
Action (ICELA) and the Supreme Court delivered a landmark Judgement banning
industrial/ construction activity within 500 mtrs of the High Tide Line and set a
time limit for the coastal states to formulate coastal management plans.
▪ Many more such cases could be added from the history of Indian Judiciary who is
most vocal in support of Environment and healthy life than other pillars of Indian
Democracy. They have capitalized the provisions mentioned in the constitution
itself while taking advantage of cardinal principles of International treaties and
conventions.

Reasons for Judicial Activism in protection of Environment:

The year 1972 holds significance for the Environment Jurisprudence as it has changed
the course of action altogether. The Stockholm conference is milestone from where this
country and other developing countries had to look environment from different
perspective. United Nations Conference on the Human Environment, having met at
Stockholm from 5 to 16 June 1972, having considered the need for a common outlook
and for common principles to inspire and guide the peoples of the world in the
preservation and enhancement of the human environment. They have set some
illuminated and cardinal principles to be observed while interacting with nature for man-
made development. At the end of the summit, following principles were adopted-
 1. Human rights must be asserted, apartheid and colonialismcondemned
2. Natural resources must be safeguarded
3. The Earth’s capacity to produce renewable resources must be maintained
4. Wildlife must be safeguarded
5. Non-renewable resources must be shared and not exhausted
6. Pollution must not exceed the environment’s capacity to clean itself
7. Damaging oceanic pollution must be prevented
8. Development is needed to improve the environment
9. Developing countries therefore need assistance
10. Developing countries need reasonable prices for exports to carry out
environmental management
11. Environment policy must not hamper development
12. Developing countries need money to develop environmental safeguards
13. Integrated development planning is needed
14. Rational planning should resolve conflicts between environment and
development
15. Human settlements must be planned to eliminate environmental problems
16. Governments should plan their own appropriate population policies
17. National institutions must plan development of states’ natural resources
18. Science and technology must be used to improve the environment
19. Environmental education is essential
20. Environmental research must be promoted, particularly in developing
countries
21. States may exploit their resources as they wish but must not endanger others
22. Compensation is due to states thus endangered
23. Each nation must establish its own standards
24. There must be cooperation on international issues
25. International organizations should help to improve the environment
26. Weapons of mass destruction must be eliminated.

The Government of India was though signatory at later stage but strong votary of
protection as agreed upon. Post 1972 , The National Governments had pursued the
development path in much vigor and command but less interested in protection of
environment and ecology. Somewhere around 1982, concept of Public Interest Litigation
was gaining importance due to recognition given by Honorable Judge like P.N. Bhagvatiji.
Government had made no comprehensive plan, lay out of industrialization and on the
other hand , vested groups had eye on green lands and cheap natural resources without
taking any ethical and social responsibility against those communities who protected
and maintained such valuable ecological balance. Supreme Court of India came to the
rescue for the plights of those people who either had to migrate to some other places
due to minning or industry or were facing the ill effects of any activity. Before the Pro-
active role of Indian Judiciary, Government had no mechanism to deal with such
situations. No comprehensive law existed prior to 198. Environment Protection Act came
into existence in 1986 after 14 years of Stockholm Conference. Though Water Act, 1974
and Air Act, 1981 were there but they were in sufficient to deal with.

Indian Judiciary, especially, Supreme Court of India had consolidated the environment
Jurisprudence on case to case basis and developed some outstanding principles to be
followed by lower courts while dealing environment cases. They have tried to fill the
vacuum created by legislature and paralyzed by administrative machinery. Indian
Judiciary have got the necessary impetus from Civil Society’s activism in environment
protection, some stalwarts like M.C. Mehta, International Conventions like Earth Summit,
Kyoto Summit, which maintained the focus of such issues among the business of the
Governments.

The interpretation by the Indian Judiciary in favor of marginalized people while counting
protection of environment as investment by the community live by the side of nature
and entrepreneur has to share economic fruits with those communities as ecological
balance contributed the industrial output also. Such strong ethical and legal backing
provided by Indian Judiciary has modeled the whole Environment movement in India and
now they are leading the world. Indian Environment jurisprudence shaped by and large
by the Indian Judiciary within the Indian Constitution is major achievement after
Stockholm conference. Many more things yet to be done and many strictures, comments
and orders have yet to be followed by different governments in this country.

The failure of the state agencies to effectively enforce the environmental laws apart from
non-compliance with statutory norms by the polluters resulted into further degradation
of the environment which has affected the health of the people and forced the
environmentalists and the residents of polluted areas as well as the non-governmental
organizations to approach the judiciary, particularly the higher judiciary, for the suitable
remedies. Of course the initiative for the protection of environment came from the
legislature but the failure of the executive to implement the environmental laws in India
created the ground for the intervention of the judiciary.

The judiciary made several attempt to resolve the conflict between the development and
environment. The environmental jurisprudence in India developed through the
instrument of Public Interest Litigation (PIL). Under the PIL, the judiciary liberalized the
concept of locus standi and thereby empowered the people to approach the judiciary
when the public interest is harmed by either the action of the state, organization or
individual. Unique feature of the Indian environmental jurisprudence is the important
role played by the PIL. The activism of the higher judiciary regarding the cases related
with violation of environment and human rights has acquired the name of judicial
activism. The Supreme Court has not only played a leading role in the implementation
of environmental laws but also interpreted the right to life under Article 21 to include a
right to healthy and pollution free environment, as a fundamental right.

Conclusion:

Government of India as well as State Government have now started to chart out the
plans sector wise, lay out was drafted, guidelines being issued, compliance report is
being submitted to Higher courts regarding steps taken by them to ensure the standard
of environment protection.

After Independence, if anything that was single handedly covered and regulated by
Judiciary is, Environment protection. Judges have taken it very seriously and observations
were not made but compliance was closely watched till it is done in letter and spirit.

Environmental law has seen considerable development in the last two decades in India.
Most of the principles under which environmental law works in India come within this
period. The development of the laws in this area has seen a considerable share of
initiative by the Indian judiciary, particularly the higher judiciary, consisting of the
Supreme Court of India and the High courts of states. PIL has proved to be an effective
tool in the area of environmental protection. The Indian judiciary adopted the technique
of public interest litigation for the cause of environmental protection in many cases. The
basic ideology behind adopting PIL is that access to justice ought not to be denied to the
needy for the lack of knowledge or an finances. In PIL, a public spirited individual or an
organization can maintain petition on behalf of poor and ignorant individuals. Due to
PIL, the court indicated contractors of indiscriminate mining operations which had
disturbed and destroyed ecological balance and ordered for their closure in the interest
of protection of natural environment and conservation of natural resources for public
health. The Supreme court recognized several unarticulated liberties which were implied
in Article 21 of the constitution like the right to free legal assistance and the prisoners to
be treated with dignity were recognized as part of fundamental right. Supreme Court
also interpreted the right and personal liberty to include the right to wholesome
environment. The most important achievement of the Indian constitution is the
constitutionalism of the environmental problems by the apex court. Before the year of
1980, there were legislation about control of environmental pollution but little had been
done to really make pollution control. But in the present time the Supreme Court of India
expand the meaning of environmental Right. The Supreme Court is making
interpretations which led to the creation of new rights. Eventually under Article 21, this
court has created new rights including the right to health and pollution free
environment.

References

1. ROLE OF THE JUDICIARY IN ENVIRONMENTAL PROTECTION Dubey Amit* and

Tiwari B.K. Department of Law, Barkatullah University, Bhopal (INDIA)
2. The Role played by Indian Judiciary in Environment Protection by Supriya Guru
3. The Role of Indian Judiciary in protection of Environment in India by Atisha
Sisodiya, Christ University
4. Contents on Indianenvironmentalportal.org.in
5. Principles of International Environmental Law and Judicial Response in India by
Dr.S.K. Gupta
6. Constitutional Provisions related to Environment Conservation by Binod Prasad
Sharma
7. UN report on United Nations Conference on the Human Environment 1972
Stockholm.
8. Environmental jurisprudence in India: A look at the initiatives of the Supreme
Court of India and their success at meeting the needs of enviro-social justice by
Debadyuti Banerjee
9. Judicial Activism and Environmental Jurisprudence in India: written by Shri Rohan
Bagai
10. Judicial Activism for Environment Protection in India Mahajan Niyati Graduate
School of Social Sciences, Waseda University, Tokyo, JAPAN
11. IMPLICATIONS OF INDIAN SUPREME COURT’S INNOVATIONS FOR
ENVIRONMENTAL JURISPRUDENCE by Geetanjoy Sahu for LEAD Magazine.
12. https://en.wikipedia.org/wiki/United_Nations_Conference_on_the_Human_Enviro
nment

By: Mr. Arvind Kumar Singh,

He is Senior Auditor in CAG office at Mumbai