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RECENT JUDGEMENTS OF NGT w.r.t PROTECTION OF

ENVIRONMENT

A Project Submitted to

ARMY INSTITUTE OF LAW

In partial fulfilment of the requirements for the award of

Degree BA.LLB.

SUBMITTED TO: SUBMITTED BY:

Dr. Puja Jaiswal Kashish Kochar

(Environment Law-1) (2101)

PUNJABI UNIVERSITY PATIALA (PUNJAB)

2023-24
 Page |2

DECLARATION

I hereby declare that all the work embodied in this project entitled “Recent Judgements of
NGT w.r.t. Environment Protection” is the fruitful result of my own research from various
sources. All the material referred to has been gathered from secondary sources such as books
and websites. They have been duly acknowledged.

Date: 20 September 2023 Name: Kashish Kochar

Place: Army Institute of Law, Mohali Roll No. : 2101

 Page |3

ACKNOWLEDGEMENT

I am overwhelmed in all humbleness and gratefulness to acknowledge my depth to all those

who have helped me to put all these ideas, well above the level of simplicity and into
something concrete. I would like to express my special thanks of gratitude to my teacher Dr.
Puja Jaiswal who gave me this golden opportunity to execute this project. Their
approachable nature has made learning more effective and effortless. Without their expertise
and extraordinary method of instruction, the project would lack in quality.

I would like to convey my heartfelt thanks to my parents for their constant guidance and
support. Best wishes are in order to all my batch mates who have been cooperative, patient
and have stood by me as pillars of strength at all times. Special mention to my seniors for
being my guiding light at all times and for being very proactive whenever I‟ve approached
them for assistance.

My deepest gratitude would also go out to my Principal, Dr. Tejinder Kaur and Army
Institute of Law, Mohali, for giving me the privileged to being a part of the esteemed AIL
family and for all the learning opportunities in the years to come.
 Page |4

INDEX

1. A Brief Introduction of the National Green Tribunal 1-2

2. Judgements w.r.t Jurisdiction and Powers of NGT 2-3
3. Recent Judgements w.r.t Environment Protection 3-13
4. Conclusion 13
5. Bibliography 13
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 Page |1

I. A BRIEF INTRODUCTION OF THE NATIONAL GREEN

TRIBUNAL

The National Green Tribunal was set up under the aegis of the National Green Tribunal
Act, 2010. The objectives of the Legislature to pass such law are discussed hereunder-

1. For the effective and expeditious disposal of cases relating to environmental

protection and conservation of forests and other natural resources including- the
enforcement of any legal right relating to environment and giving relief and
compensation for damages to persons and property and for matters connected
therewith or incidental thereto.

2. Since India is a party to the decisions taken at the United Nations Conference on the
Human Environment held at Stockholm in June, 1972 - to take appropriate steps for
the protection and improvement of the human environment.

3. To provide effective access to judicial and administrative proceedings, including

redress and remedy and to develop national laws regarding liability and compensation
for the victims of pollution and other environmental damage.

4. The rapid expansion in industrial, infrastructure and transportation sectors and

increasing urbanisation in recent years have given rise to new pressures on our natural
resources and environment. There is a commensurate increase in environment related
litigation pending in various courts and other authorities. The risk to human health
and environment arising out of hazardous activities has also become a matter of
concern.

5. The right to healthy environment has been construed as a part of the right to life under
Article 21 of the Constitution in the judicial pronouncement in India.

6. The National Environment Tribunal Act, 1995 was enacted to provide for strict
liability for damages arising out of any accident occurring while handling any
hazardous substance and for the establishment of a National Environment Tribunal for
effective and expeditious disposal of cases arising from such accident, with a view to
giving relief and compensation for damages to persons, property and the environment.
However, the National Environment Tribunal, which had a very limited mandate, was
not established.
 Page |2

7. The National Environment Appellate Authority Act, 1997 was enacted to establish the
National Environment Appellate Authority to hear appeals with respect to restriction
of areas in which any industries, operations or processes or class of industries,
operations or processes shall not be carried out or shall be carried out subject to
certain safeguards under the Environment (Protection) Act, 1986. The National
Environment Appellate Authority has a limited workload because of the narrow scope
of its jurisdiction.

8. In MC Mehta v. UOI & Ors.1, the then CJI, Justice PN Bhagwati suggested setting up
of Environment Courts since due to more cases involving issues of environment
pollution , ecological destruction and conflict over natural resources. He also laid
importance upon the increasing need and assessment of evolution of scientific and
technical data regarding environmental matters.

9. Taking into account the large number of environmental cases pending in higher courts
and the involvement of multidisciplinary issues in such cases, the Supreme Court
requested the Law Commission of India to consider the need for constitution of
specialised environmental courts. Pursuant to the same, the Law Commission, in its
186rd Report, 2003 recommended the setting up of environmental courts having both
original and appellate jurisdiction relating to environmental laws.

10. Accordingly, it was decided to enact a law to provide for the establishment of the
National Green Tribunal for effective and expeditious disposal of civil cases relating
to environmental protection and conservation of forests and other natural resources
including enforcement of any legal right relating to environment.

II. JUDGEMENTS W.R.T JURISDICTION AND POWER OF NGT

1. NHAI v. Aam Aadmi Lokmanch2

a) Facts

 EIA notice vide 14-09-2006 held requirement of Environmental Clearance even

for minor minerals if the lease area was more than 5 hectares. But R (leaseholder)
did illegal mining without obtaining such EC. Due to piling of debris from

1
M.C. Mehta v. Union of India, (1986) 2 SCC 325
2
NHAI v. Aam Aadmi Lokmanch, (2021) 11 SCC 566
 Page |3

unauthorised mining which blocked the natural flow of water and due to heavy
rains, a local flood was caused in the nearby highway, causing death of 2 persons.

b) Judgement

 Proceedings before NGT for payment of-

 compensation to victims of pollution/other environmental

damage/violation of environmental laws caused by/attributable to private
person(s) and/or public authorities;

 charges for restitution of environment;

 Issuance of directions for preventive and restorative measures in the

interest of environment and ecology, held, maintainable.

 NGT, held, has wide jurisdiction in matters of environment and ecology.

2. Tata Power Delhi Distribution Ltd. v. Manoj Misra3

a) Facts-

 Where the NGT imposed “sewerage charges” due to encroachment and dumping of
building debris in riverbed and natural water body of River Yamuna in Delhi, its
validity was challenged and subsequently upheld by the Hon‟ble Apex Court.

III. RECENT JUDGEMENTS w.r.t ENVIRONMENT PROTECTION

1. Almitra H. Patel & Anr. v. UOI & Ors.4

a) Facts-

 In this matter, Mrs. Almitra Patel and others had filed a PIL under Article 32 of the
Constitution of India earlier wherein the Petitioner sought the instant and pressing
development concerning the practices which are currently followed for the manner
Municipal Solid Waste is handled in India.

 The Tribunal discovered that the importance of the dispute became huge due to the
fact over a lakh of tonnes of waste is dumped each day and there may be no right

3
Tata Power Delhi Distribution Ltd. v. Manoj Misra, (2019) 10 SCC 104
4
Almitra H. Patel v. Union of India, 2014 SCC OnLine NGT 6146
 Page |4

remedy of this waste that is dumped simply out of doors the town limits on land,
alongside highway, lakes, nalas, etc.

 The whole society generated over 1,33,760 MT of waste each day as of 2012-2013
and this has been growing with time.

b) Judgement

 The Tribunal cited the requirement of conversion of this waste into a supply of
electricity and gasoline for use for society‟s benefit, deliberating the Principles of
Circular Economy.

 The Tribunal directed each state and UT to put in force the Solid Waste Management
Rules, 2016, and put together the plan in motion in phases within four weeks.

 Further, the Tribunal directed the Central Government, state governments, local
bodies, and all residents to carry out their respective duties in compliance with the
Rules with no delay.

 Absolute segregation was made obligatory in waste.

 The Tribunal ordered a prohibition on open burning of waste on lands, which includes
at landfills.

2. Samir Mehta v. UOI & Ors.5

a) Facts-

 On 12.08.2011 a ship (M.V. Rak Carrier) carrying over 60,054 metric plenty of coal
and also containing 290 tonnes of fuel and 50 tonnes of diesel sank approximately 20
nautical miles from the coast of South Mumbai because of water ingression in ballast
tanks, which went on because of technical faults.

 Delta Group International shipped the coal for Adani Enterprises Limited. The marine
oil spill over the ocean has caused environmental damage to aquatic life and thus
caused marine pollution. Adani enterprises had taken no action to manage the
pollution caused by spillage whatsoever.

5
Samir Mehta v. Union of India, 2013 SCC OnLine NGT 1370
 Page |5

 So, the Indian Coastguard stepped in and made measures to regulate the damage
caused and as a result, a significant amount of costs was incurred by the Indian
Government. Samir Mehta, an environmentalist, filed the petition before the NGT.

 Samir Mehta questioned the importance of environmental jurisprudence, in relevance

to the pollution caused by the sinking of the ship and oil spillage in the body of water,
contiguous zone and therefore the Exclusive Economic Zone of the country and
consequences and liabilities arising therefrom. The petitioner filed it under sections 14
and 15 of the National Green Tribunal Act, 2010.

b) Issues Raised-

 Whether the NGT has jurisdiction to do this case, because the incident befell around
20 nautical miles from the coast of Mumbai, which is past the territorial waters of
India that extends simplest as much as 12 nautical miles.

 Whether the Tribunal has the power to grant repayment in lieu of lawful workout
undertaken through the Government of India (Indian Coast Guard).

 On whom the legal responsibility has to be fixed?

 Whether sinking amounted to dumping.

c) Judgement-

 The Tribunal held that it has jurisdiction to entertain the case because India‟s
sovereignty over the herbal sources extends to the contiguous area and different
financial areas beneath the Maritime Zones Act, 1976.

 Under this Act, the Central Government has different jurisdictions to maintain and
defend maritime surroundings inside the stated zones and to gain this purpose, the
tribunal has jurisdiction to address subjects referring to maritime pollutants in
different financial zones.

 The Tribunal has also held that it has the energy to supply reimbursement for the
charges incurred through the Central Government to smooth the wrecks which can
 Page |6

also additionally pose dangers to navigation and marine surroundings. Even diverse
worldwide conventions offer provisions to that effect.

 So, the respondents (Delta Group International) were held susceptible to pay
environmental reimbursement/damages to the track of Rs. 100 Crores to the Ministry
of Shipping, Government of India under Sections 15 & 17 studied with Sections 14 &
20 of the 2010 Act, for inflicting marine pollutants.

 The Tribunal, regarding the legal responsibility of Adani companies, held that in
keeping with Section 71 of the Merchant Shipping Act, 1958, their beneficial
involvement makes them susceptible to pay pecuniary damages. Hence, Adani
companies are susceptible to pay damages as much as a track of five crore rupees to
the Ministry of Shipping.

 The Court thereby reaffirmed the “Precautionary Principle” and “Polluter Pays
Principle” and additionally identified the Right to smooth surroundings as an essential
thing under Article 21 of the Constitution of India which ensures the safety of
existence and private liberty.

3. Save Mon Region Federation & Anr. v. Union of India & Ors.6

a) Facts-

 In this case, an appeal was filed through an organization named Save Mon Region
Federation in conjunction with a social activist in opposition to the grant of
Environmental Clearance given to an INR 6,400 crore hydro venture.

 The stated task was located near the wintering site for a bird named Black-necked
Crane, which is a Schedule one species under the Wildlife Protection Act, 1972 and
comes under in the „Threatened Birds of India‟ literature produced via way of means
of the Appellants. Apart from the birds, the vicinity turned into domestic to numerous
different endangered species inclusive of the snow leopard, red panda, Arunachal
macaque, etc.

6
Save Mon Region Federation v. Union of India, 2013 SCC OnLine NGT 2507
 Page |7

b) Judgement-

 The Tribunal proactively suspended the Environmental Clearance granted to the

Project.

 The Tribunal directed the Expert Appraisal Committee to make a fresh appraisal of
the thought for environmental clearance furnish and requested the Ministry of
Environment and Forest to make a separate take a look at the safety of the stated bird.

4. Srinagar Bandh Aapda Sangharsh Samiti v. Alaknanda Hydropower Co. Ltd7

a) Facts-

 The petitioners filed a petition mentioning numerous problems looking for

instructions to the primary respondent, Alaknanda Hydro Power Co. Ltd. to
compensate with INR 9,26,42,795 towards the harm suffered. The 2013 Uttarakhand
floods which brought on mass destruction of lifestyles and belongings is the backdrop
of this case.

 The case of the Applicants was that the primary Respondent had dumped a massive
amount of „muck‟ generated due to the Srinagar Hydro Electric Project without taking
the prescribed measures to stable such a great deal from the floods.

 Due to heavy rains, while the reservoirs of the Project were filled, the opening of the
dam caused the muck to escape and caused inconvenience to the villages ensuing in a
massive loss to the lifestyles and belongings of the Samiti.

 The Tribunal needed to determine whether or not Respondent No. 1 was liable to pay
the claimed compensation.

b) Judgement-

 The Tribunal reached the realization that harm to the assets as alleged through the
petitioners incurred due to flood water, which delivered alongside soil and muck,
coming into residential premises.

7
Srinagar Bandh Aapda Sangharsh Samiti v. Alaknanda Hydropower Co. Ltd., 2014 SCC OnLine NGT 1180
 Page |8

 The Tribunal mentioned that although the 2013 Uttarakhand floods had been the
result of a cloud burst, the harm inflicted on the residential location was no longer the
result of Act of God.

 The muck was approximately 30 percent, which undeniably was the footprint of
Respondent No.1‟s involvement in the harm. And even supposing it turned into an
Act of God, the Tribunal noticed the invocation of the „No Fault Liability‟ below
Section 17(3) of the National Green Tribunal Act, 2010 justified, which precept made
the Respondent No. 1 prone to pay the claimed repayment at the side of Rs. 1 lakh per
petitioner.

5. Anand Arya v. Art of Living Foundation8

a) Facts-

 Founded in 1981 by Shri Shri Ravi Shankar, The Art of Living Foundation is a Non-
Governmental Organization running on humanitarian and academic matters.

 In March 2016, this organization staged a three-day cultural occasion – the World
Cultural Festival from the eleventh to thirteenth March, on the Yamuna floodplains in
New Delhi.

 The Yamuna banks are taken into consideration to be ecologically very fragile
however the preparations for the festival have been stupendous. A seven-acre stage
was set up which was the most important part, and able to accommodate 35,000
musicians and dancers. According to the organizers, the occasion became attended by
35 lakh humans and over 20,000 global guests.

 A petition was filed on eighth February 2016 before the National Green Tribunal,
Principal Bench, New Delhi, being Original Application (OA) through Sri Manoj
Mishra, a retired officer of the Indian Forest Service against the Delhi Development
Authority (DDA).

8
Anand Arya v. Art of Living Foundation, 2016 SCC OnLine NGT 1813
 Page |9

b) Issues-

 Whether the Yamuna floodplains and wetlands had been and are being destroyed
ecologically, environmentally, and biologically through the Art of Living Foundation.

 In the occasion of such damaging environmental effect and consequence, if any,

whether or not the organizers are at risk of pay any repayment or excellent for such
harm and repair the venue to its pre-existing condition.

c) Judgement-

 The high-powered panel had stated that the floodplains had lost „almost all its
natural vegetation‟ like trees, shrubs, tall grasses, aquatic vegetation, including
water hyacinth that provides habitat to a large number of animals, insects and mud -
dwelling organisms because of the three-day event.

 The green forum also chastised the DDA for allowing the event on the floodplains.
“The DDA has failed to perform its statutory functions of maintaining the
ecology. It shall assess the quantum of damage and carry out the restoration
work.” the bench said.
 While the Tribunal asked to pay a fine of Rs. 5 crore, it further said that the cost of
restoration is expected to be much higher if the assessment of a committee
constituted to probe the matter is anything to go by. An expert committee, headed
by water resources secretary Shashi Shekhar had stated in April that it could cost as
much as Rs 13.29 crore to restore the floodplains. It had also observed that the
exercise could take up to ten years.

11. In Karuna Society for Animals & Nature v. Union of India9, in accordance with the
Hon‟ble Apex Court‟s judgement, the NGT issued directions regarding
implementation of prohibition of use, sale and disposal of plastic bags in all
Municipalities and Municipal Corporations, in the country, in a time bound manner.

12. In Lawrence Basaiawmoit v. All Dimasa Students Union10, unregulated and

unscientific rat hole mining in State of Meghalaya resulting in water logging and

9
Karuna Society for Animals & Nature v. Union of India, (2016) 14 SCC 303
10
Lawrence Basaiawmoit v. All Dimasa Students Union, (2015) 14 SCC 416
 P a g e | 10

death of workers, considering report of expert and fact situation, National Green
Tribunal banned mining activity in interest of maintaining ecological balance and
safety of employees. It was also noticed that due to such mining Government and
public were not getting any benefits. When such order challenged in appeal before the
Hon‟ble Apex Court, it held, “Order passed by Tribunal being interim in nature,
does not call for any interference. If there is any grievance with order of Tribunal,
then it may be approached for variation or modification or recall before the
Hon’ble Supreme Court.”

13. In Tribunal on its own Motion v. Ministry of Environment, Forest, & Climate
Change & Ors. (2020) (OA 249/20), having regard to increased adverse health impact
of pollution by use of crackers on Covid-19, aggravating risk to lives and health
which led to ban by the Governments of Odisha, Rajasthan, Sikkim, UT Chandigarh,
DPCC and by the Calcutta High Court on sale and use of crackers, applying the
„Sustainable Development‟ and „Precautionary‟ principles, the NGT issued directions
for banning sale and use of fire crackers during November 9 to 30 in areas where air
quality is „poor‟, „very poor‟ and „severe‟.

14. Gas Leak at LG Polymers Chemical Plant, In re11, this matter was taken up suo-
motu on the basis of media reports to the effect that leakage of hazardous gas, Styrene,
took place at 03:45AM on 07.05.2020, from a chemical factory owned by the South
Korean company LG Polymers India Pvt., Limited, R.R. Venkatpuram village,
Pendurthy Mandal, Vishakhapatnam resulting in death of 11 persons and
hospitalization of more than 100 people of whom at least 25 were reported to be
serious. These fatalities and injuries were reportedly likely to increase. More than
1000 persons were reported sick. There was also damage to environment and habitat.
Having regard to the prima facie material regarding the extent of damage to life,
public health and environment, the NGT directed LG Polymers India Pvt., Limited to
forthwith deposit an initial amount of Rs. 50 Crore, with the District Magistrate,
Vishakhapatnam. The amount was fixed having regard to the financial worth of the
company and the extent of the damage caused.

11
Gas Leak at LG Polymers Chemical Plant, In re, 2020 SCC OnLine NGT 128
 P a g e | 11

15. In OA 178/2023, the NGT took suo moto cognisance of a news item published in The
Hindu dated 06.03.2023 titled “Kochi chokes as fire at waste dump still rages;
govt. asks people to stay indoors.” The court held, “It is self- evident that good
governance in the matter of waste management is being neglected for long time to the
detriment of environment and public health and no one has taken moral responsibility
for such gross failure of rule of law and damage to public health. It is difficult to
understand what is the value of citizen‟s right to life and safety with such attitude of
total neglect by authorities in Government? This calls for soul searching and also high
level enquiry to determine culpability in larger public interest. Thus, the Principal
Bench fined the Kochi Corporation to the tune of Rs. 100 crore.

16. In Salman Qasmi v. State of Rajasthan (OA 558/2022) and Agnimitra Trivedi v.
State of Rajasthan (OA 268/2022), these two applications involved common issue of
violation of environmental norms by industries engaged in textile printing business in
District Jaipur, Rajasthan, adversely affecting the water quality of Dravyavati River
and quality of vegetables and other crops grown on nearby farms. There were total
835 textile units, 775 units on agricultural land and 60 on commercial plots land.
Thus, untreated effluents were going into the river in violation of law and no action
was taken against rampant violations.
The Tribunal noted with dismay that the state of affairs to be utterly unsatisfactory.
“It appears that there is no environmental rule of law in the area. This calls for
emergent action in a mission mode at higher level to remedy the situation and to fix
accountability for such failure of the administration in collusion with law violators.
The erring industries operating without consents or in violation of consent
conditions need to be stopped and made accountable for past violations on
“Polluter Pays” principle or otherwise with reference to the expected cost of
remediation and financial capacity of the units, as per law.” As a result, the State of
Rajasthan was fined to the tune of Rs. 100 crore as compensation.

17. In OA 448/2022, the NGT took suo moto cognisance of a news item published in
Hindustan Times dated 03.06.2022 titled “178 women workers fall ill after gas leak
in Andhra’s Visakhapatnam.” The Tribunal found that there is overwhelming
preponderance of probabilities to hold that Brandix, where the two incidents have
 P a g e | 12

taken place, is responsible for the incidents of gas leak affecting large number of
persons. If on account of hazardous commercial activity of any enterprise any person
is affected, principle of absolute liability is attracted in view of M.C Mehta & Anr v.
Union of India, (1987) 1 SCC 395. It is not necessary to prove negligence.
Results of sample taken from the unit establish presence of several chemicals like
acetonitrile, dichoromethane, ethyl acetate, nhexane, toluene, chloromethane,
cyclopropane, acetaldehyde, furan, acetone, 2-methyl propanal, n-butanol, 2-methyl
furan, 2-butanone, benzene, 2, 3 butanedione, 2-methyl butanol, Chlorphyrifos. There
is nothing to rebut natural inference of nexus of Brandix with the toxic gas which
affected large number of victims.
Accordingly, the NGT held that 539 workers identified in the report as having been
admitted to hospital by gas leak were entitled to compensation @ Rs.1 lac each.

18. Devanshu Bose v. Agra Development Authority12 (OA 329/2021) (Decided 2023)-
Grievance in this application was against failure of the State authorities to prevent
discharge of sewage on open land from „Nalanda Town‟, a housing colony developed
by a builder at Shamshabad Road area of Agra, Uttar Pradesh. Sewage was estimated
to be 1.45 Lakh Litres per day. Agra Development Authority (ADA) was primarily
responsible for such failure. In light of report of the joint Committee dated
22.02.2022, the NGT acknowledged that sewage was not being treated and was being
discharged on land. There was no sewer line. The Tribunal held that Agra
Development Authority (ADA) had failed to perform its statutory obligation to
protect environment and public health and directed ADA to deposit interim
compensation of Rs. 25 Lakhs with District Magistrate, Agra for restoration of
damage to the environment, as per „polluter pays‟ principle.

19. In Sandeep Kharb v. Ministry of Environment, Forest & Climate Change13, the
question for consideration was remedial action against illegal mechanical sand mining on the
river bed of River Yamuna and construction of a temporary bridge with hume pipes at
Shamli, Uttar Pradesh. The Tribunal opined, “We are surprised that even after finding
illegal mining the leasee has been allowed to continue without any coercive measure
and even without recovering the assessed compensation which is against the rule of

12
Devanshu Bose v. Agra Development Authority, 2022 SCC OnLine NGT 2266
13
Sandeep Kharb v. Ministry of Environment, Forest & Climate Change, 2021 SCC OnLine NGT 137
 P a g e | 13

law and arbitrary. Collusion of authorities allowing such action is not ruled out which
needs to be looked into by concerned higher authority.” The leasse was fined to the
tune of Rs. 66, 58,953 keeping in mid the illegally mined material and the restoration
of environment.

20. Arvind Kumar v. Central Pollution Control Board14, grievance in this application
was against unscientific dumping of waste at main road of village Changipur, District
Bijnor by the Municipal Council, Noorpur. The waste included carcasses which
resulted in foul and obnoxious smell and also air and land pollution. In spite of
representations made to the Municipal Council, no remedial action was taken.
In view of the above the NGT directed District Magistrate, Bijnor in coordination
with Municipal Council, Noorpur and any other concerned authority to ensure
effective steps for scientific management of the waste, ensuring that no foul smell and
air or land pollution took place. The Tribunal further opined, “It is made clear that if
no satisfactory action is taken in terms of these directions, the Tribunal may be left
with no other options except to take coercive measures under the provisions of
the National Green Tribunal Act, 2010 which can include civil imprisonment and cut
in or attachment of salary of the concerned heads of the departments.

IV. CONCLUSION
It is our collective and individual responsibility, to tend to the world in which we all live
in. These ethics have time and again been reiterated by various pronouncements of the
National Green Tribunal.

V. BIBLIOGRAPHY

1. 10 Years of National Green Tribunal, available at: https://www.drishtiias.com/daily-

news-editorials/10-years-of-national-green-tribunal, (last visited on August 26, 2023).

14
Arvind Kumar v. Central Pollution Control Board, 2021 SCC OnLine NGT 155
 P a g e | 14

2. Landmark Judgements by National Green Tribunal, available at:

https://www.lawinsider.in/columns/landmark-judgements-by-national-green-tribunal,
(last visited on August 25, 2023).

3. Bird‟s Eye View of NGT‟s Performance over the Past 5 Years (July, 2018- July
2023), available at:
https://greentribunal.gov.in/sites/default/files/important_orders/NGT_Initiatives%20fi
nal-1.pdf, (last visited August 26, 2023).

4. Landmark Verdicts of NGT up to 2020, available at:

https://www.indiascienceandtechnology.gov.in/sites/all/themes/vigyan/images/sti_hig
hlights/NGT-Green%20VERDICTs-2020_PU-PGI_Booklet.pdf, (last accessed
August 26, 2023).

5. SCC Online, available at: https://www.scconline.com/Members/SearchResult.aspx,

(last accessed August 26, 2023).