04 Apr 2025
This update highlights recent developments in Indian environmental law from March 2025, including judgments, legislative measures and regulatory actions.
Partner: Rajat Jariwal, Senior Associate: Gaurav Sharma, Associate: Dev Chand
The month of March 2025 saw significant judicial and regulatory developments in India’s environmental sector. The Supreme Court addressed tree-felling in the Taj Trapezium Zone (TTZ), reinstating the need for prior court permission, and emphasised balancing development with environmental protection in the Auroville Township Project. On the regulatory front, amendments were made to the Environment (Protection) Rules regarding the Caustic Soda industry, the ‘Acacia Catechu’ timber was recognised as a notified species under Maharashtra Forest Rules, thereby regulating its inter-state transit, Stage I of the Graded Response Action Plan (GRAP) was deployed in the National Capital Region (NCR) and subsequently revoked, and the Environment Impact Assessment Notification, 2006 (EIA Notification) was amended to include a standard operating procedure for undertaking linear projects. Additionally, state pollution control boards in Uttarakhand and Kerala revised the categorisation of industrial sectors within their States.
The Supreme Court passed multiple orders concerning tree-felling and industrial expansion activities in the TTZ.
On 25 March 2025,1 the Supreme Court recalled its earlier order dated 11 December 2019, which had removed the requirement to obtain prior permission from the Court to cut trees on non-forest and private lands within the TTZ.2 The 2019 order, issued while deciding an application by the North Central Railway seeking permission to fell trees, allowed such felling within the TTZ area over a distance of 30 kilometres from the proposed railway line, subject to the fulfilment of certain conditions, recognising the importance and need of the proposed railway line. By recalling the 2019 order, the Supreme Court has reinstated the stipulation to obtain the Court’s permission prior to engaging in the felling of trees within the TTZ.
In a separate order dated 18 March 2025, the Court considered an application filed by the TTZ Authority seeking a modification of its previous order prohibiting the establishment or expansion of industries in the TTZ. The Court ruled that no blanket modification could be made as prayed for by the TTZ authority. The Court emphasised that permission for the establishment or expansion of any industry must be contingent on an assessment of whether it would cause pollution.3
These orders showcase increased judicial oversight to ensure strict enforcement of environment protection measures, especially in sensitive areas like the TTZ. In view of the strict scrutiny by the Court, proposals to setup industries in the TTZ must make a strong case in favour of the industry sought to be established and buttress their submissions with extensive environmental impact assessments and approvals.
On 17 March 2025, the Supreme Court overruled the National Green Tribunal’s (NGT) order that had halted the Auroville Township Project in Puducherry due to the absence of environmental clearance.4 The NGT had prohibited the Auroville Foundation from proceeding with the proposed project until such clearance was obtained. However, the Supreme Court held that the project presented no significant environmental concerns and did not violate Schedule I of the National Green Tribunal Act, 2010.
The Supreme Court emphasised the necessity of balancing environmental protection with development. It stated that while the ‘Precautionary Principle’ and the ‘Polluter Pays Principle’ are integral to the Indian environmental law regime, and that the right to a clean environment is a guaranteed fundamental right under Articles 14 and 21 of the Constitution of India, the right to development through industrialisation holds equal significance under Articles 14, 19 and 21. Therefore, the Court advocated for harmonising ‘sustainable development’, and striking a golden balance between the right to development and the right to a clean environment.
On 26 March 2025, the Ministry of Environment, Forest and Climate Change (MoEF&CC) introduced an amendment to Schedules I and VI of the Environment (Protection) Rules, 1986, prescribing additional effluent standards, fugitive emission standards, process emission standards, wastewater generation standards and load-based standards applicable to the Caustic Soda industry. The amendment also does away with the emission standards stipulated for the industry under Item 28 of Schedule I.
By way of this amendment, the MoEF&CC seeks to strengthen the regulation of the Caustic Soda industry, imposing stricter operational stipulations to prevent environmental degradation caused by unchecked effluents.
On 25 March 2025, the Government of Maharashtra notified ‘Acacia Catechu’ timber exceeding twenty-five centimetres in girth at its thickest part as a notified species for the purposes of Rule 37 of the Maharashtra Forest Rules, 2014. The species of timbers or woods notified under this rule must necessarily bear a property mark of the State from which such timbers or woods are moved into the State of Maharashtra by any medium other than by sea.
As a result of ‘Acacia Catechu’ timber being notified, its transit within the state has been subjected to compliance with the above condition.
The Commission for Air Quality Management’s GRAP sub-committee implemented Stage 1 measures under the GRAP, in NCR earlier last month, citing rising Air Quality Index (AQI) levels in Delhi due to adverse weather conditions. Specifically, the AQI had reached 206, categorised as ‘Poor’. However, on 29 March 2025, the sub-committee revoked these measures across the NCR with immediate effect following a significant improvement in the region’s AQI levels.5
On 17 March 2025, the MoEF&CC notified an amendment to Item 6 of Appendix IX of the EIA Notification, making excavation activities relating to linear projects subject to compliance with specific conditions.6 The amendment also introduces Appendix XIV which contains these conditions and also provides a definition for ‘linear projects’.
This revision addresses a previous amendment made on 28 March 2020 which introduced Appendix IX to the EIA Notification, exempting certain activities from the requirement of obtaining an environmental clearance. The extraction, sourcing, or borrowing of ordinary earth for linear projects such as roads, pipelines, etc., was included within the list of exempted activities under Item 6.
The Supreme Court, in Noble Paikada v Union of India and Ors., struck down Item 6 of the Appendix observing that the lack of a proper definition of ‘linear projects’ and a specified process for excavation makes it arbitrary and unguided.
The amendment aims to tackle this concern by providing a precise definition of ‘linear projects’, establishing environmental safeguards for the extraction or sourcing of ordinary earth to facilitate such projects, and stipulating a standard operating procedure that must be adhered to while undertaking such activities.
The Uttarakhand Pollution Control Board has revised the industrial sector categorisation in Uttarakhand, while the Kerala State Pollution Control Board has expanded the industrial categorisation by including certain additional industries.
The revised system in Uttarakhand classifies 125 sectors as Red, 137 as Orange, 94 as Green, 54 as White, and 9 sectors under the newly announced Blue category.7
The revised system in Kerala categorises certain additional industries as under.8
[1] Order dated 25 March 2025, in I.A. Nos. 104091, 104097 of 2018 and 112177 of 2019 in W.P. No. 13881 of 1984, available at Order issued by Supreme Court on 25-Mar-2025.
[2] Order dated 11 December 2019 in I.A. Nos. 567 of 2017 and 184391 of 2018 in W.P. No. 13381 of 1984, available at Order issued by Supreme Court on 11-Dec-2019.
[3] Order dated 18 March 2025, in I.A. No. 22551 of 2025, in W.P. No. 13381 of 1984, available at Order issued by Supreme Court on 18-Mar-2025.
[4] Judgment issued by Supreme Court on 17-Mar-2025.
[5] Press Release from PIB (Govt. of India).
[6] MoEF&CC Office Memorandum (PDF).
[7] Office Order bearing number UKPCB/HO/Gen-256-III-2025-1774 dated 3 March 2025 (UKPCB), available at https://ueppcb.uk.gov.in/upload/contents/File-166.pdf.
[8] Circular bearing number KSPCB/159/2022-SEE-3 dated 7 March 2025 (KSPCB), available at Download: Categorization of Industries Circular – KSPCB.
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