16 Jan 2026
This update highlights key legislative, regulatory, and judicial developments in Indian environmental law from December 2025.
Partner: Rajat Jariwal, Associates: Dev Chand and Anushka Awasthi
The month of December 2025 saw significant legislative, regulatory, and judicial developments shaping environmental governance in India. On the legislative front, the Solid Waste Management Bill, 2025 was introduced in the Rajya Sabha, seeking to establish a statutory framework for segregation, recycling, and disposal of municipal solid waste, while imposing defined obligations on state governments, municipal authorities, and large waste generators.
On the regulatory front, pollution control authorities across jurisdictions issued targeted directions aimed at both environmental protection and ease of doing business. These included directions by the Delhi Pollution Control Committee (DPCC) to curb dust pollution arising from roadside storage and transport of construction materials, the introduction of a framework for third-party inspections by the Pollution Control Committee of Dadra and Nagar Haveli and Daman and Diu, and the notification of revised timelines and procedural reforms by the Andhra Pradesh Pollution Control Board (APPCB) for processing consent applications.
On the judicial front, the Supreme Court delivered a series of consequential rulings reinforcing the importance of environmental conservation. These included, (a) reiterating restrictions on non-forest use of forest lands in Karnataka, (b) accepting expert committee recommendations for the conservation of the Great Indian Bustard (GIB) while balancing sustainable development considerations, and (c) staying its earlier judgment defining the Aravalli Hills and Ranges, pending a comprehensive re-examination by a high-powered committee, while continuing to restrain mining activities in the ecologically sensitive region. The Supreme Court also took cognisance of a matter concerning illegal encroachments of forest lands in Uttarakhand, directing a detailed inquiry into the occupied lands.
These key developments are discussed in detail below.
On 5 December 2025, the Solid Waste Management Bill, 20251 (Bill) was introduced in the Rajya Sabha, with a view to provide for a statutory framework governing segregation and recycling of municipal solid waste, use of recyclable waste in waste-energy plants for the generation of energy and transportation of nonrecyclable waste into landfills. The Bill proposes to be in addition to, and not in derogation of, the prevailing statutory framework governing the handling and management of solid wastes under the Environment (Protection) Act, 1986.
Section 3 of the Bill confers on the appropriate state government a duty to ensure waste segregation by waste-generating units in its jurisdiction and to impose liability on such units to make payments for waste transported to landfills in the prescribed manner. Owners of large manufacturing facilities would be required to ensure segregation, reuse, and recycling of waste at the source, and transport recyclable waste to waste-to-energy plants. Under Section 4, municipal authorities would be required to collect segregated waste, treat organic waste through biodegradation, and transport non-recyclable or non-biodegradable waste to notified landfills.
Section 5 of the Bill provides that a failure to comply with the provisions of this statute upon its commencement would be punishable with imprisonment up to three months, with fines which may extend to INR 20,000.
If passed, the Solid Waste Management Bill, 2025 mandates strict segregation, recycling, and responsible disposal of waste by obligated entities, including waste-generating units and large manufacturing facilities and prescribes considerable penalties for non-compliance.
On 9 December 2025, the Delhi Pollution Control Committee (DPCC) issued directions2 to the Zonal Deputy Commissioners of the Municipal Corporation of Delhi under Section 31A of the Air (Prevention and Control of Pollution) Act, 1974 (Air Act), directing:
The directions have been issued with a view to regulate and control the persistent dust pollution generated from roadside storage, sale and transportation of building and construction materials such as sand, bajri, bricks, cement, tiles, stones by vendors.
In order to facilitate the ease of doing business, the Pollution Control Committee, Dadra and Nagar Haveli and Daman and Diu issued a circular3 on 10 December 2025, directing that all third-party inspections/certifications of industries shall be carried out by consultants and firms recognised by the Ministry of Environment, Forest and Climate Change (MoEF&CC). Such inspection/certification must be undertaken based on the risk profile of industries and subject to approval of the Central Pollution Control Board (CPCB).
On 16 December 2025, the Andhra Pradesh Pollution Control Board (APPCB) issued a circular4 stipulating revised timelines for the processing of online applications seeking the grant of Consents to Establish (CTE) and Consents to Operate (CTO), received through the Online Consent Management and Monitoring System (OCMMS). Regional Officers are required to inspect industries and forward their inspection reports to the zonal office/ head office of the APPCB (as required), in time to enable APPCB to process such applications within the following timelines:
| Category of Industry | Timeline for CTE Applications | Timeline for CTO Applications |
|---|---|---|
| Red | 12 | 15 |
| Orange | 10 | 12 |
| Green | 03 | 05 |
The circular includes the following directions for all Zonal and Regional Officers of the APPCB, for the speedy processing of CTE and CTO applications:
The Circular aims to streamline the compliance process under the Water (Prevention and Control of Pollution) Act, 1974, and the Air Act to facilitate easier establishment and operation of industrial plants in the State.
On 18 December 2025, the Supreme Court passed a judgment5 reaffirming that forest land cannot be diverted for agricultural or other non-forest uses without strict compliance with the Forest (Conservation) Act, 1980. The Supreme Court’s judgment was passed in an appeal by the State of Karnataka against the final judgment and order of the Karnataka High Court. The State government had previously issued orders granting an area located at Benachi and Tumarikoppa village in Dharwad, Karnataka, to the Gandhi Jeevan Collective Farming Cooperative Society Limited (Society), under lease for cultivation for a ten-year period. At the end of the lease period, the State government refused to extend the lease and passed an order on 13 March 1985 terminating the same. The Society was subsequently evicted, as the forest department took possession of the land.
In the current appeal, referring to the Supreme Court’s findings in T. N. Godavarman Thirumulpad v Union of India and Ors.,6 the Court observed that the very grant of the lease to the Society was uncalled for and led to the deforestation of approximately 134 acres of forest area. In view of the general restriction against de-reservation or use of forest lands for non-forest purposes, under the Forest (Conservation) Act, 1980, the Court held that no such permission could have been granted, and that the Society was not entitled to any extension of the lease. The Forest Department, Karnataka, was directed to restore the forest in the affected area by planting indigenous plants and trees in consultation with experts within 12 months.
On 19 December 2025, the Supreme Court accepted the recommendations of the expert committee in a long-standing matter7 concerning the conservation of the Great Indian Bustard (GIB) and the Lesser Florican. The case originally arose from a writ petition filed before the Supreme Court in 2019 to protect the GIB and the Lesser Florican from extinction, citing the existence of overhead power lines in Rajasthan and Gujarat as a hazard to these birds. In its interim order dated 19 April 2021, the court directed the conversion of all overhead cables into underground powerlines within a period of one year, and the installation of bird divertors, pending such installation. Further, restrictions were imposed on the establishment of overhead transmission lines in a territory of 99,000 square kilometres (GIB Areas), while a committee was appointed to assess the feasibility of laying high-voltage underground power lines.
Subsequently, on 21 March 2024, the Court modified its order on the grounds of technical infeasibility and grid safety concerns, appointing an expert committee to adopt a more calibrated approach, which included members of the Ministry of New and Renewable Energy and the Corbett Foundation.
On 19 December 2025, the Court accepted the directions of the expert committee for – (a) rationalisation of the extent of the GIB Areas to a ‘revised Priority Area’ of 14,013 square kilometres in the State of Rajasthan, and 740 square kilometres in Gujarat; (b) provision of dedicated power corridors, where the installation of new powerlines would be permitted; (c) restrictions on the establishment of new wind turbines and solar parks/plants of more than 2 MW capacity in the revised priority areas; and (d) mitigation of existing 33kV and 66kV transmission lines in the revised Priority Areas. The Court further recommended that mitigation measures must be undertaken for the areas outside the revised Priority Areas and recommended that all future lines be routed through power corridors.
The Court also directed the MoEF&CC to (a) ensure expedient undergrounding of 250 kilometres of critical power lines identified by the Wildlife Institute of India (WII) within two years; and (b) to consider the deployment of ‘Bird Flight Divertors’ as an additional mitigation measure in both states, after the WII studies regarding their effectiveness and maintenance are received.
Staying its earlier judgment dated 20 November 2025 (Judgment), the Supreme Court revisited the issue of the definition of the terms ‘Aravali Hills’ and ‘Aravali Ranges’.8 The issue is significant for the conservation of the Aravalis and their ecosystem.
The Supreme Court had previously acknowledged that differences in how the NCT of Delhi, Rajasthan, Haryana and Gujarat define and classify the hills and ranges of Aravalis have weakened the efforts to protect the ecology of the Aravalis.
In the above context, the Court had constituted a committee on 9 May 2024 to provide a uniform definition. Based on the committee’s report dated 3 October 2025 (Report), whereby the Aravalli Hills were defined as ‘any landform located in the Aravali districts, having an elevation of 100 metres or more from the local relief’, the court instituted restrictions on the grant of new mining leases within the newly demarcated ‘Aravali Hills and Ranges’. The findings of the committee were subsequently accepted, along with the definitions in the Judgment, which have since been challenged before the Supreme Court in a number of interlocutory and miscellaneous applications, and petitions.
The Supreme Court, in its recent order dated 29 December 2025, acknowledged that the committee’s report and the Judgment had failed to clarify certain critical issues. Accordingly, keeping the findings of the Report in abeyance, the Court constituted a high-powered committee comprising of domain experts to undertake a comprehensive assessment of the Report, and a holistic analysis of the following questions framed by the Court:
The Supreme Court further reinforced its stay on the grant of any permissions for fresh mining leases or renewals in the Aravali Hills and Ranges, without the prior permission of the Court, until further orders.
The dispute arises from a Special Leave Petition filed before the Supreme Court impugning the systematic grabbing of large expanses of forest land in Uttarakhand by private actors. The said encroachments were made pursuant to the passing of orders directing surrender and reversion of the forest land to the Government from the year 2001.
The Court, in its order9 dated 22 December 2025, strongly criticised the inaction of the state government and its authorities, and enlarged the scope of the proceedings suo motu, while directing the constitution of an ‘Inquiry Committee’ by the Chief Secretary of Uttarakhand and Principal Chief Conservator of Forests, Uttarakhand, for a detailed examination of facts. In the interim, all private individuals in possession of the lands have been restrained from alienating, encumbering the land, or carrying out any constructions thereon.
The Court subsequently took cognisance of the first interim inquiry report filed by the Inquiry Committee on 5 January 2026, which revealed consistent negligence of the executive authorities, bordering on collusion and connivance with the land grabbers. The Court expressed grave concern that every officer entrusted with executive responsibility seemed liable for persistent dereliction of duty. Accordingly, the Court directed that a comprehensive counter affidavit be filed by the state government, furnishing complete particulars of the total extent of the land involved and the number of persons presently in occupation thereof. The matter has been listed for hearing next in February 2026.
The Court’s suo motu action against the illegal encroachments underscores a proactive approach to environmental conservation, reinforcing judicial oversight where systemic executive failure threatens forest conservation.
[1] Bill No. LI of 2025
[2] Circular No. DPCC/Air Pollution/Roadside Vendors/2025/770-72 dated 9 December 2025.
[3] Circular No. PCC/DDD/ORDER-EODB/2025-26/190 dated 10 December 2025.
[4] Circular No. 328/APPCB/RO-ZO/2025 dated 16 December 2025.
[5] The State of Karnataka v Gandhi Jeevan Collective Farming Cooperative Society Limited Civil Appeal No. 3661 Of 2011.
[6] (1997) 2 Scc 267
[7] M.K. Ranjitsinh and Others v Union of India and Others Writ Petition (C.) No. 838 of 2019.
[8] Order dated 29 December 2025, in Suo Motu Writ Petition (Civil) No. 10/2025.
[9] Order dated 22 December 2025, in Special Leave Petition (Crl.) No. 21058 of 2025.
If you require any further information about the material contained in this newsletter, please get in touch with your Trilegal relationship partner or send an email to alerts@trilegal.com. The contents of this newsletter are intended for informational purposes only and are not in the nature of a legal opinion. Readers are encouraged to seek legal counsel prior to acting upon any of the information provided herein.
If you would like to receive content directly in your inbox from our knowledge repository, please complete this subscription form. This service is reserved for clients and eligible contacts.
Under the rules of the Bar Council of India, Trilegal is prohibited from soliciting work or advertising in any form or manner. By accessing this website, www.trilegal.com, you acknowledge that:
We prioritize your privacy. Before proceeding, we encourage you to read our privacy policy, which outlines the below, and terms of use to understand how we handle your data:
For more information, please read our terms of use and our privacy policy.
