#PRINCIPLES OF ENVIRONMENT LAW:

A) Sustainable development
Meaning
The most widely accepted definition of sustainable development was provided in the
Brundtland Report, titled Our Common Future, published in 1987. The report defined
sustainable development as “development that meets the needs of the present without
compromising the ability of future generations to meet their own needs.”
Sustainable development therefore involves careful and responsible use of natural
resources, prevention of environmental damage, and adoption of environmentally
friendly technologies and practices. It promotes a balanced approach where economic
development, environmental protection, and social welfare are integrated into a unified
framework.
Objectives of Sustainable Development
The primary objective of sustainable development is to ensure that economic
development and environmental protection go hand in hand without compromising
each other. It aims to protect the environment from degradation by controlling
pollution, conserving natural resources, and maintaining ecological balance. Another
important objective is to ensure economic growth that is long-term and sustainable
rather than short-term and destructive. Sustainable development also seeks to promote
social equity by ensuring fair distribution of resources and opportunities among all
sections of society. It recognizes that development should benefit everyone, including
weaker and marginalized communities. Additionally, sustainable development aims to
conserve natural resources such as forests, water, minerals, and biodiversity so that
they remain available for future generations. It also emphasizes the need to improve the
quality of life of people by providing clean air, safe drinking water, and a healthy
environment.
Sustainable development is based on three essential components, namely
environmental protection, economic development, and social equity.
Principles of Sustainable Development
Sustainable development is supported by several important legal principles that guide
environmental protection and resource management. One of the most important
principles is the principle of inter-generational equity, which means that the present
generation must use natural resources in a manner that does not deprive future
generations of their rights. This principle recognizes that future generations have equal
rights over natural resources and environmental protection. Another important
principle is intra-generational equity, which emphasizes fairness among people of the
present generation. It ensures that resources are distributed equitably and that no
group is deprived of access to essential environmental resources such as clean air and
water.
Sustainable Development in Indian Constitutional Law
Although the term sustainable development is not explicitly mentioned in the
Constitution of India, it is derived from various constitutional provisions. Article 21 of
the Constitution guarantees the right to life and personal liberty. The Supreme Court has
interpreted this right to include the right to live in a clean and healthy environment. In
Subhash Kumar v. State of Bihar 1991, the Court held that the right to life includes the
right to pollution-free air and water. This interpretation has made environmental
protection a fundamental right.
Article 48A of the Constitution, which is part of the Directive Principles of State Policy,
provides that the State shall endeavor to protect and improve the environment and
safeguard forests and wildlife. Although Directive Principles are not enforceable in
courts, they guide the government in making laws and policies. Article 51A(g), which is
part of the Fundamental Duties, imposes a duty on every citizen to protect and improve
the natural environment, including forests, lakes, rivers, and wildlife. These
constitutional provisions collectively promote sustainable development and
environmental protection.
Role of Indian Judiciary in Promoting Sustainable Development
The Indian judiciary has played a crucial role in promoting sustainable development
through judicial activism and Public Interest Litigation (PIL). The Supreme Court and
High Courts have interpreted constitutional provisions and environmental laws to
protect the environment. In Rural Litigation and Entitlement Kendra v. State of UP, 1986
the Supreme Court ordered the closure of limestone quarries that were causing
environmental damage. This case marked the beginning of judicial recognition of
sustainable development in India.
In Vellore Citizens Welfare Forum v. Union of India,1996 the Supreme Court declared
sustainable development as part of Indian law and recognized the precautionary
principle and polluter pays principle. Similarly, in Narmada Bachao Andolan v. Union of
India,2005 the Court emphasized the need to balance environmental protection and
economic development. These judicial decisions have strengthened environmental
governance in India.
International Recognition of Sustainable Development
Sustainable development has also been recognized at the international level. The
Stockholm Declaration was the first international conference that recognized the
importance of environmental protection. It established the foundation for modern
environmental law. The Rio Declaration of 1992 further strengthened the concept of
sustainable development and introduced key principles such as precautionary principle
and polluter pays principle. The Johannesburg Declaration of 2002 reaffirmed global
commitment to sustainable development and emphasized the need for international
cooperation in environmental protection.

B) THE POLLUTER PAYS PRINCIPLE

In environmental law, ‘the Polluter Pays Principle’ has been enacted to make the party
responsible for producing ‘pollution’ to pay for the damage done to the natural
environment. In simple words “The Polluter Pays Principle is the commonly accepted
practice that those who produce pollution should bear the costs of managing it to
prevent damage to human health or the environment.” For instance, a factory that
produces a potentially poisonous substance as a by- product of its activities is usually
held responsible for its safe disposal.
‘Polluter Pays Principle’ is also known as ‘Extended Producer Responsibility’ (EPR). This
is a concept that was described by Thomas Lindhqvist for the Swedish Government in
1990.
 The credit for popularizing the ‘Polluter Pays Principle’ for the first time goes to
Organisation for Economic Co-operation and Development (OECD).
The Supreme Court of India interpreted ‘Polluter Pays principle’ as the absolute
liability for harm to the environment extends not only to compensate the victims of
pollution but also the cost of restoring the environmental degradation.
The Environment Protection Act, 1986 expressly empowers the government “to take
all such measures as it deems necessary or expedient for the purpose of protecting and
improving the quality of environment”. Thus, it includes environmental costs as well as
direct costs to the people or property. So, it means that polluter should bear the cost of
pollution as the polluter is responsible for it.
The ‘Polluter Pays Principle’ finds prominent place in the ‘Rio Declaration of 1992’.
Principle 16 of the Declaration proclaims that national authorities should endeavour to
promote the internationalization of environmental costs and the use of economic
instruments, taking into account the approach that the polluter should bear the cost of
pollution, with due regard to the public interest and without distorting international
trade and investment.
The ‘Polluter Pays Principle’ exposes the polluter to two fold liability namely:
1. Compensation to the victims of pollution
2. Ecological restoration
But despite its different impact on pollution, the doctrine of Polluter Pays Principle is
limited in the sense that it can be applied only at the remedial stage i.e. after the
pollution has already taken place. It means one may “pay and pollute”.

C) THE PRECAUTIONARY PRINCIPLE

‘Precautionary Principle’ plays a significant role in determining whether the
development process is sustainable or not.
Precautionary Principle underlies sustainable development which requires that the
developmental activity must be stopped and prevented if it causes serious and
irreversible environmental damage. The Precautionary Principle ensures that a
substance or activity posing a threat to the environment is prevented from adversely
affecting it, even if there is no conclusive scientific proof linking that particular
substance or activity to the environmental damage.
adequacies of science are the real basis that has led to the emergence of Precautionary
Principle. The Principle is based on the theory that it is better to be on the side of
caution and prevent environmental harm which may indeed become irreversible.
The Precautionary Principle has been given utmost importance in the United Nation’s
Conference on Environment and Development held at Rio in 1992. Principle 15 of the
‘Rio Declaration’ states:
“In order to protect the environment, the precautionary approach shall be widely
applied by the States according to their capabilities, where there are threats as serious
as of irreversible environmental degradation.”
The Supreme Court of India in case of Vellore Citizens’ Forum v. Union of India, held
that the Precautionary Principle is a part of the environmental law of the country.
The essential ingredients of Precautionary Principle are:
 Environmental measures by the State Government & the statutory authorities like state
pollution boards must anticipate, prevent and attack the causes of environment
degradation.
 Where there are threats of serious and irreversible damage, lack of scientific certainty
should not be used as a reason for postponing measures to prevent environmental
degradation.

D) THE PUBLIC TRUST DOCTRINE

The ‘Public Trust Doctrine’ is the principle that certain resources are preserved for
public use, and that the government is required to maintain them for the reasonable use
of the public.
The ancient Roman Empire developed a legal theory known as ‘The Doctrine of Public
Trust’, which was founded on the ideas that certain common properties such as rivers,
seashore, forests and the air were held by government in trusteeship for the free and
unrestricted use of the general public.
The Public Trust Doctrine primarily rests on the principle that certain resources like air,
sea water and the forests have such a great importance to the people as a whole that it
would be wholly unjustified to make them a subject of private ownership.
The said resources being gifts of nature, they should be made freely available to
everyone, irrespective of the status in life. The doctrine enjoins upon the government to
protect the resources for the enjoyment of the general public rather than to permit their
use for private ownership or for commercial purposes.
The State is the ‘Trustee’ of all natural resources, which are by nature meant for public
use and enjoyment. Public at large is the beneficiary of the sea-shore, running waters,
air, forests and ecologically fragile lands.
The State as ‘Trustee’ is under a legal duty to protect the natural resources. These
resources meant for public use cannot be converted into private ownership. As rivers,
forests, minerals and such other resources constitute a nation’s natural wealth, these
resources are not to be frittered away and exhausted by any one generation.
Every generation owes a duty to all succeeding generations to develop and conserve the
natural resources of the nations in the best possible way. This is in the interest of the
nation as well as in the interest of the mankind.
The Doctrine was first mentioned by the Honourable Supreme Court applied the
‘Doctrine of Public Trust’ with regard to the protection and preservation
of natural resources. The Supreme Court stated that the Public Trust Doctrine primarily
rests on the principle that certain resources like air, sea, waters and forests have such
great importance to the people as a whole that it would not be justified to make these
resources a subject of private ownership .
The Honourable Supreme Court held that the Mahapalika, as a ‘trustee’ for the proper
management of the park, has to be more cautious in dealing with its properties.
The maintenance of the park because of its historical importance and environmental
necessity was in itself a public purpose. If the true nature of the park, as it existed is
destroyed, it would be violative of the ‘Doctrine of Public Trust’.
Restrictions imposed by the Public Trust Doctine
 This Doctrine imposes three kinds of restrictions on the State:
1. the property must not only be used for a public purpose,it must be available for use by
the general public;
2. the property must not be sold, even for fair cash equivalent; and
3. the property must be maintained for particular kind of uses, such as navigation,
recreation, or fishery
Ultimately, under this Doctrine, the State has a duty as a ‘Trustee’ under Article 48A of
the Constitution of India to protect and improve the environment and safeguard the
forests and wildlife of the country.
While applying Article 21 of the Constitution of India (right to life), the State is obliged to
take account of Article 48A of Directive Principle of State Policy. The State’s trusteeship
duties have been expanded to include a right to ‘a healthy environment’.

Why judicial remedies matter in environmental law

Legislation can set standards and prescribe penalties, but it is the judiciary that breathes
life into those standards when the executive machinery falls short. Judicial remedies for
environmental protection in India draw from two broad streams: civil remedies under
the law of torts, and criminal remedies under the Indian Penal Code (IPC) and the Code
of Criminal Procedure (CrPC). Together, they give individuals and communities a
practical way to seek compensation, stop ongoing harm, and hold polluters — public or
private — legally responsible.

Tort law as a tool for environmental protection

Tort law deals with civil wrongs — situations where one person’s conduct causes harm
to another, outside of a contractual relationship. Its application to environmental
disputes is well-established in India, operating through several distinct doctrines.

Private nuisance
Private nuisance arises when there is a substantial and unreasonable
interference with another person’s use or enjoyment of their land or property. In
environmental contexts, this covers offensive smells from industrial units, noise
pollution, contamination of groundwater, and air pollution from factories. Crucially, the
interference must not be fleeting — a single, short inconvenience is not actionable; the
nuisance must continue over time. The remedy available is either damages (monetary
compensation) or an injunction restraining the defendant from continuing the harmful
activity, or both.
For instance, in V. Lakshmipathy and Ors. v. State of Karnataka (AIR 1992 Kant 57), the
Karnataka High Court applied nuisance principles to restrain industrial activity that was
harming residential areas — a clear judicial use of private nuisance to protect the
environment at the local level.

Negligence
Where private nuisance focuses on the effect of an activity, negligence focuses on the
conduct of the defendant. To succeed in a negligence claim, the plaintiff must prove
three things: that the defendant owed a duty of care, that the defendant breached that
duty, and that this breach directly caused damage to the plaintiff. In environmental
cases, this is particularly relevant where industries fail to maintain safety standards,
store chemicals carelessly, or neglect to treat waste before discharge. The Bhopal Gas
Tragedy of 1984 — where thousands died due to the leakage of methyl isocyanate from
Union Carbide’s plant — remains the most harrowing illustration of environmental
harm caused by industrial negligence on a catastrophic scale, and it fundamentally
shaped how India approached corporate liability for environmental damage.

Strict liability: the rule in Rylands v. Fletcher

The doctrine of strict liability was laid down by the English courts in the 1868 case
of Rylands v. Fletcher. It holds that if a person brings onto their land something likely to
do mischief if it escapes, and it does escape causing damage, that person is liable
regardless of whether they were negligent. The key elements are the non-natural use of
land, the escape of a hazardous thing, and resulting harm.
In environmental law, this translated into liability for industries that stored hazardous
chemicals, toxic gases, or polluting substances — without needing to prove any fault.
However, strict liability under Rylands v. Fletcher came with recognised defences: act of
God, consent of the plaintiff, default of the plaintiff, and act of a third party. These
exceptions significantly limited the rule’s effectiveness in dealing with large-scale
industrial disasters — a gap that Indian courts ultimately filled with a far more powerful
doctrine.

Absolute liability: India’s own evolution

The most significant and distinctly Indian contribution to environmental tort law is the
principle of absolute liability, established by the Supreme Court in the landmark case
of M.C. Mehta v. Union of India (1987), commonly known as the Oleum Gas Leak Case.
The facts arose from a deadly oleum gas leak at Shriram Food and Fertilizers Industries
in Kirti Nagar, Delhi — a densely populated area of around 200,000 residents. The leak,
occurring barely a year after the Bhopal tragedy, caused severe health harm and the
death of a lawyer practising at Tis Hazari Court. Environmental advocate M.C. Mehta
filed a Public Interest Litigation (PIL) under Articles 21 and 32 of the Constitution
seeking closure and compensation.
Chief Justice P.N. Bhagwati, writing for the Court, held that the old rule of Rylands v.
Fletcher — designed for a 19th-century agrarian society — was inadequate for a modern
industrial economy. The Court declared that an enterprise engaged in a hazardous or
inherently dangerous activity is strictly and absolutely liable to compensate all those
affected by any accident arising from such activity, and that this liability admits of no
exceptions whatsoever. No defence — not even an act of God or the intervention of a
third party — could shield a hazardous industry from paying compensation.
The Court further held that the quantum of compensation must be proportionate to the
magnitude and financial capacity of the enterprise — embedding a deterrent logic into
the doctrine. This principle, famously linked to the idea of “deep pockets,” ensured that
larger and wealthier enterprises faced heavier liability. The doctrine of absolute
liability laid the groundwork for the Public Liability Insurance Act, 1991, which requires
industries handling hazardous substances to maintain insurance for immediate relief to
accident victims.

Available remedies under tort law

 Once a tort is established — whether nuisance, negligence, or strict/absolute liability —
courts have two primary remedies at their disposal.
Damages are monetary compensation awarded to the injured party. They may be
nominal (where a technical violation is proved but little actual harm occurred),
substantial (reflecting the actual loss suffered), or exemplary (punitive damages where
the conduct was especially egregious). In environmental cases, courts have awarded
damages for harm to health, property, livelihood, and ecological resources.
Injunctions are judicial orders that restrain a person or enterprise from continuing
a tortious act. Where monetary compensation is insufficient — particularly when
irreversible environmental damage is threatened — an injunction becomes the
appropriate remedy. Courts may grant a temporary injunction to halt ongoing harm
while proceedings continue, or a perpetual injunction to permanently prevent the
offending activity. In cases where an industry has a government licence, courts have still
granted injunctions, recognising that a licence to operate does not confer a licence to
pollute.

#CRIMINAL REMEDIES
The Indian Penal Code and the Criminal Procedure Code, 1973 deal with the remedies
and concept of various nuisance with regards to environmental pollution and crimes.
 Indian Penal Code
Background: Chapter XIV of the Indian Penal Code deals with offences affecting the
public safety, health, convenience, decency and morals.
Provisions:
Section 268– This section classifies environment crimes as a public nuisance. If any act
or omission causing injury to any person by polluting the environment takes place, the
person can be subjected to prosecution under this section. Even noise pollution is
punishable under section. According to this section a person can be held liable for the
offence of public nuisance under the following circumstances;
(I) If he engages or conducts any act which causes common injury.
(ii) If he engages or conducts any activity that poses danger or annoyance to any
property for the public.
(iii) If he engages or conducts any activity that poses danger or annoyance to the public.
Section 269- This section deals with negligent acts that are likely to spread infection of
disease that are dangerous to life. A person liable under this section shall be punished
with imprisonment for a term of up to six months or with a fine or both.
Section 277– This section deals with provisions for preventing water pollution.
According to this section, any person who voluntarily corrupts or fouls water of any
public reservoir and makes it less fit for consumption shall be held liable. The person
may be punished with imprisonment for a term of up to three months or with a fine
extending to Rupees 500 or both.
Section 278– This section deals with remedies for acts that make atmosphere noxious
to health, air pollution. Whoever voluntarily vitiates the atmosphere in any way that
makes it noxious to health of persons shall be punished with a fine of maximum Rupees
500.
Section 290– This section provides for the punishment of public nuisance. The
maximum penalty under this section is Rupees 200. This section also makes clear that
 smoking in public place causes public nuisance and therefore is punishable under this
Act.
Relevant Judgement:
1. Ramakrishnan V. State of Kerala (1999)- The Court held that smoking in public cases
causes public nuisance and is therefore punishable under the Indian Penal Code.
 Criminal Procedure Code, 1973
Background: Chapter 10 of Criminal Procedure Code, Maintenance of Public Order and
Tranquility. It provides legal provisions for the maintenance of public order and
tranquility. It is the duty of every citizen to maintain public order. Maintenance of public
order and tranquility in the society is one of the primary objectives of any government.
It contains remedies for public nuisances cases.
Provisions:
Section 133– This section provides for the remedy to environmental pollution in
general. It empowers the District Magistrate and Sub- Divisional Magistrate to stop the
nuisance. Any order made under this provision cannot be questioned in any civil court.
Under this section six category of public nuisances can be resolved.
1. Unlawful obstruction or nuisance to any public place, river or channel lawfully used by
the public.
2. Conduct of any trade or occupation or storing goods that are injurious to health or
causes discomfort to the community.
3. Construction of any project or disposal of any substance that is likely to cause an
explosion.
4. Any building, tent, or structure that is likely to cause damage or injury to a person.
BNS
Section 270 – Public nuisance.
A person is guilty of a public nuisance who does any act or is guilty of an illegal omission which causes any common
injury, danger or annoyance to the public or to the people in general who dwell or occupy property in the vicinity, or
which must necessarily cause injury, obstruction, danger or annoyance to persons who may have occasion to use any
public right but a common nuisance is not excused on the ground that it causes some convenience or advantage.

Section 280 – Making atmosphere noxious to health.

Whoever voluntarily vitiates the atmosphere in any place so as to make it noxious to the health of persons in general
dwelling or carrying on business in the neighbourhood or passing along a public way, shall be punished with fine
which may extend to one thousand rupees.
BNSS Classification
 Fine of 1,000 rupees.
 Non-cognizable
 Bailable
 Triable by Any Magistrate.

Section 292 – Punishment for public nuisance in cases not otherwise provided for.
Whoever commits a public nuisance in any case not otherwise punishable by this Sanhita shall be punished with fine
which may extend to one thousand rupees.
BNSS Classification
 Fine of 1,000 rupees.
 Non-cognizable
 Bailable
 Triable by Any Magistrate.
 In the Bharatiya Nagarik Suraksha Sanhita (BNSS), environmental protection is
primarily enforced through the provisions dealing with the abatement of public
nuisances.
The primary sections are Section 152 (Conditional order for removal of nuisance) and
Section 163 (Power to issue urgent orders in cases of nuisance or apprehended
danger). These sections empower Magistrates to take immediate preventive action to
halt environmental harm.
Relevant Statutory Provisions
 Section 152 BNSS (equivalent to Section 133 of the erstwhile CrPC): Allows a District
Magistrate or a Sub-divisional Magistrate to issue a conditional order to remove
environmental hazards such as unlawful pollution in rivers, noxious trades, or
dangerous structures.
 Section 163 BNSS (equivalent to Section 144 of the erstwhile CrPC): Empowers
Magistrates to issue urgent, immediate orders to prevent or stop environmental
nuisances that pose an imminent threat to public health and safety.
Relevant Landmark Judgment
Ratlam Municipality v. Vardichand (1980 AIR 1622)
 The Case: Residents of Ratlam filed a complaint against the municipality for failing to
construct drains, leading to severe pollution and foul odors from overflowing waste
water.
 The Judgment: The Supreme Court directed the municipality to construct proper
drainage and abate the pollution. The Court firmly established that local bodies cannot
cite a lack of funds as an excuse to avoid performing their statutory duties to protect
public health and the environment. This case paved the way for using magistrate-led
nuisance laws to enforce basic environmental safety.

#NGT
Locus standi refers to the legal right of a party to bring a case to court. For the National
Green Tribunal (NGT), these rules are heavily liberalized. Any "person" (including
individuals, NGOs, and environmental groups) can file an application to seek relief,
effectively expanding standing far beyond those who have suffered direct, personal
injury.
1. Liberalized Locus Standi under the NGT
Unlike traditional civil courts where the petitioner must be a direct victim, the NGT
takes a highly inclusive approach.
 Broad Definition of 'Person': Under Section 2(j) of the National Green Tribunal Act,
2010, a "person" can include individuals, local bodies, societies, registered companies, or
non-governmental organizations.
 No Direct Harm Required: An applicant does not need to prove direct, personal
property damage or physical injury. If a substantial question relating to the environment
(including the enforcement of any legal environmental right) is raised, anyone can apply.
 Public Interest Angle: The NGT functions on the same broad principles as a Public
Interest Litigation (PIL) court, permitting public-spirited individuals to defend the
environment.
2. Statutory Provisions (NGT Act, 2010)
 Section 14: Grants the NGT jurisdiction over all civil cases where a "substantial question
relating to the environment" is involved.
  Section 15: Allows individuals to file for relief, compensation, and restitution for
environmental damage.
 Section 18: Dictates who can file an application. It specifies that an application for
compensation can be filed by the person who sustained the injury, the owner of the
property damaged, or any representative body/organization functioning in the field of
environment.
3. Suo Motu Powers and Expanded Reach
 Inherent Powers: The Supreme Court of India has affirmed that the NGT is not merely
an adjudicatory body, but a "unique" forum. It is not bound strictly by the Code of Civil
Procedure (CPC) and operates on the principles of natural justice.
 Taking Cognizance: The Supreme Court recognized that the NGT possesses the power
to initiate cases suo motu (on its own motion) based on media reports or letters, entirely
bypassing the need for a formal petitioner.

M.C. Mehta V Kamal Nath (1997)

A Club belonging to Span Motels Private Limited carried out various constructions on
the riverbed and the banks of River Beas and was discharging untreated effluents into
the river. The club was built after encroaching upon 27.12 bighas of land, including
forestland, in 1990. The land was later regularised and leased out to the company on 11
April 1994. The regularisation was done when Kamal Nath was Minister of Environment
and Forests. The family of Indian politician Kamal Nath had direct links with this
company. Court applied 'Public Trust Doctrine' in this case. Applying the Public Trust
Doctrine court held that the lease is cancelled and set aside.
Government shall take over the area and restore it to its original-natural conditions. The
Motel shall pay compensation by way of cost for the restitution of the environment and
ecology of the area. The pollution caused by various constitutions made by the Motel in
the riverbed and the banks on the river Beas have to be removed and reversed.

The Taj Mahal Case-

The Taj Mahal Case, also known as the Taj Trapezium Case, was fought between M.C. Mehta and
the Union of India. He filed a writ petition in 1986.
Background- Taj Mahal is considered one of India’s most epic Mughal structures. The Taj
Trapezium zone, which is of 10,400 sq. km., is built to protect it from pollution. Mehta visited
Taj in 1984 and noticed the white marble of Taj turning yellow. To bring this matter into
limelight, he filed a petition in the Supreme Court.
Facts of the case-
  The petitioner stated pollution as the main cause of the yellow colour. Emission of
pollutant gases like sulphur dioxide and oxygen turned into acid rain. This rain was
harmful to the monument and caused the marbles to turn yellow.
 Therefore, the petitioner asked for the protection of the monument.
 As a result, the Central Board for Prevention and Control of Water published “Inventory
and Assessment of Pollution Emission in and Around Agra-Mathura Region”.
 The report declared the pollution levels as high and measures to reduce them.
 One of the measures was to shut down thermal power stations. Another step was to
reduce emissions of Sulphur Dioxide by 50%.
Judgements- the Supreme Court observed that other than chemicals, socio-economic factors
too influenced the degradation of Taj. The people living in the Trapezium Zone were at risk due
to air pollution. The court ordered 292 industries to operate using safe fuels like propane
instead of coke/coal, otherwise they would have to relocate. The Gas Authority of India Limited
was in charge of applications of gas. The court also gave few fundamental rights to workers of
these industries and demanded payment of their wages during the time taken for relocation.