Hanuman Laxman v. Union of India — Goa Airport Case II

1. Were the EAC’s revisions and added conditions legally sound under environmental rules?
2. Could the Supreme Court safely revoke its suspension of the EC on that basis?

• Doctrine of Sustainable Development: Policy must balance growth, society, and ecology; today’s gains must not damage tomorrow’s needs.
• Precautionary Principle: Where serious or irreversible risk exists, preventive steps are required. Lack of full scientific certainty is not a reason to delay action.

• The Supreme Court lifted the suspension on the EC and allowed work to continue.
• It imposed additional environmental conditions, including a push toward zero-carbon operations.
• The Court directed NEERI to supervise and monitor compliance with the new conditions.

Balance with safeguards: Courts may allow strategic infrastructure where appraisal gaps are cured and robust mitigation is ensured.

Precaution stays central: Uncertainty triggers preventive conditions, monitoring, and expert oversight.

Process integrity: Transparent, reasoned EAC review can justify lifting interim restraints.

• Shows how courts use conditional relief to protect nature while enabling development.
• Reinforces that appraisal quality and ongoing audits are non-negotiable.
• Useful precedent on tailoring remedies: suspend → revisit → permit with conditions.

1. EAC must give clear, reasoned, and data-based findings.
2. Precaution can mean stricter conditions, not a blanket stop.
3. Independent oversight (e.g., NEERI) builds accountability.
4. Zero-carbon goals can be judicially encouraged in major projects.

Mnemonic: “Evaluate, Enable, Ensure” (3E)

• Evaluate — EAC revisits and fixes appraisal gaps.
• Enable — Court lifts suspension with strict terms.
• Ensure — NEERI oversight + zero-carbon direction.

Issue: Can the EC suspension be lifted after a lawful and complete EAC review?

Rule: Sustainable Development and Precaution: development may proceed only with credible mitigation, monitoring, and transparency.

Application: The EAC’s revised appraisal addressed material concerns; added conditions reduced ecological risk; third-party oversight strengthened compliance.

Conclusion: Yes. Suspension lifted; EC stands with tougher safeguards and supervision.

Environmental Clearance (EC)

Official approval that a project meets environmental norms with mitigation.

EAC

Expert Appraisal Committee that reviews project impacts and sets conditions.

NEERI

National Environmental Engineering Research Institute; provides scientific oversight.