What principle did the Supreme Court establish in M.C. Mehta v. Kamal Nath?

The Court embedded the Public Trust Doctrine in Indian law: the State holds vital natural resources in trust for the public and must protect them.

How do Precautionary and Polluter Pays apply here?

Developers must prevent harm and bear full costs of damage and restoration. The burden of proof lies on the developer to show safety.

What orders were made against Span Motels?

Lease and prior approval were set aside; the motel had to fund restoration, stop using the river basin, and comply with NEERI’s safeguards.

What constitutional rights were relied on?

Article 21’s right to a healthy environment and Article 32 allowed the Court to grant effective remedies to protect the ecosystem.

Why is this case important for students?

It ties constitutional rights with environmental principles and shows courts can order real restoration, not just declare rights.

M.C. Mehta v. Kamal Nath

Quick Summary

A resort project on the River Beas altered the riverbank and harmed the ecosystem. The Supreme Court said the State holds rivers and similar resources in trust for the public. It struck down approvals, ordered restoration, and made the developer pay. The Court applied the Public Trust Doctrine, the Precautionary Principle, and the Polluter Pays rule, grounding relief in Articles 21 and 32.

Issues

Is the Public Trust Doctrine part of Indian law?
Was Span Motels’ construction on the Beas riverbank legally justified?
Were allegations against Mr. Kamal Nath relevant to the legality of approvals and use of public resources?

Rules

Public Trust Doctrine: The State holds crucial natural resources (like rivers) in trust for the public; it cannot allow their private capture or degradation.
Precautionary Principle: Where serious environmental risk exists, authorities and developers must act to prevent harm even if scientific certainty is incomplete.
Polluter Pays Principle: The developer bears the full cost of damage and restoration, and must prove safety of its activities.
Articles 21 & 32: Right to a healthy environment and effective constitutional remedies empower courts to protect ecosystems.

Facts (Timeline)

Timeline visual for M.C. Mehta v. Kamal Nath events

Span Motels builds a new “Span Club” along the Beas bank near the resort.
Media report: Indian Express highlights river training and encroachment concerns.
Government approval: MoEF grants consent and lease of ~27.12 bighas of forest land (24 Nov 1993).
River impact: Heavy embankments and machinery disturb the river course; adjoining areas are washed away.
1995 flood: Beas floods cause major damage; environmental risk becomes evident.

Arguments

Petitioner (M.C. Mehta)

River and riverbed are public trust assets; private alteration is impermissible.
Approvals and lease enabling embankments breached environmental duties.
Apply Precautionary & Polluter Pays; order restoration and costs.

Respondents (Span Motels & Others)

Project followed government permissions; embankments protected property.
No clear proof of lasting ecological harm attributable solely to the project.
Any restrictions should be prospective and reasonable.

Judgment

Held: The Supreme Court adopted the Public Trust Doctrine into Indian law. The MoEF approval and forest-land lease were quashed. The State was directed to restore the river to its natural state, and Span Motels was made liable for restitution costs under Polluter Pays, with Precautionary controls to prevent future harm.

NEERI to assess and guide restoration and safeguards.
Construct a 4-metre boundary wall; no access/use of river basin beyond it.
No discharge of sewage into the river; regional inspections for other units; strict action for violations.
Respondents to explain why additional environmental compensation should not be levied (per Court’s direction).

Ratio

Rivers and similar resources are public trust assets. The State cannot convert or permit their private capture. Where risk exists, prevent the harm (Precautionary) and make the wrongdoer pay and restore (Polluter Pays), backed by constitutional rights under Articles 21 & 32.

Why It Matters

Puts the Public Trust Doctrine at the heart of Indian environmental law.
Makes restoration and real-world compliance part of remedies, not just declarations.
Guides future projects on riverbanks, floodplains, forests, and coasts.

Key Takeaways

Public trust assets can’t be privatized: State must preserve access and ecology.
Prevent first: If risk exists, apply Precautionary controls immediately.
Restore and compensate: Polluter Pays covers victims’ loss and ecosystem repair.
Constitutional backing: Articles 21 & 32 ensure effective judicial protection.

Mnemonic + 3-Step Hook

Mnemonic: TRI-P — Trust (Public Trust) • Restore (natural state) • Interdict (harm via Precaution) • Pay (Polluter Pays).

Spot: Is the resource a public trust asset (river, forest, coast)?
Probe: Are approvals enabling private capture or ecological harm?
Pin: Apply Precaution & Polluter Pays; order restoration and monitoring.

IRAC Outline

Issue

Whether the State could allow riverbank alteration for a private resort and whether Public Trust, Precautionary, and Polluter Pays apply.

Rule

Public Trust Doctrine; Precautionary & Polluter Pays principles; Articles 21 & 32 enabling environmental remedies.

Application

Approvals enabling embankments privatized a public resource and heightened risk; Court quashed permissions, imposed safeguards and costs.

Conclusion

Doctrine adopted; restoration ordered; Span Motels to pay; NEERI oversight and strict no-use of river basin enforced.

Glossary

Public Trust Doctrine: Legal idea that the State holds key natural resources for public use and must protect them.
Precautionary Principle: Prevent harm where risk is credible, even without complete scientific certainty.
Polluter Pays: Polluters must finance compensation and full environmental restoration.