Rural Litigation and Entitlement Kendra v. State of U.P. ((1985) 3 SCC 614)
Supreme Court steps in to save the Doon Valley—quarrying stopped under the Forest Conservation Act, with a clear message: protect nature and people together.
Table of Contents
Quick Summary
In the Doon Valley, unregulated limestone quarrying damaged forests, springs and farms. The Supreme Court used the Forest Conservation Act, 1980 and the idea of sustainable development to stop unsafe mining. Orders allowing quarrying were dissolved. Workers were given priority for jobs in future lawful mining.
Issues
- Were quarry operations in the valley in breach of the Forest Conservation Act, 1980?
- Did quarrying degrade perennial springs and water flow?
- Could mining trigger landslides, vegetation loss and wide ecological harm?
- Were the State leases and permissions issued in line with law?
Rules
- Sustainable Development: balance environment, economy, and social needs; protect today and the future.
- FCA 1980 Compliance: forest use for non-forest purposes (like mining) needs central approval and strict safeguards.
Facts — Timeline
Timeline view1950s–1965: Doon Valley becomes a hub for limestone mining; early signs of erosion and siltation.
1961: State Mining Department outlaws mining; 1962: Legislature still grants 20-year licenses—quarrying resumes.
1980s: Severe degradation—mudslides, floods, farm losses, drying springs.
1982: On renewal, State bans licenses owing to ecological harm; Allahabad HC allows mining favouring economic gains.
1983: RLEK sends letter-PIL under Article 32 to the Supreme Court challenging destructive quarrying.
Arguments — Appellant vs Respondent
Petitioners (RLEK)
- Mining violates FCA 1980 and destroys forests and springs.
- Risks of landslides, flooding and permanent ecological loss.
- State leases/permissions not in full legal compliance.
State/Quarry Lessees
- Mining supports local economy and jobs.
- With safeguards, impacts can be managed.
- Existing leases should be respected.
Judgment
- Mining activities in the valley were in grave violation of the FCA 1980; they could not continue.
- Any orders allowing lessees to resume mining were dissolved with immediate effect.
- Court noted worker hardship; directed that affected workers get priority in future lawful mine auctions.
Ratio Decidendi
Forest protection and human safety come first. Where quarrying harms springs, slopes and forests, the Court enforces FCA 1980 and applies sustainable development—stopping damage while planning fair worker transitions.
Why It Matters
RLEK is an early environmental PIL that links forests, water security, disaster risk and livelihoods. It shows courts can prevent irreversible harm and still consider people who depend on the sector.
Key Takeaways
- FCA 1980 controls mining in forest areas—no shortcuts.
- Protect springs and slopes; stop activities that trigger landslides and floods.
- Sustainable development = ecology + economy + equity.
- Plan worker priority in lawful, safer operations.
Mnemonic + 3-Step Hook
Mnemonic: “D-O-O-N” — Defend forests, Obey FCA, Observe springs, Navigate jobs fairly.
- Check Law: FCA approval mandatory.
- Check Nature: Springs, slopes, trees first.
- Check People: Prioritise workers in transitions.
IRAC Outline
Issue
Could limestone mining continue in the Doon Valley despite ecological harm and FCA requirements?
Rule
FCA 1980 + sustainable development; non-forest use needs central permission and strong safeguards.
Application
Mining harmed forests and hydrology; legal approvals and safety were inadequate to prevent risks.
Conclusion
Stop unlawful/unsafe mining; dissolve contrary orders; give workers priority in future lawful auctions.
Glossary
- FCA 1980
- Forest Conservation Act—central approval needed for non-forest use of forest land.
- Perennial Spring
- A spring that flows all year; quarrying can reduce or dry it.
- Sustainable Development
- Development that protects nature, supports people, and sustains the economy.
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