Historical Evolution of International Environment Law:

Evolution of International Environmental Law:

Traditional Period (1900-1972): Conservation dates back to 1669, when Jean-Baptiste
Colbert passed the Ordonnance et Forest, which can be considered the forerunners of today’s
environmental legislation. As a result, natural resource management has been a topic of
international law for over 500 years, beginning with the introduction of the Traditional
Period, which gave us the first glimmers of Environmental Law.
It began as a core aspect of international law during this time period, when bilateral
agreements were made between various states to handle disputes over shared natural
resources. Everything that happened during this time was based on the ‘principle of
reciprocity’ between states, and no particular environmental legislation was formed.
The Ramsar Convention on Wetlands of International Importance was adopted in 1971 as a
result of cooperative efforts by the United Nations Educational, Scientific, and Cultural
Organization (UNESCO).
All of these events culminated in the creation of a firm foundation for environmental law that
was ready to be refined and crystallized.
Modern Period (1972-1992): At the United Nations Conference on the Human Environment
in Stockholm in 1972, governments from all over the world came together for the first time to
identify and address environmental issues.
The fundamental problem at this meeting was the contradiction between economic progress
and environmental protection, and it was at this conference that the concept of Sustainable
Development was established.
The Convention for the Prevention of Marine Pollution by Dumping of Wastes and Other
Matters and the Convention for the Protection of World Cultural and Natural Heritage, both
signed in 1972, and the Convention on International Trade in Endangered Species of Wild
Fauna and Flora (CITES), signed in 1973, are two important multilateral agreements
associated with the Stockholm Conference.
Over the next two decades, worldwide environmental agreements multiplied, with over 1100
international legal instruments dedicated to the environment in some way. Countries grew
competent at negotiating new agreements in short time frames of little more than two months
throughout this period.
Post Modern Period (1992-2012): The United Nations Conference on Environment and
Development kicks off this period, which lasts for the next two decades. On the twentieth
anniversary of the 1972 Stockholm Conference, countries met in Rio de Janeiro, Brazil, in
June 1992.
The venue provided a strong statement that environmental and development problems were
shared by all countries, regardless of their economic growth. Major changes in worldwide
environmental law and policy have occurred in the years after the Rio Conference.
It has grown in both strength and breadth. Trade, human rights, and national security have all
become intertwined. Old laws and principles have been redefined, while new ones have
evolved.
Some Major International Environmental Conventions:
1. Ramsar Convention,1971: It is called the Convention on Wetlands. Came into force on
1975.
2. Stockholm Convention,1972: It was about Human Environment. The United Nations
Environment Programme (UNEP) was created as a result of this conference.
3. Convention on International Trade in Endangered Species,1963 (CITES) : It is a
convention on International Trade in Endangered Species of Wild Fauna and FloraIt was
adopted in 1963.It came into force in 1975.
4. Convention on Biological Diversity (CBD), 1992: It came into force in 1993.
5. Bonn Convention,1979: It is a convention on the Conservation of Migratory Species of
Wild Animals. It came into force in 1983.
6. Vienna Convention, 1985: It is a convention for the Protection of Ozone Layer. It came
into force in 1988.
7. Montreal Protocol,1987: It is an international environment protocol on substances that
deplete the Ozone Layer. It came into force in 1989.
8. Kyoto Protocol,1997: It is an international protocol to reduce greenhouse gas emissions. It
came into force in 2005.
9. United Nations Framework Convention on Climate Change,1992: It is an international
environmental treaty governing actions to combat climate change through adaptation and
mitigation efforts directed at control of emission of Greenhouse Gases (GHGs) that cause
global warming. It came into force in 1994.
10. Rio Summit,1992: It is a United Nations Conference on Environment and Development.
11. United Nations Convention to Combat Desertification (UNCCD) ,1994: It came into
force in 1996.
12. Basel Convention, 1989: It is a convention on the Control of Transboundary Movements
of Hazardous Wastes and their Disposal. It came into force in 1992.
13. Cartagena Protocol,2000: It is an international environmental protocol on Biosafety to
the Convention on Biological Diversity. It came into force in 2003.
14. United Nations Programme on Reducing Emissions from Deforestation and Forest
Degradation (UN-REDD) ,2008.
15. Nagoya Protocol,2010: It is an international environment protocol on Access to Genetic
Resources and the Fair and Equitable Sharing of Benefits Arising from their Utilization
(ABS) to the Convention on Biological Diversity (CBD).It came into force in 2014.
16. COP24: It is the 24th meeting of the conference of parties (COP) to the United Nations
Framework Convention on Climate Change. It took place in 2018.
17. COP21: It is the 21st meeting of the conference of parties (COP) to the United Nations
Framework Convention on Climate Change. It took place in 2018.
18. Kigali Agreement: It is an amendment to the Montreal Protocol. It was adopted in
2016.It came into force in 2019.
19. Minamata Convention: It is an international environmental treaty intended to protect
health and the environment from the adverse effects of mercury. It was adopted in 2013. It
came into force in 2017.
20. Rotterdam Convention,1998: It is an international environmental convention on Prior
Informed Consent (PIC) Procedure for Certain Hazardous Chemicals and Pesticides in
International Trade. It came into force in 2004.
21. COP25: It is the 25th meeting of the Conference of Parties (COP) to the United Nations
Framework Convention on Climate Change (UNFCCC). It took place in 2019.

Perspectives of Developed and Developing Countries:

The developed countries consume more global energy and contribute more to global emission
than developing countries that cause global inequity in energy consumption in the world and
the developing countries contribute in reducing the global carbon emission
Common But Differentiated Responsibilities (CBDR):
At the 1992 United Nations Conference on Environment and Development held at Rio
de Janeiro, the principle of Common But Differentiated Responsibilities (CBDR) was
formalized. Principle 7 of the Rio Declaration was enshrined as the concept of CBDR. It was
stated in the declaration that, “In view of the different contributions to global environmental
degradation, States have common but differentiated responsibilities. The developed
countries acknowledge their responsibility that they bear in the international pursuit of
sustainable development in view of the pressures that their societies place on the global
environment and of technologies and financial resources they command.”
Stockholm Declaration: (1972)
The United Nations Conference on the Human Environment (also known as the
Stockholm Conference) was an international conference convened under United Nations
auspices held in Stockholm, Sweden from June 5-16, 1972. It was the UN's first major
conference on international environmental issues, and marked a turning point in the
development of international environmental politics.
The meeting agreed upon a Declaration containing 26 principles concerning the environment
and development; an Action Plan with 109 recommendations, and a Resolution.
Some of the Important Principles and Recommendations of the Conference are:
(1) Right to Protect Environment: Man has the fundamental right to freedom, equality and
adequate conditions of life in an environment of a quality that permits a life of dignity and
wellbeing and he bears a solemn responsibility to protect and improve the environment for
present and future generation.
(2) Management of Natural Resources:
The natural resources of the earth, including the air, water, land, flora and fauna and
especially representative samples of natural ecosystems, must be safeguarded for the benefit
of present and future generations through careful planning or management as appropriate.
(a)Non-Renewable Resources: The non-renewable resources of the earth must be employed
in such a way as to guard against their future exhaustion and to ensure that benefits from such
employment are shared by all mankind.
(b)Renewable Resources: he capacity of the earth to produce vital renewable resources must
be maintained and, wherever practicable, restored or improved.
(3) Conservation of Wildlife
(4) Population Policy.
(5) Environment and Development.
(6) Pollution Control.
(7) Resource Planning.
(8) Ban on nuclear weapons.

Rio Conference: (1992)

The United Nations Conference on Environment and Development (UNCED), also
known as the Rio de Janeiro Earth Summit, the Rio Summit, the Rio Conference, and
the Earth Summit, was a major United Nations conference held in Rio de Janeiro from 3 to
14 June in 1992. 172 governments participated, with 116 sending their heads of state or
government. Some 2,400 representatives of non-governmental organizations (NGOs)
attended, with 17,000 people at the parallel NGO “Global Forum” (also called Forum
Global), who had Consultative Status. A significant accomplishment of the summit was an
agreement on the Climate Change Convention which in turn led to the Kyoto Protocol and
the Paris Agreement. Another agreement was to “not to carry out any activities on the lands
of indigenous peoples that would cause environmental degradation or that would be culturally
inappropriate”.
The Rio Summit 1992 is also called the Earth Summit. This summit led to the
development of the following documents:
● Rio Declaration on Environment and Development
● Agenda 21
● Forest Principles

Moreover, important legally binding agreements were opened for signature: (This signed
document is also known as Rio Declaration):
● Convention on Biological Diversity
● Framework Convention on Climate Change (UNFCCC)
● United Nations Convention to Combat Desertification
Rio Declaration: The first document called the Rio Declaration in short, contained 27
principles that were supposed to guide countries in future sustainable development. It was
signed by over 175 countries. It includes formulations of the precautionary principle
(principle 15) and of the polluter pays principle (principle 16).
Agenda 21: Agenda 21 is an action plan with respect to sustainable development, but it is
non-binding. . Its aim is achieving global sustainable development. One major objective of
the agenda 21 initiative is that every local government should draw its own local Agenda 21.
Forest Principles: The Forest Principles is formally called ‘Non-Legally Binding
Authoritative Statement of Principles for a Global Consensus on the Management,
Conservation and Sustainable Development of All Types of Forests’. It makes many
recommendations for conservation and sustainable development forestry, and is non-binding.
Earth Summit 2002: (Rio+10)(Johannesburg declaration)
The World Summit on Sustainable Development 2002, took place in South Africa, from 26
August to 4 September 2002. It was convened to discuss sustainable development
organizations, 10 years after the first Earth Summit in Rio de Janeiro. (It was therefore also
informally nicknamed "Rio+10".)
The Johannesburg Declaration was the main outcome of the Summit; however, there were
several other international agreements. It laid out the Johannesburg Plan of Implementation
as an action plan
Sources of International Environmental Law:
International environmental law is derived primarily from three sources: customary
international law; international treaties; and judicial decisions of international courts.
1) Customary International Law: Customary international law refers to international
obligations arising from established international practices, as opposed to obligations arising
from formal written conventions and treaties.
2) International Treaties: International treaties are the most recent, and most effective,
source of international environmental law.
A treaty is a formal, legally binding written agreement between actors in international law. It
is usually made by and between sovereign states, but can include international organizations,
individuals, business entities, and other legal persons.
3) Judicial Decision of International Courts: Decisions by international courts or
arbitrators, such as the International Court of Justice or the International Tribunal for the Law
of the Sea, also shape international environmental law.

General Principles of International Environmental Law:

 Sovereignty over Natural Resources: The principle of sovereignty over natural
resources embodies the right of States and peoples to dispose freely of their natural
resources.
 Obligation Not to Cause Damage: Also known as the No-Harm Rule is a widely
recognised principle of customary international law whereby a State is duty-bound to
prevent, reduce and control the risk of environmental harm to other states.
 Principles of Preventive Action: This principle mainly states that there should be
some preventive action in the state regarding reducing wastes, reducing liability, and
increasing efficiency. Some ways are: Use of penalties, Authorities established to
particularly look into these preventive actions and Establishing environmental
standards.
 Precautionary Principle: This principle was first codified in the Rio
Declaration,1992. It was stated that “In order to protect the environment, the
precautionary approach shall be widely applied by States according to their
capabilities.
 Polluter Pays Principle: The basic meaning of this principle is that those who
commence the act of pollution shall bear the cost of its management and prevention.
The 1992 Rio Declaration has recognised the polluter pays principle. ‘If you make a
mess, it’s your duty to clean it up’- this is the fundamental basis of this slogan.
 Doctrine of Absolute Liability: Its is a principal which sates that where business of
inherently dangerous nature is carried on, the business is absolutely liable for the
damages caused knowingly or unknowingly.
 Equitable Sharing of Cost: The cost of damages needs to be assessed fairly and if
multiple parties are the reason, their contribution should be equitable in proportion to
their impact relating to the damages caused.
 Principle of Sustainable Development: development should meets the needs of the
present, without compromising the ability of future generations to meet their own
needs.
 Public Trust Doctrine: The Public Trust Doctrine primarily rests on the principle
that certain resources like air, water, sea and the forests have such a great importance
to people as a whole that it would be wholly unjustified to make them a subject of
private ownership.
Transboundary Pollution:
Transboundary pollution is defined legally as pollution that originates in one country but can
cause damage in another country's environment, by crossing borders through pathways
like water or air.
State Liability for Transboundary Pollution:
Responsibility of States for Internationally Wrongful Acts, 2001 along with the certain
Treaties signed by a sovereign state has provisions to what their responsibility is and their
liability in case of violation.
The violation of both a duty under either a bilateral or multilateral environmental agreement
or rules of general international law by a State entails its international responsibility to the
injured State. As a legal consequence, the responsible State is obliged to make reparations
with a monetary payment (compensation) being only one of many means of providing
reparation for injury. However, compensation is often provided in practice to offset the
environmental damage because restitution in kind is not possible.

The Convention on Long-Range Transboundary Air Pollution, often abbreviated as Air

Convention or CLRTAP, is intended to protect the human environment against air pollution
and to gradually reduce and prevent air pollution, including long-range transboundary air
pollution.
The Convention on the Protection and Use of Transboundary Watercourses and
International Lakes (Water Convention) was adopted in Helsinki in 1992 and entered into
force in 1996. Its highest decision-making body is the Meeting of the Parties, which is
convened every three years. The subsidiary bodies of the Meeting of the Parties include the
Bureau, the working group on the integrated water resources management, the working group
on monitoring and assessment, the task force on water and climate, the task force on the
water, food, energy, ecosystem nexus and the joint expert group on water and industrial
accidents.
The Water Convention also has an Implementation Committee, a Secretariat and an
International Water Assessment Centre (IWAC).

Many important water agreements like the Danube River Protection Convention (1994), the
Convention on the Protection of the Rhine (1999), and the Convention for the Prevention of
Conflicts Related to the Management of Shared Water Resources in Central Africa (2017)
mention the Water Convention as a core reference for the cooperation of their parties.
Desertification:
Desertification is the process by which vegetation in drylands i.e. arid and semi-arid lands,
such as grasslands or shrublands, decreases and eventually disappears.
The United Nations Convention to Combat Desertification (UNCCD) is a Convention to
combat desertification and mitigate the effects of drought through national action programs
that incorporate long-term strategies supported by international cooperation and partnership
arrangements. The measure if this convention are implemented in Countries Experiencing
Serious Drought and/or Desertification, Particularly in Africa. All 193 countries are
signatories. The Convention stemming from a direct recommendation of the Rio Conference's
Agenda 21, was adopted in Paris, France, on 17 June 1994 and entered into force in
December 1996.
Climate Change convention:
The first global conference on climate change was held in 1972 in Stockholm, Sweden. This
conference ushered in numerous global negotiations and international agreements on the
environment. All of these culminated in the establishment of the United Nations Framework
Convention on Climate Change (UNFCCC) at Rio, in 1992.
The UNFCCC objective is to "stabilize greenhouse gas concentrations in the atmosphere at a
level that would prevent dangerous anthropogenic interference with the climate system.
Causes of Climate Change:
 Burning coal, oil and gas produces carbon dioxide and nitrous oxide.
 Cutting down forests (deforestation). Trees help to regulate the climate by
absorbing CO2 from the atmosphere. When they are cut down, that beneficial effect is
lost and the carbon stored in the trees is released into the atmosphere, adding to the
greenhouse effect.
 Increasing livestock farming. Cows and sheep produce large amounts of methane
when they digest their food.
 Fertilisers containing nitrogen produce nitrous oxide emissions.
 Fluorinated gases are emitted from equipment and products that use these gases.
Such emissions have a very strong warming effect, up to 23 000 times greater than
CO2.

Effects of Climate Change include:

 Hotter Temperatures
 More Severe Storms
 Increased drought
 A warming, rising ocean
 Loss of species
 Food Scarcity
 More health risks
 Poverty and displacement
Kyoto protocol: The Kyoto Protocol came into effect on 16 February 2005. This
international treaty seeks to implement the objectives of the United Nations Framework
Convention on Climate Change (UNFCCC) to combat global warming by decreasing
greenhouse gas concentrations in the atmosphere.
The major greenhouse gases that are addressed are :
● Carbon dioxide (CO2)
● Methane (CH4)
● Nitrous oxide (N2O)
● Hydrofluorocarbons (HFCs)
● Perfluorocarbons (PFCs)
● Sulphur hexafluoride (SF6)
The Kyoto Protocol extends the UNFCCC and makes members commit to a specific
reduction target. The text of the protocol was unanimously adopted 11 December 1997. It
entered into force in February 2005. Currently, there are 192 parties to the protocol.

The Vienna Convention for the Protection of the Ozone Layer is a multilateral
environmental agreement signed in 1985 that provided frameworks for international
reductions in the production of chlorofluorocarbons due to their contribution to the
destruction of the ozone layer, resulting in an increased threat of skin cancer.
Montreal Protocol on Substances that Deplete the Ozone Layer: (1987)
In the two years that followed the creation of the Vienna Convention there was incredible
progress in reaching a global scientific consensus on the nature of the threat from ozone loss.
Agreement was also reached on other outstanding scientific and technological matters. As of
September 16, 2009, it has been signed and ratified by 196 countries, achieving universal
participation.
Under the Montreal Protocol, 95% of the production and consumption of all ozone-depleting
substances have been phased-out. Global observation have verified that atmospheric levels of
key ozone-depleting substances are going down and it is believed that with implementation of
the Montreal Protocol's provisions, the ozone layer should return to its pre-1980 levels
by 2050 to 2075.
Global Environment Facility (GEF) is a multilateral financial mechanism that provides
grants to developing countries for projects that benefit the global environment and promote
sustainable livelihoods in local communities. GEF was established during the Rio Earth
Summit of 1992. The GEF is jointly managed by the United Nations Development
Programme (UNDP), the World Bank and the United Nations Environment Programme
(UNEP). The financial mechanism was established to help tackle our planet’s most pressing
environmental problems. It provides funds to the developing countries and transition
economies for projects related to climate change, Biodiversity, ozone layer.
United Nations Convention on Biological Diversity: informally known as the biodiversity
convention is a multilateral treaty opened for signature at the Earth Summit in Rio De
Janeiro in 1992. It is a key document regarding sustainable development.
● 198 countries are a party to the CBD.
● India is also a party to the Convention. The convention is legally binding on its signatories.
● Conference of Parties (COP) is the governing body of the convention. It is comprised of the
governments that have ratified the treaty.
Three main goals of the convention:
 Conservation of Biological Diversity
 Sustainable use of the components of the biodiversity
 Fair and equitable sharing of benefits arising from the genetic resources
The idea of CBD is to develop national strategies for the conservation and sustainable use of
biological diversity. The convention affirms the following:
1. Intrinsic value of biodiversity
2. Biodiversity conservation as common concern of humankind
3. Sovereign rights of States over their biological resources
4. Responsibility of States to conserve and sustainable use their biodiversity
5. Precautionary approach towards biodiversity conservation
6. Vital role of local communities and women
7. Need for provision of new and additional financial resources and access to technologies for
developing countries to address biodiversity loss.
All the genetic resources, species and ecosystems are covered in the agreement. Traditional
conservation efforts are linked to the economic goal of using biological resources sustainably.
Set of principles are laid out for equitable and fair sharing of the benefits that arise out of the
use of genetic resources, specifically those destined for commercial use. It also covers the
rapidly expanding field of biotechnology through its Cartagena Protocol on Biosafety,
addressing technology development and transfer, benefit-sharing and biosafety issues.
Causes of Biodiversity Loss:
 Pollution
 Climate change
 Habitat destruction
 Invasive Species
 Deforestation
 Over exploitation of species.
Protection of Genetic Variety and Protection of Ecosystem is a part of this Convention on
Biological Diversity,1992
India is a signatory to various International Treaties:
 India is a party to the Ramsar Convention on Wetlands. India has 26 Internationally
acknowledged Ramsar sites.
 India Is a party to the World Earth Summit.
 India has so many Environmental protection laws established In accordance to various
other treaties signed by them.
 India is a part of all the International Air and Sea regulation conventions.
 India Is fully committed to the Kyoto protocol.
 Some of major environmental acts in India are :
i. The Environment (Protection) Act,1986
ii. The Biological Diversity Act 2002 and Biological Diversity Rules,2004
iii. The Water (Prevention and control of Pollution) Act,1974
iv. Air (Prevention and Control of Pollution) Act, 1981
v. The Public Liability Insurance Act and Rules 1991 and Amendment, 1992
vi. The National Environmental Tribunal Act,1995, Amendment 2010
vii. National Green Tribunal Act, 2010
viii. The National Environment Appellate Authority Act,1997
ix. The Biomedical waste (Management and Handling) Rules,1998
x. The Environment (Siting for Industrial Projects) Rules, 1999
xi. The Municipal Solid Wastes (Management and Handling) Rules, 2000
xii. The Ozone Depleting Substances (Regulation and Control) Rules, 2000
xiii. The Batteries (Management and Handling) Rules, 2001
xiv. The Noise Pollution (Regulation and control) (Amendment) Rules, 2010
Judicial Activism:
Judicial Activism in India means that the Supreme Court and the High Courts have the power
to rule those laws that contradict or are incompatible with one or more constitutional
provisions that are unconstitutional and invalid.
The Legal Framework for Environmental Protection in India:
The Constitution of India recognizes the right to a healthy environment as a fundamental
right under Article 21, which guarantees the right to life and personal liberty. The
Constitution also places a duty on the State to protect and improve the environment under
Article 48A and 51A(g).
In India there is a provision of filing a Writ under the Article 32 and 226 of the Indian
Constitution. A public Interest Litigation can be Filed using the above-mentioned articles, if
there is any fundamental right violated. The right to safe environment is a fundamental right.
Role of Public Interest Litigation in Environmental Protection:
Public Interest Litigation is a legal mechanism that allows any person, organization, or group
to approach the court on behalf of the public or for the protection of public interest. PIL in
environmental law has been instrumental in promoting environmental protection and
conservation in India.
PIL can be filed against both public and private entities who are violating environmental laws
or causing harm to the environment. PIL is often used to address issues related to
environmental protection, pollution control, conservation of natural resources, and
sustainable development.
PIL helps to promote transparency and accountability in governance by holding public
authorities responsible for their actions or inactions regarding environmental protection. PIL
in environmental law has also helped to create awareness among citizens about
environmental issues and their rights. It has empowered people to take action against
environmental violations and seek redressal from the judiciary.
The Constitution of India under part III guarantees fundamental rights which are
essential for the development of every individual and to which a person is inherently entitled
by virtue of being human alone. According to Article 21 of the Constitution, “no person
shall be deprived of his life or personal liberty except according to procedure
established by law” (right to Life).The concept of the right to life has been broadened
through the judicial pronouncements. While resolving cases relating to the environment, the
judiciary considered the right to clean or the good environment as fundamental to life and
upheld as a fundamental right.
The Supreme Court, which has interpreted the right of life to mean the right to live a civilized
life and it also includes the right to clean environment. Following are some important
judicial pronouncements by the apex court of India:
Subhash Kumar v. State of Bihar: In the instant case, the Court observed that ‘right to life
guaranteed by article 21 includes the right of enjoyment of pollution-free water and air
for full enjoyment of life.’
Rural Litigation and Environment Kendra, Dehradun vs. State of Uttar Pradesh:
The representatives of the Rural Litigation and Entitlement Kendra, Dehradun wrote to the
Supreme Court alleging that illegal limestone mining in the Mussorie-Dehradun region was
causing damage to the fragile eco-systems in the area. The Court treated this letter as a
public interest petition under Article 32 of the Constitution. The court set up various
committees to investigate. Therefore, the Court ordered the closure of a number of
limestone quarries. Although the Court did not mention any violation of fundamental
right explicitly it impliedly admitted the adverse effects to the life of people and
involved a violation of Article 21 of the Constitution.
M.C. Mehta vs. Union of India (Vehicular Pollution Case):
A matter regarding the vehicular pollution in Delhi city. The Apex court again confirmed
right to a healthy environment as a basic human right and stated that the right to clean air also
stemmed from Article 21. This case has served to be a major landmark because of which
lead-free petrol supply was introduced in Delhi. There was a complete phasing out old
commercial vehicles more than 5 years old as directed by the courts.

Murli S. Deora vs. Union of India:

It was contended that smoking is injurious to health and may affect the health of smokers
but there is no reason that health of passive smokers should also be injuriously affected.
So, till the statutory provision is made and implemented by the legislative enactment, it was
held that it would be in the interest of the citizens to prohibit smoking in public places.
Life is not construed in Article 21 of the Constitution merely the physical act of
breathing. It does not connote mere animal existence. It has a much wider meaning
which includes right to live with human dignity, right to livelihood, right to health, right
to pollution free air, etc. Right to life is fundamental to our very existence without which
we cannot live as human being.
Vellore Citizens’ Welfare Forum vs. Union of India: The Supreme Court allowed a
public-spirited social organization to represent the residents of Vellore to protect their health.
In this case, the tanneries located around the Palar River in Vellore, Tamil Nadu, were found
to be discharging toxic chemicals into the river, endangering the health of the residents. As a
result, the Court ordered the tanneries to close their businesses.
India vs. KKR Majestic Colony Welfare Association: The Supreme Court ruled that noise
pollution amounts to a violation of Article 21 of the Constitution.