Comprehension
Today, in the year 2025, we have been experiencing the drastic consequences of large scale destruction of environment on human lives in the capital city of our country and in many other cities. At least for a span of two months every year, the residents of Delhi suffocate due to air pollution. The AQI level is either dangerous or very dangerous. They suffer in their health. The other leading cities are not far behind. The air and water pollution in the cities is ever increasing. Therefore, coming out with measures such as the 2021 Official Memorandum is violative of fundamental rights of all persons guaranteed under Article 21 to live in a pollution free environment. It also infringes the right to health guaranteed under Article 21 of the Constitution.
The 2021 OM talks about the concept of development. Can there be development at the cost of environment? Conservation of environment and its improvement is an essential part of the concept of development. Therefore, going out of the way by issuing such OMs to protect those who have caused harm to the environment has to be deprecated by the Courts which are under a constitutional and statutory mandate to uphold the fundamental right under Article 21 and to protect the environment. In fact, the Courts should comedown heavily on such attempts. As stated earlier, the 2021 OM deals with project proponents who were fully aware of the EIA notification and who have taken conscious risk to flout the EIA notification and go ahead with the construction/continuation/expansion of projects. They have shown scant respect to the law and their duty to protect the environment. Apart from violation of Article 21, such action is completely arbitrary which is violative article 14 of the Constitution of India, besides being violative of the 1986 Act and the EIA notification.
(Extracted with edits from Vanashakti v. Union of India, 2025 INSC 718)
Question: 1
What was the central controversy in the petition, Vanashakti v. Union of India?
What was the central controversy in the petition, Vanashakti v. Union of India?
Show Hint
"Ex post facto" means "after the fact." In environmental law, it refers to the illegal practice of granting clearance to a project that has already started without the legally required prior approval.
Updated On: Dec 9, 2025
- The constitutional validity of the Environment (Protection) Act, 1986.
- The determination of pollution load standards for Category 'B' projects.
- The ex post facto grant of Environmental Clearance (EC).
- The delegation of powers to the State Environment Impact Assessment Authority (SEIAA).
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The Correct Option is C
Solution and Explanation
Step 1: Understanding the Question:
The question asks to identify the main issue or controversy in the case from which the passage is extracted.
Step 2: Detailed Explanation:
The passage heavily criticizes an "Official Memorandum" (OM) for protecting "those who have caused harm to the environment" and who have "flouted the EIA notification". It talks about project proponents who went ahead with construction without prior clearance, taking a "conscious risk". The legal term for granting clearance after the project has already started or been completed is "ex post facto" clearance. The passage's strong condemnation of this practice indicates that the validity of such retrospective clearances was the central issue.
- Option (A) is incorrect as the validity of the parent Act was not the issue.
- Option (B) is too specific and not the main theme of the passage.
- Option (D) deals with delegation, which is not mentioned.
- Option (C) perfectly captures the essence of the controversy described: granting environmental clearance after the fact to projects that violated the law by not obtaining it beforehand.
Step 3: Final Answer:
The central controversy in the petition was the grant of ex post facto Environmental Clearance.
The question asks to identify the main issue or controversy in the case from which the passage is extracted.
Step 2: Detailed Explanation:
The passage heavily criticizes an "Official Memorandum" (OM) for protecting "those who have caused harm to the environment" and who have "flouted the EIA notification". It talks about project proponents who went ahead with construction without prior clearance, taking a "conscious risk". The legal term for granting clearance after the project has already started or been completed is "ex post facto" clearance. The passage's strong condemnation of this practice indicates that the validity of such retrospective clearances was the central issue.
- Option (A) is incorrect as the validity of the parent Act was not the issue.
- Option (B) is too specific and not the main theme of the passage.
- Option (D) deals with delegation, which is not mentioned.
- Option (C) perfectly captures the essence of the controversy described: granting environmental clearance after the fact to projects that violated the law by not obtaining it beforehand.
Step 3: Final Answer:
The central controversy in the petition was the grant of ex post facto Environmental Clearance.
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Question: 2
The Environment Impact Assessment (EIA) Notification, 2006, which mandates prior EC, was issued by the Central Government under which primary legislation?
The Environment Impact Assessment (EIA) Notification, 2006, which mandates prior EC, was issued by the Central Government under which primary legislation?
Show Hint
Remember that the Environment (Protection) Act, 1986, is the key "umbrella" law in India for environmental regulation, under which many important rules and notifications (like EIA, Coastal Regulation Zone rules, etc.) are framed.
Updated On: Dec 9, 2025
- The Wild Life (Protection) Act, 1972.
- The Biological Diversity Act, 2002.
- The Environment (Protection) Act, 1986.
- The National Green Tribunal Act, 2010.
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The Correct Option is C
Solution and Explanation
Step 1: Understanding the Question:
The question asks for the parent or primary Act under which the EIA Notification, 2006 was issued.
Step 2: Detailed Explanation:
The Environment (Protection) Act, 1986 (EPA) is an "umbrella" legislation that gives wide-ranging powers to the Central Government to protect and improve the environment. Section 3 of the EPA empowers the Central Government to take all such measures as it deems necessary or expedient for the purpose of protecting and improving the quality of the environment. Under this power, the government issues various rules and notifications. The EIA Notification, which mandates prior environmental clearance for certain projects, is one such notification issued under the authority of the EPA, 1986.
- The other acts listed have different, more specific purposes: Wildlife Protection, Biodiversity, and establishing the NGT. The EPA is the broad framework legislation for environmental regulation.
Step 3: Final Answer:
The EIA Notification, 2006 was issued under the Environment (Protection) Act, 1986.
The question asks for the parent or primary Act under which the EIA Notification, 2006 was issued.
Step 2: Detailed Explanation:
The Environment (Protection) Act, 1986 (EPA) is an "umbrella" legislation that gives wide-ranging powers to the Central Government to protect and improve the environment. Section 3 of the EPA empowers the Central Government to take all such measures as it deems necessary or expedient for the purpose of protecting and improving the quality of the environment. Under this power, the government issues various rules and notifications. The EIA Notification, which mandates prior environmental clearance for certain projects, is one such notification issued under the authority of the EPA, 1986.
- The other acts listed have different, more specific purposes: Wildlife Protection, Biodiversity, and establishing the NGT. The EPA is the broad framework legislation for environmental regulation.
Step 3: Final Answer:
The EIA Notification, 2006 was issued under the Environment (Protection) Act, 1986.
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Question: 3
The Supreme Court reiterated a concluded finding that the concept of ex post facto or retrospective Environmental Clearance (EC) is:
The Supreme Court reiterated a concluded finding that the concept of ex post facto or retrospective Environmental Clearance (EC) is:
Show Hint
The core principle of EIA is "prevention is better than cure." Ex post facto clearance attempts to "cure" a violation after the fact, which undermines the entire preventative framework of environmental law.
Updated On: Dec 9, 2025
- Detrimental to the environment but permissible under Article 142 of the Constitution.
- Completely alien to environmental jurisprudence and the EIA notification.
- A necessary measure to bring defaulting entities into regulatory compliance.
- A valid administrative decision protected by Section 3 of the 1986 Act.
- Freedom is a notoriously complex and contested philosophical notion, and I won’t pretend to settle any of the big controversies it raises.
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The Correct Option is B
Solution and Explanation
Step 1: Understanding the Question:
The question asks for the Supreme Court's established view on the legality and validity of ex post facto Environmental Clearance.
Step 2: Detailed Explanation:
The Supreme Court of India, in several landmark judgments, including Alembic Pharmaceuticals Ltd. v. Rohit Prajapati, has held that the concept of ex post facto EC is fundamentally contrary to environmental law. The entire purpose of an Environmental Impact Assessment is to predict and evaluate the potential environmental impacts of a project before any irreversible damage is done. Granting clearance after the project is already underway defeats this purpose. The court has described it as a "fait accompli" situation where the regulator is left with little choice. The passage reflects this view by stating that such actions are "violative of the 1986 Act and the EIA notification".
- (A) is incorrect. While the court has used Article 142 to balance equities, it has never held that ex post facto clearance is a permissible norm.
- (C) reflects the argument of the government/project proponents, not the finding of the court. The court has rejected this justification.
- (D) is incorrect as the court has found it to be contrary to the spirit and letter of the Act.
- (B) accurately captures the court's consistent position that this practice is alien to the principles of environmental law.
Step 3: Final Answer:
The Supreme Court has held that the concept of ex post facto EC is completely alien to environmental jurisprudence.
The question asks for the Supreme Court's established view on the legality and validity of ex post facto Environmental Clearance.
Step 2: Detailed Explanation:
The Supreme Court of India, in several landmark judgments, including Alembic Pharmaceuticals Ltd. v. Rohit Prajapati, has held that the concept of ex post facto EC is fundamentally contrary to environmental law. The entire purpose of an Environmental Impact Assessment is to predict and evaluate the potential environmental impacts of a project before any irreversible damage is done. Granting clearance after the project is already underway defeats this purpose. The court has described it as a "fait accompli" situation where the regulator is left with little choice. The passage reflects this view by stating that such actions are "violative of the 1986 Act and the EIA notification".
- (A) is incorrect. While the court has used Article 142 to balance equities, it has never held that ex post facto clearance is a permissible norm.
- (C) reflects the argument of the government/project proponents, not the finding of the court. The court has rejected this justification.
- (D) is incorrect as the court has found it to be contrary to the spirit and letter of the Act.
- (B) accurately captures the court's consistent position that this practice is alien to the principles of environmental law.
Step 3: Final Answer:
The Supreme Court has held that the concept of ex post facto EC is completely alien to environmental jurisprudence.
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Question: 4
The EIA Notification 2006, mandates that prior Environmental Clearance (EC) must be obtained at what stage of a project?
The EIA Notification 2006, mandates that prior Environmental Clearance (EC) must be obtained at what stage of a project?
Show Hint
For EIA, "prior" means right at the beginning. No digging, no clearing, no construction until the Environmental Clearance certificate is in hand.
Updated On: Dec 9, 2025
- Before commencing operations or processes.
- Within six months of a project's completion.
- After the public hearing but before the final appraisal.
- Before any construction work, or preparation of land is started on the project.
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The Correct Option is D
Solution and Explanation
Step 1: Understanding the Question:
The question asks for the specific stage at which prior Environmental Clearance is legally required under the EIA Notification, 2006.
Step 2: Detailed Explanation:
The EIA Notification, 2006, is very clear about the "prior" nature of the clearance. The term "prior" means before any activity related to the project begins on the ground. This includes not just the main construction or operation but also preparatory work like site clearance, levelling of land, etc. The idea is to assess the environmental impact before any irreversible change is made to the site.
- (A) is too late; much of the environmental damage from construction would have already occurred by the time operations commence.
- (B) is ex post facto and illegal.
- (C) is a stage within the EC process, not the point before which EC must be obtained.
- (D) correctly identifies the earliest stage. The clearance is required before any physical work starts on the project site.
Step 3: Final Answer:
Prior EC must be obtained before any construction work, or preparation of land is started on the project.
The question asks for the specific stage at which prior Environmental Clearance is legally required under the EIA Notification, 2006.
Step 2: Detailed Explanation:
The EIA Notification, 2006, is very clear about the "prior" nature of the clearance. The term "prior" means before any activity related to the project begins on the ground. This includes not just the main construction or operation but also preparatory work like site clearance, levelling of land, etc. The idea is to assess the environmental impact before any irreversible change is made to the site.
- (A) is too late; much of the environmental damage from construction would have already occurred by the time operations commence.
- (B) is ex post facto and illegal.
- (C) is a stage within the EC process, not the point before which EC must be obtained.
- (D) correctly identifies the earliest stage. The clearance is required before any physical work starts on the project site.
Step 3: Final Answer:
Prior EC must be obtained before any construction work, or preparation of land is started on the project.
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Question: 5
Allowing for ex post facto clearance was held to be contrary to which two fundamental principles of environmental jurisprudence?
Allowing for ex post facto clearance was held to be contrary to which two fundamental principles of environmental jurisprudence?
Show Hint
Precautionary Principle = Look before you leap. Sustainable Development = Don't saw off the branch you're sitting on. Ex post facto clearance = Leaping without looking and then checking if the branch is still there.
Updated On: Dec 9, 2025
- Doctrine of Necessity and Principle of Stare Decisis.
- Polluter Pays Principle and Public Trust Doctrine.
- Precautionary Principle and Sustainable Development.
- Doctrine of Sovereign immunity and doctrine of Public Trust
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The Correct Option is C
Solution and Explanation
Step 1: Understanding the Question:
The question asks to identify two core principles of environmental law that are violated by the practice of granting ex post facto clearance.
Step 2: Detailed Explanation:
Let's analyze the principles:
- Precautionary Principle: This principle states that where there are threats of serious or irreversible damage, lack of full scientific certainty shall not be used as a reason for postponing cost-effective measures to prevent environmental degradation. The EIA process is a classic application of this principle – you assess the risk *before* you act. Ex post facto clearance completely violates this by allowing the action to proceed without prior assessment of risk.
- Sustainable Development: This principle seeks to balance development and environmental protection. It ensures that development meets the needs of the present without compromising the ability of future generations to meet their own needs. A key component of sustainable development is the integration of environmental considerations at the earliest stages of decision-making, which is what the EIA process does. Ex post facto clearance prioritizes development first and considers the environment later (if at all), which is the antithesis of sustainable development.
- Polluter Pays Principle applies after pollution has occurred. While related, it's not the primary principle violated by the *process* of ex post facto clearance itself.
- Public Trust Doctrine relates to the government's duty to protect natural resources for the public. While violated, the most directly offended principles are precautionary and sustainable development.
- The other options (A and D) list principles not as directly relevant to the procedural violation inherent in ex post facto clearance.
Step 3: Final Answer:
Allowing for ex post facto clearance is fundamentally contrary to the Precautionary Principle and the principle of Sustainable Development.
The question asks to identify two core principles of environmental law that are violated by the practice of granting ex post facto clearance.
Step 2: Detailed Explanation:
Let's analyze the principles:
- Precautionary Principle: This principle states that where there are threats of serious or irreversible damage, lack of full scientific certainty shall not be used as a reason for postponing cost-effective measures to prevent environmental degradation. The EIA process is a classic application of this principle – you assess the risk *before* you act. Ex post facto clearance completely violates this by allowing the action to proceed without prior assessment of risk.
- Sustainable Development: This principle seeks to balance development and environmental protection. It ensures that development meets the needs of the present without compromising the ability of future generations to meet their own needs. A key component of sustainable development is the integration of environmental considerations at the earliest stages of decision-making, which is what the EIA process does. Ex post facto clearance prioritizes development first and considers the environment later (if at all), which is the antithesis of sustainable development.
- Polluter Pays Principle applies after pollution has occurred. While related, it's not the primary principle violated by the *process* of ex post facto clearance itself.
- Public Trust Doctrine relates to the government's duty to protect natural resources for the public. While violated, the most directly offended principles are precautionary and sustainable development.
- The other options (A and D) list principles not as directly relevant to the procedural violation inherent in ex post facto clearance.
Step 3: Final Answer:
Allowing for ex post facto clearance is fundamentally contrary to the Precautionary Principle and the principle of Sustainable Development.
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Top CLAT PG Questions
- Our society is governed by the Constitution. The values of constitutional morality are a non-derogable entitlement. Notions of “purity and pollution”, which stigmatise individuals, can have no place in a constitutional regime. Regarding menstruation as polluting or impure, and worse still, imposing exclusionary disabilities on the basis of menstrual status, is against the dignity of women which is guaranteed by the Constitution. Practices which legitimise menstrual taboos, due to notions of “purity and pollution”, limit the ability of menstruating women to attain the freedom of movement, the right to education and the right of entry to places of worship and, eventually, their access to the public sphere. Women have a right to control their own bodies. The menstrual status of a woman is an attribute of her privacy and person. Women have a constitutional entitlement that their biological processes must be free from social and religious practices, which enforce segregation and exclusion. These practices result in humiliation and a violation of dignity. Article 17 prohibits the practice of “untouchability”, which is based on notions of purity and impurity, “in any form”. Article 17 certainly applies to untouchability practices in relation to lower castes, but it will also apply to the systemic humiliation, exclusion and subjugation faced by women. Prejudice against women based on notions of impurity and pollution associated with menstruation is a symbol of exclusion. The social exclusion of women, based on menstrual status, is but a form of untouchability which is an anathema to constitutional values. As an expression of the anti-exclusion principle, Article 17 cannot be read to exclude women against whom social exclusion of the worst kind has been practised and legitimised on notions of purity and pollution. Article 17 cannot be read in a restricted manner. But even if Article 17 were to be read to reflect a particular form of untouchability, that Article will not exhaust the guarantee against other forms of social exclusion. The guarantee against social exclusion would emanate from other provisions of Part III, including Articles 15(2) and 21. Exclusion of women between the age group of ten and fifty, based on their menstrual status, from entering the temple in Sabarimala can have no place in a constitutional order founded on liberty and dignity.
[Extracted from Indian Young Lawyers Association v. State of Kerala, (2019) 11 SCC 1 (hereafter IYLA)] - An Ordinance which is promulgated by the Governor has (as clause 2 of Article 213 provides) the same force and effect as an Act of the legislature of the State assented to by the Governor. However - and this is a matter of crucial importance – clause 2 goes on to stipulate in the same vein significant constitutional conditions. These conditions have to be fulfilled before the ‘force and effect’ fiction comes into being. These conditions are prefaced by the expression “but every such Ordinance” which means that the constitutional fiction is subject to what is stipulated in sub-clauses (a) and (b). Sub-clause (a) provides that the Ordinance “shall be laid before the legislative assembly of the state” or before both the Houses in the case of a bi-cameral legislature. Is the requirement of laying an Ordinance before the state legislature mandatory? There can be no manner of doubt that it is. The expression “shall be laid” is a positive mandate which brooks no exceptions. That the word ‘shall’ in sub-clause (a) of clause 2 of Article 213 is mandatory, emerges from reading the provision in its entirety. As we have noted earlier, an Ordinance can be promulgated only when the legislature is not in session. Upon the completion of six weeks of the reassembling of the legislature, an Ordinance “shall cease to operate”.
Article 213(2)(a) postulates that an ordinance would cease to operate upon the expiry of a period of six weeks of the reassembly of the legislature. The Oxford English dictionary defines the expression “cease” as : “to stop, give over, discontinue, desist; to come to the end.” P Ramanatha Aiyar’s, The Major Law Lexicon defines the expression “cease” to mean “discontinue or put an end to”. Justice C K Thakker’s Encyclopaedic Law Lexicon defines the word “cease” as meaning: “to put an end to; to stop, to terminate or to discontinue”. The expression has been defined in similar terms in Black’s Law Dictionary.
The expression “cease to operate” in Article 213(2)(a) is attracted in two situations. The first is where a period of six weeks has expired since the reassembling of the legislature. The second situation is where a resolution has been passed by the legislature disapproving of an ordinance. Apart from these two situations that are contemplated by sub-clause (a), sub-clause (b) contemplates that an ordinance may be withdrawn at any time by the Governor. Upon its withdrawal the ordinance would cease to operate as well.
[Extracts from the judgment of majority judgment in Krishna Kumar Singh v. State of Bihar, Civil Appeal No. 5875 of 1994, decided on January 2, 2017 hereafter ‘KK Singh’] - The other material which prompted the High Court to reach the conclusion that the subsoil/minerals vest in the State is … recitals of a patta which ….. states that if minerals are found in the property covered by the patta and if the pattadar exploits those minerals, the pattadar is liable for a separate tax in addition to the tax shown in the patta and …. certain standing orders of the Collector of Malabar which provided for collection of seigniorage fee in the event of the mining operation being carried on. We are of the clear opinion that the recitals in the patta or the Collector’s standing order that the exploitation of mineral wealth in the patta land would attract additional tax, in our opinion, cannot in any way indicate the ownership of the State in the minerals. The power to tax is a necessary incident of sovereign authority (imperium) but not an incident of proprietary rights (dominium). Proprietary right is a compendium of rights consisting of various constituent, rights. If a person has only a share in the produce of some property, it can never be said that such property vests in such a person. In the instant case, the State asserted its ‘right’ to demand a share in the ‘produce of the minerals worked’ though the expression employed is right – it is in fact the Sovereign authority which is asserted. From the language of the BSO No.10 it is clear that such right to demand the share could be exercised only when the pattadar or somebody claiming through the pattadar, extracts/works the minerals – the authority of the State to collect money on the happening of an event – such a demand is more in the nature of an excise duty/a tax. The assertion of authority to collect a duty or tax is in the realm of the sovereign authority, but not a proprietary right….
The only other submission which we are required to deal with before we part with this matter is the argument of the learned counsel for the State that in view of the scheme of the Mines and Minerals (Development and Regulation) Act, 1957 (hereafter ‘MMDRA’) which prohibits under Section 4 the carrying on of any mining activity in this country except in accordance with the permit, licence or mining lease as the case may be, granted under the Act, the appellants cannot claim any proprietary right in the sub-soil…
[Extract from the judgment in Thressiamma Jacob v. Dept. of Mining & Geology, (2013) 9 SCC 725] (hereafter ‘T Jacob’) - A nationwide lockdown was declared by the Central Government from 24 March 2020 to prevent the spread of the CoVID-19 pandemic. Economic activity came to a grinding halt. The lockdown was extended on several occasions, among them for the second time on 14 April 2020. On 17 April 2020, the Labour and Employment Department of the State of Gujarat issued a notification under Section 5 of the Factories Act to exempt all factories registered under the Act “from various provisions relating to weekly hours, daily hours, intervals for rest etc. for adult workers” under Sections 51, 54, 55 and 56. The stated aim of the notification was to provide “certain relaxations for industrial and commercial activities” from 20 April 2020 till 19 July 2020.
Section 5 of the Factories Act provides that in a public emergency, the State Government can exempt any factory or class or description of factories from all or any of the provisions of the Act, except Section 67. Section 5 is extracted below: “5. Power to exempt during public emergency. — In any case of public emergency the State Government may, by notification in the Official Gazette, exempt any factory or class or description of factories from all or any of the provisions of this Act except section 67 for such period and subject to such conditions as it may think fit: Provided that no such notification shall be made for a period exceeding three months at a time. Explanation.— For the purposes of this section ‘public emergency’ means a grave emergency whereby the security of India or of any part of the territory thereof is threatened, whether by war or external aggression or internal disturbance.” (emphasis supplied) The notification in its relevant part is extracted below:
“... NOW, THEREFORE, in exercise of the powers conferred by Section 5 of the Factories Act, 1948, the ‘Factories Act’ PART B Government of Gujarat hereby directs that all the factories registered under the Factories Act, 1948 shall be exempted from various provisions relating to weekly hours, daily hours, intervals for rest etc. of adult workers under section 51, section 54, and section 55 and section 56 with the following conditions from 20th April till 19th July 2020, –
(1) No adult worker shall be allowed or required to work in a factory for more than twelve hours in any day and Seventy Two hours in any week.
(2) The Periods of work of adult workers in a factory each day shall be so fixed that no period shall exceed six hours and that no worker shall work for more than six hours before he has had an interval of rest of at least half an hour.
(3) No Female workers shall be allowed or required to work in a factory between 7:00 PM to 6:00 AM.
(4) Wages shall be in a proportion of the existing wages (e.g. If wages for eight hours are 80 Rupees, then proportionate wages for twelve hours will be 120 Rupees).”
[Extract from judgment of the Supreme Court in Gujarat Mazdoor Sabha v. The State of Gujarat decided on 1 October, 2020, (hereafter ‘GMS’)] - In view of various counter claims regarding registration or non-registration, what is necessary is only that the information given to the police must disclose the commission of a cognizable offence. In such a situation, registration of a FIR is mandatory. However, if no cognizable offence is made out in the information given, then the FIR need not be registered immediately and perhaps the police can conduct a sort of preliminary verification or inquiry for the limited purpose of ascertaining as to whether a cognizable offence has been committed. But, if the information given clearly mentions the commission of a cognizable offence, there is no other option but to register a FIR forthwith. Other considerations are not relevant at the stage of registration of FIR, such as, whether the information is falsely given, whether the information is genuine, whether the information is credible etc. These are the issues that have to be verified during the investigation of the FIR. At the stage of registration of a FIR, what is to be seen is merely whether the information given ex facie discloses the commission of a cognizable offence. If, after investigation, the information given is found to be false, there is always an option to prosecute the complainant for filing a false FIR.
[Excerpted from the judgment delivered by Sathasivam, C.J.I. in Lalita Kumari v. State of Uttar Pradesh, (2014) 2 SCC 1 (hereafter ‘Lalita Kumari’)]
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