ENVIRONMENTAL LAW-II

ENVIRONMENTAL JUSTICE DELIVERY

SUBMITTED BY:
SIDDHI KUDALKAR
I.D. NO: 2178

IV YEAR, XI TRIMESTER
B.A., LL.B (HONS.)

DATE OF SUBMISSION: JANUARY 8, 2018

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ToC

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Index of Authorities
1. Cases:

 Dahanu Taluka Environment Protection Group and others v. Bombay Suburban Electricity
Supply Company Limited and others 1991 (2) SCC 542 (Supreme Court of India).
 Indian Council far Enviro-Legal Action v. Union of India (1996) 5 SCC 28 (Supreme
Court of India).
 L.K. Koolwal v. State of Rajasthan, AIR 1988 Raj 2 (Rajasthan High Court).
 M.C. Mehta v. Union of India, 1987 AIR 1086 (Supreme Court of India).
 Narmada Bachao Andolan v. Union of India (2010) 10 SCC 664 (Supreme Court of India).
Ratlam Municipality v. Vardhichand and Others AIR 1980 SC 1629 (Supreme Court of
India).
 Rural Litigation and Entitlement Kendra v. State of U.P. 1985 AIR 652 (Supreme Court of
India).
 S. Jagnnath v. Union of India 1997 (2) SCC 87 (Supreme Court of India).
 Subhash Kumar v. State of Bihar 1991 AIR 420 (Supreme Court of India).
 T. Damodhar Rao v. Special Officer, Municipal Corporation. Hyderabad, AIR 1987 AP
171 (Andhra Pradesh High Court).
 T. N. Godavarman v. Union of India, AIR 1997 SC 122 (Supreme Court of India).
 Tehri Bandh Virodhi Sangarsh Samiti and Others v. State of Uttar Pradesh and Others,
1992 Supp (1) SCC 45 (Supreme Court of India).

2. Statutes:
 Environment Protection Act, 1986
 Factories Act, 1958.

3. Constitutions:
 The Constitution of India, 1950.

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Research Methodology

Aim
In writing this paper, the aim of the researcher is to understand the regime of environmental justice
delivery system within constitutional framework.

Objective
The broader aim of the researcher, in writing this paper, is to unpack the ideals and policy that
motivated the concept of green governance and effective role by judiciary in laying the
groundwork of machinery to protect environmental rights of people.

Research Questions
This researcher attempts to answer the following research questions in this paper:
1. How do we understand the environmental justice delivery?
2. What are the constitutional provisions dealing with environmental protection?
3. What are the important doctrines evolved by the judiciary
4. What is the impact of the judicial activism in the arena of environmental jurisprudence

Scope and Limitations

The nature of this project being collaborative, this researcher and his co-researcher have chosen to
cover different aspects of the ‘Environmental Justice Delivery’ in India, with a view to ensuring
that reading this collaborative project provides a holistic understanding of the subject. In this
project, this researcher focuses on the constitutional framework, judicial doctrines and processes
evolved by the Supreme Court in order to contribute to environmental jurisprudence in India.

Sources
Both primary and secondary sources have been relied on by the researcher.

Style of Writing
This researcher has adopted a combination of the analytical and descriptive styles of writing.

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Mode of Citation
The NLS Guide to Uniform Legal Citation has been followed in this paper.

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Introduction
Environmental justice delivery is a legal and a constitutional framework laying down the
foundation of a platform to deal with violations of rights of the citizens or persons on the territory
caused by the breakdown of environmental protection machinery.1 The concept of environmental
protection is not new to Indian subcontinent. Kautilya’s Arthshastra provides with in depth
analysis of measures to be taken by the King in order to deal with problems associated with
environmental degradation. Various kings in the history of Indian subcontinent have provided with
measures to protect wild life and possible hard to the environment. During the colonial times this
idea of environmental protection was overpowered by capitalistic attitude and treatment towards
exploitation of colonial Indian land. This was fuelled by increased industrialization of colonies.
However, at the time of framing of the Constitution, pre-colonial historical background of
environmental justice delivery was preserved and the environmental philosophy was reflected in
the Constitution of India.

In addition to the explicit statutes made by the Parliament and respective state governments as per
the subject division in Part VII of the Constitution. The Directive Principles contained in Part IV
(Article 37 to 51) of the Constitution, though not justiciable per se are of primary importance when
it comes to policy making and interpretation of existing laws and the Constitution. Article 51
prominently deals with international law and international relation, inter alia, provides that the
“state shall endeavor to foster respect for international law and treaty obligations”. However, it
seems that in environmental cases, Article 51 has not been put to the use by the Courts in the same
manner. Here, the courts have invoked Article 48-A (duty of the state to protect environment) to
develop a fundamental right to environment as part of the right to life under Article 21.

In this paper, researcher focuses on the Constitutional provisions dealing with the cure for the
environmental justice violations and its link to the fundamental rights jurisprudence, especially
right to life. Researches researcher on the new set of rules and informal legal frameworks
developed by the judiciary in order to come up with the effective justice delivery system and to
settle the claims arising out of environmental violations. In the later part of the paper, researcher

1A. B. Abdulkadir, Issues and Challenges in the Environmental Justice Delivery System in Malasia
and Nigeria, 6 BEPRESS, UNIVERSITY OF ILORIN 321, (2012).

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also analyses the impact of such a machinery on the future environmental law jurisprudence and
its possible recognition on the international level.

Chapter I: Constitutional Framework of Environmental Justice

Indian Constitution has a division of subjects on which centre and state government can legislate
to classify separate arenas for both the governments under Part VII of the Indian Constitution
which has three legislative lists. In any of those lists there is no specific entry of subject named
‘environmental protection’. Attempts to made such an entry were futile. Currently, 74th
Amendment to the constitution added "urban forestry, protection of the environment and
promotion of ecological aspects” this subject to the state list. However, this subject is helpful and
can be interpreted only in terms of "the powers and function of municipalities”, sandy there is
nothing which allows exercise of such power at panchayat level. Legislative entries that have
relationship with environmental protection come within the ambit of the three categories of law-
making power and also under the power of states in relation to panchayats and

municipalities.2
 
 When Constitution failed to ensure that legislation takes care of the matters

relating to environmental protection, the judiciary, have been active in the protection of rights of
citizens, affecting due to the environmental hazards.3 Supreme Court has brought concept of Public
Interest Litigation in the ambit of environmental justice by drawing connections with constitutional
provisions in this regard. Additionally, Article 142 of the Constitution4 provided the Supreme
Court with considerable power to decide cases in a manner that the “complete justice could be
done". As evident from the powers conferred by the Constitution on the Supreme Court, Supreme
Court is the ultimate authority when it comes to the constitutional interpretation, thus, it has an
important role when it comes to its contribution to environmental jurisprudence and legal
processes. For instance, the fundamental right of right to life provided in Article 21 is so widely
interpreted by the Apex Court that it affects many matters.

2 Id.
3 A. Pandey, Environmental Jusice Delivery System in India: Tracing the Evolution of Green
Justice, 3 SOUTH ASIAN LAW REVIEW JOURNAL 30, (2017).
4
Article 142, Constitution of India, 1950.

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To explain this further, in Subhash Kumar v. State of Bihar5 the Court observed that:
 "Right to

live is a fundamental right under Article 21 of the Constitution6 and it includes the right of
enjoyment of pollution-free water and air for full enjoyment of life. If anything endangers or
impairs that quality of life in derogation of laws, a citizen has the right to have recourse to Article

32 of the Constitution...."7 
 While interpreting Article 21, simultaneously to the strengthening

the fundamental human rights of citizen, the Apex Court has directly or indirectly contributed a
lot to the environmental legal system of India. In number of decisions Supreme Court has amplified
the ambit of Article 21 to include right to a pollution-free atmosphere, a clean environment and
air, drinking water, hazard free food etc. are considered to be part of basic human rights and, thus,
become fundamental rights of Indian citizens. In Rural Litigation and Entitlement Kendra v. State
of U.P8, the Supreme Court based its detailed interim orders on the just understanding that
"environmental rights were to be implied into the scope of Article 21", as was stated in T.
Damodhar Rao v. Special Officer, Municipal Corporation. Hyderabad9 as well as L.K. Koolwal v.
State of Rajasthan10,

"The Court has successfully isolated specific environmental law principles upon the interpretation
of Indian statutes and the Constitution, combined with a liberal view towards ensuring social
justice and the protection of human rights. The principles have often found reflection in the
Constitution in some form, and are usually justified even when not explicitly mentioned in the

statute concerned."
 


Legal processes are technically legal battles where both the parties produce evidence and go
through the trial procedure, based on the same, applying the suitable laws judge gives “just

5
Subhash Kumar v. State of Bihar 1991 AIR 420 (Supreme Court of India).
6
Article 21, CONSTITUTION OF INDIA, 1950.
7 Supra note 3, at 37.
8
Rural Litigation and Entitlement Kendra v. State of U.P. 1985 AIR 652 (Supreme Court of
India).
9
T. Damodhar Rao v. Special Officer, Municipal Corporation. Hyderabad, AIR 1987 AP 171
(Andhra Pradesh High Court).
10
L.K. Koolwal v. State of Rajasthan, AIR 1988 Raj 2 (Rajasthan High Court).

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outcome”.11 Like any other battle, legal battles are also often very expensive and thus, beyond the
reach of ordinary people and that is one of the primary reasons why the High Courts and/or
Supreme Court were moved under Article 22612 and Article 32 of the Constitution of India13. In
some of the cases, the Courts taking into account other just considerations focused on applying
"creative reason", under the purview of "judicial activism," in order to prevent injustice, which
allows protection of right to life in its true sense.14

The interpretation of this nature is the very gist of Article 21, which has been read positively
concerning environmental requirements and enshrined in various environmental laws with a view
to design remedial measures, to prevent further pollution and to restore ecology to its normalcy.15
Four years after the Stockholm Conference, the 42nd amendment added to the Constitution of
India certain significant provisions relating to the environment. The new provisions added were
Article 48A16 and Article 51(g)17 . Forest, wildlife and population control were subjects on which
the state had exclusive power to make laws, but now the concurrent list enables both the centre
and the state to make laws on the area.

11 A. M. Slater, Environmental Justice: Lessons on Definition and Deliver, 52(6) JOURNAL OF

ENVIRONMENTAL PLANNING AND MANAGEMENT 797, 801 (2008).
12
Article 226, CONSTITUTION OF INDIA, 1950.
13
Article 142, CONSTITUTION OF INDIA, 1950.
14 Supra note 3, at 36.
15 L. Mehta, Global Environmental Justice, 54 GEOFURUM 158, 162 (2014).
16
Article 48A, CONSTITUTION OF INDIA, 1950.
17
Article 51(g), CONSTITUTION OF INDIA, 1950.

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Chapter II: Processes of Environmental Justice Delivery

• Public Interest Litigation (PIL):

With the initiatives of Justice P.N. Bhagwati and Justice V.R. Krishna Iyer, sweeping
change has been brought about in the environmental jurisprudence of India in the 1970s.
This was marked by attempts to include broader issues affecting the public at large within
the ambit. In the post-emergency period, in 1976 the Indian Supreme Court declared that
"where a wrong against community interest is done, the principle of locus standi will not
always be a pre-requisite to draw the attention of judiciary against public body for their
failure in discharging constitutional duties." Since that time the Indian approach to PIL has
extended the rules of locus standi to the point that they may be said to have ceased to
present any real obstacle to the public interest litigant. Now any citizen of India can file a
petition on behalf of any citizen or group of citizens.18

Prior to the introduction of mechanism of PIL, only remedies available were torts for the
tort of nuisance or negligence including air and water pollution which could have been
initiated by the aggrieved party only. Since the relaxation of locus standi principle in 1970s,
PIL has been used as one of the major devices, especially for the protection of environment
and resolving issues revolving around environmental justice.

Important PILs influencing Environmental Jurisprudence:

The Rural Litigation & Entitlement Kendra (RLEK) v. Union of India19 filed in 1983 was
the first PIL of its kind in India for the protection of environment. In this case of large
number of leases of lime-stone quarries which were polluting the environment, causing
ecological imbalance and health hazards were closed down despite the possible loss of
employment and investment it caused to workers and the factory owners respectively.
Similarly Vellor Citizen’s Welfare Forum filed a PIL for the same reason and Court clearly
stated that merely because tanneries bring a lot of foreign exchange does not give such

18 G. Sahu, Implications of Indian Supreme Court’s Innovations for Environmental Jurisprudence,

4 LAW, ENVIRONMENT AND DEVELOPMENT JOURNAL 34, (2008).
19
Rural Litigation and Entitlement Kendra v. State of U.P. 1985 AIR 652 (Supreme Court of
India).

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 industries right to harm the ecology, reduce quality of the environment or give rise to health
hazards. The Court ordered Central Government to take an instant action under Section
3(3) of India's Environment Protection Act, 1986 to take suitable directions.20

In M.C. Mehta v. Union of India21, the petitioner M.C.Mehta, filed a writ petition in 1985
under Article 32 of the Constitution to close down Kanpur tanneries which were
discharging effluents beyond the permissible limit and the same was upheld. In the Delhi
Vehicular Pollution case, M.C. Mehta filed another PIL suit in the Supreme Court against
the Union of India in 1985, charging that existing environmental laws obligated the
government to take steps to help reduce the pollution in Delhi in the interests of public
health. to September 30, 2001 . It emphasized that public health cannot be taken for granted
and government needs to ensure it without pleading for any further time-period, absence
of technology and infrastructure. In the Tarun Bharat Sangh, Alwar, Government of
Rajasthan issued 400 mining licenses in the protected areas of the forest without the prior
approval of Central Government and the same were declared illegal by the Court.

In Indian Council far Enviro-Legal Action v. Union of India22, the petitioner, brought the
action to stop and remedy the pollution caused by several chemical industrial plants in
Bichhri village, Udaipur District of Rajasthan. Calling them as rogue industries the Court
held that the chemical industries inflicted untold misery upon the poor, unsuspecting
villagers, de-spoiling their land, their water sources and their entire environment-all in
pursuance of their private profit and failed to comply with statutory acts for prevention and
control of pollution. Accordingly, the Court ordered the closure of all these plants

Other Side of Environmental Jurisprudence:

PIL has been an effective tool in the hands of helpless citizen, however there are instances

20 G. Sahu, Public Interest Environmental Litigations in India: Contributions and Calculations,

69(4) THE INDIAN JOURNAL OF POLITICAL SCIENCE 745, 752 (2008).
21
M.C. Mehta v. Union of India, 1987 AIR 1086 (Supreme Court of India).
22
Indian Council far Enviro-Legal Action v. Union of India (1996) 5 SCC 28 (Supreme Court of
India).

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 where the Court has been reluctant to deliver justice because the economic development of
the country was upheld at the cost of rights of the citizen. This is evident in cases like
Oleum Gas Case, where gas leakage from Shriram Fertilizers and Food factory caused
various health hazards to the people in Delhi and caused dealth of a person. PIL was
initiated to order shut down of the factory and the compensation. It was held by the Court
that,

“We cannot possibly adopt a policy of not having any chemical or other hazardous industry
merely because they pose hazard or risk to the community. Industries, even if hazardous,
have to be set up since they are essential for economic development and advancement of
well being of the people. We can only hope to reduce the element of hazard or risk to the
community by taking all necessary measures for locating such industries in a manner which
would pose least risk or danger to the community and maximizing safety requirements in
such industries."

However, the Court ordered the management to deposit a sum of Rs. 20,00,000 to pay the
compensation to the victims.

Another case of this kind is Narmada Bachao Andolan v. Union of India23 challenging the
validity of Sardar Sarovar Project which claimed to have been a flawed project with grossly
underestimated social and environmental costs and violations of human rights. Thus, the
petition was filed for the review of the project. The Court held that allowing the
development of a project is an executive decision and the only duty of Court is to ensure
that the due process of necessary compliances is followed, the court cannot give or refuse
to give approval to such projects as that is the sole prerogative of executive as in the
democratic society executive is bestowed with the responsibility of welfare of people. In
this case Court opined that the Governmnet can take care of welfare of affected people by
well made rehabilitation schemes and granting suitable compensation and court does not
need to interfere.

Through various PILs regarding the environmental justice, the Apex Court has
safeguarded the fundamental rights of the citizen to have life conducive environment. With

23
Narmada Bachao Andolan v. Union of India (2010) 10 SCC 664 (Supreme Court of India).

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 the passage of time new principles of environmental jurisprudence have been evolved by
the Supreme Court, thus strengthening the justice delivery system even further. However,
as seen above, there has been inconsistencies in the attitude of Court towards PILs
concerning environmental justice. For instance, even though the Court allowed PILs on
environmental issues such like pollution and forest degradation from industrial activities,
has refused to grant environmental protection due to infrastructure projects such as big
dam, thermal power plant, airport and railway construction etc. There are several aspects
to this in understanding the result and impact of the mechanism of the PIL which shall be
dealt in the later chapter.

• Continuing Mandamus

Generally, when a judgment is passed by a court the executive becomes duty bound to see
that it gets enforced. The reason being that the court can only give guidelines for the
implementation of its decision it cannot be present to oversee its implementation. It is a
commonly observed practice among the enforcement agencies that they tend to postpone
the implementation of the court’s decisions under one pretext or another. Such an attitude
makes it difficult for the very litigants who have won the case to approach the court again
and again so as to avail the benefits of the decision given in their favour. Thus, to inspect
this problem the higher judiciary came up with another yet innovation known as continuing
mandamus. Under this method, the court would issue directions and guidelines which the
administration would be required to conform within a particular time-frame and then report
back to the court regarding the progress of the implementation.24

• Spot Visit:
This process was adopted by Justice V. R. Krishna Aiyer in Ratalam, in order to understand
the nature of dispute by gathering first hand information about the project and the
grievances of the affected people. After vising the site, Justice ordered local municipalty
to take adequate measured to avoid risk of health hazards due to the faulty drainage system.
In Doon Valley Case, the issue at hand was about conduction of certain mining operations

24 Supra note 3, at 37.

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 which became very complicated due to the possible damage to the environment and
violation of rights of the workers involved. Justice P. N. Bhagawati himself conducted a
spot visit and appointed a well-equipped committee to assist the25 judge in the decision
making and appropriate orders were issued to state government for the shut down of certain
mines. In Narmada Dam case26, In the dissenting judgment Justice Bharucha was
unsatisfied with his visit to the dam site when he figured out that there were many issues
regarding the rehabilitation and the manner of issuance of environment clearance.27
This technique of spot visit has enabled the judges to assess the environmental concerns at
the ground level. In this way, there has come to be significant difference in the final
outcome of the case. However, spot visit in such cases is more of individual or personal
interest of the judges as opposed to being a standard decision-making process.

• Expert Committee:
As discussed above, in Doon Valley Case, expert committee was appointed. Similarly in
S. Jagnnath v. Union of India28, committee of experts under the perview of Central
Pollution Control Board. After considering the report court pointed out the hazardous
effects of intensive and semi-intensive aquaculture. In Godavarman case29, the Apex Court
directed governments to have a committees for the undertaking of the research studies
regarding several problems relating to forest protection and to superwise the
implementation of court’s directions in this respect.30
However lately the trend of Supreme Court has been to give it in favour of big infrastructure
projects whenever their stake is involved. It is evident from two prominent cases viz. Tehri
Dam Case and Dahanu Taluka Environment Protection Group31 and others v. Bombay

25
Ratlam Municipality v. Vardhichand and Others AIR 1980 SC 1629 (Supreme Court of India).
26
Narmada Bachao Andolan v. Union of India (2010) 10 SCC 664 (Supreme Court of India).
27 Supra note 3, at 39.
28
S. Jagnnath v. Union of India 1997 (2) SCC 87 (Supreme Court of India).
29
T. N. Godavarman v. Union of India, AIR 1997 SC 122 (Supreme Court of India).
30 Supra note 3, at 37.
31
Tehri Bandh Virodhi Sangarsh Samiti and Others v. State of Uttar Pradesh and Others, 1992 Supp (1) SCC 45
(Supreme Court of India).

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 Suburban Electricity Supply Company Limited and others32 where going against the reports
of the expert committees, Court anyway did not consider the environmental hazards and
thus resulting violations of human rights.

32
Dahanu Taluka Environment Protection Group and others v. Bombay Suburban Electricity
Supply Company Limited and others 1991 (2) SCC 542 (Supreme Court of India).
32
S. Jagnnath v. Union of India 1997 (2) SCC 87 (Supreme Court of India).

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 Chapter III: Results and Impact of the Justice Delivery Mechanisms:

Impact of PIL Mechanism:

Apex Court after relaxing the principle of locus standi in cases of PIL took a decisive step
towards furthering the environmental justice, however the impact of this mechanism has
not always been very positive. There was a considerable misuse of this process as the
citizen started filing PILs for anything and everything without much preparation and where
the compliance was possible at the local levels. Ratlam Municipal Council Case33 is one of
such example where the resources and the time of court was misused on the issue which
could have been settled locally.34

The purpose of PIL is to ensure public interest but soon the PIL mechanism become very
individualstic and thus justice delivery started becoming dependent on the judge which
resulted in the gross miscarriage of justice. More often people started using it to achieve
individual means without exhausting other remedies available in other statutes. Code of
Civil Procedure, 1908 provides for class action in order to further the same cause but to
reduce the cost of litigation, but remedies like these never utilised, however the Apex
judiciary was burdened with PILs and thus making it more time-consuming and expensive
which mad ethe justice delivery pointless.35

In recent times there has been a change in the judicial attitude in favour of economic
development of the country, at the cost of rights of poor and innocent citizen and for the
same reason Court has adopted the attitude of non interference in the cases where the big
infrastructure projects are involved. Narmada Bachao, Tehri Dam Project, Dahanu Power
Plant Project are some of the examples where Supreme Court refused to interfere. Often
such disputes are termed ‘executive’ by the Court and reluctant attitude is adopted. In
Dahanu Power Plant Project case, Court went a step ahead and held that in case of delay

33
Ratlam Municipality v. Vardhichand and Others AIR 1980 SC 1629 (Supreme Court of India).

34 Supra note 20, at 749.

35 C. Abraham, ENVIRONMENTAL JURISPRUDENCE IN INDIA 6 (1999).

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 due to the litigation, petitioner in the PIL would be responsible to pay damages to the
project builder. This shows the clear shift in the attitude of Court towards PIL in cases of
environmental justice delivery in late 1990s which also coincides with the advent of forces
of globalisation, privatisation and liberalisation to the Indian economy.36

This has affected millions of lives and has been becoming growing cause of concern among
the citizen who look up to Supreme Court as the custodian of fundamental rights.

36 Id. At 17.

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 Conclusion

There are no two ways about the notion that environmental justice delivery system is
quintessential part of the socio economic fabric of the Indian society. Wherever statutes
and Constitution was felt inadequate to deliver environmental justice in the most effective
ways, Supreme Court has evolved new procedures and doctrines in the Constitutional
framework to address the issues related environmental injustice. From time to time
Supreme Court has made efforts to make sure that no principle or doctrine derogatory to
environmental justice delivery shall be rules and furthered by the courts of this country.
For example, Supreme Court has allowed filing of PIL, expansion of ambit of Article 32
and Article 226 and modification of locus standi principle.

Even in the light of above discussion, however lately the trend of Supreme Court has been
to give it in favour of big infrastructure projects whenever their stake is involved. It is
evident from two prominent cases viz. Tehri Dam Case and Dahanu Taluka Environment
Protection Group and others v. Bombay Suburban Electricity Supply Company Limited
and others where going against the reports of the expert committees, Court anyway did not
consider the environmental hazards and thus resulting violations of human rights.

Researcher in this paper has come to the conclusion that in order to cure the obstacles to
the justice delivery created various procedural safeguards and in a true sense come off as a
“Custodian of Rights of Citizen”. Judiciary recognised the need to have separate courts to
deal with justice delivery on environmental matter and National Green Tribunal was
established in the year 2010.37

Judiciary and National Green Tribunal to be the only hope, it has been a fear in the air that
the National Green Tribunal, like any other Tribunal will be bound by lot of red tapism.
Thus, adequate checks and balances need to be in the effect.

37A. Sharma, Access to Environmental Justice in India with Special Reference to National Green
Tribunal, 2(3) JOURNAL FOR CENTRE OF ENVIRONMENTAL LAW 1, (2013).

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 A. Sharma, Access to Environmental Justice in India with Special Reference to National
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 B. Abdulkadir, Issues and Challenges in the Environmental Justice Delivery System in
Malasia and Nigeria, 6 BEPRESS, UNIVERSITY OF ILORIN 321, (2012).
 G. Sahu, Implications of Indian Supreme Court’s Innovations for Environmental
Jurisprudence, 4 LAW, ENVIRONMENT AND DEVELOPMENT JOURNAL 34, (2008).
 G. Sahu, Public Interest Environmental Litigations in India: Contributions and
Calculations, 69(4) THE INDIAN JOURNAL OF POLITICAL SCIENCE 745, 752 (2008).
 L. Mehta, Global Environmental Justice, 54 GEOFURUM 158, 162 (2014).
 M. Slater, Environmental Justice: Lessons on Definition and Deliver, 52(6) JOURNAL OF
ENVIRONMENTAL PLANNING AND MANAGEMENT 797, 801 (2008).
 Pandey, Environmental Jusice Delivery System in India: Tracing the Evolution of Green
Justice, 3 SOUTH ASIAN LAW REVIEW JOURNAL 30, (2017).

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