CONSTITUTIONAL LAW CWS ASSIGNMENT

TITLE - Environmental Constitutionalism and Duties of

Individuals in India: A Study

An assignment submitted to Manipal University Jaipur in partial

fulfillment of the requirement for Semester III, for the award of the
degree of BA LLB (Hons).

SUBMITTED BY-
AADESH JAIN
221301098
BA LLB (HONS.)
SECTION -B

pg. 1
pg. 2
 CONTENTS

1. ABSTRACT

2. INTRODUCTION

3. RESEARCH QUESTIONS

4. SCOPE

5. LITERATURE REVIEW

6. PART-1 Need for Environmental Protection and Objective of the

Constitution

7. PART-2 Constitutional Provisions for Environment Protection

8. PART-3 International Treaties for Environmental Protection

9. CONCLUSION

10.BIBLIOGRAPHY

11.WEBELOGARPHY

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 ABSTRACT

The environment is an essential aspect of our existence, and we must take measures to
conserve, protect, and maintain it. As social beings, every individual has the right to inhabit a
healthy environment that is free from pollution. The Indian Constitution provides various
provisions that are necessary for environmental protection. According to the Hohfeld analysis
of Jural Relatives, having a right entails a corresponding duty. The law recognizes rights and
duties as critical components that are interdependent and cannot exist without each other. A
right is always imposed on someone who has a correlative duty. Unfortunately, over time,
individuals have become more conscious of their rights and have overlooked their duties. The
Indian Constitution has granted fundamental rights and duties to Indian citizens to ensure that
both the citizens and the state take responsibility for protecting the constitutional order as a
moral obligation. This paper provides a brief overview of the laws provided by the Indian
Constitution that are primarily relevant to protecting and enhancing the environment.

Keywords: Environment, Protection, Rights, Duties, Constitution

INTRODUCTION

Throughout history, people have worshipped nature, including the Sun, Moon, Earth, Air, and
Water, to show gratitude for sustaining life on our planet. This reverence for nature is based
on the principle that existence is a constant and interconnected phenomenon and that any
change in one part of the environment can affect other areas. A clean and safe environment is
crucial for human survival, and therefore, individuals have the right to breathe pollution-free
air, live in a noise-free environment, and access clean drinking water. Article 21 of the Indian
Constitution guarantees the right to life and personal liberty for every individual, which
includes a decent standard of living in a pollution-free environment.

The right to a clean environment is an old concept recognized by the judiciary and is a basic
right. However, industrialization, modernization, and a decline in moral attitudes have
contributed to environmental degradation worldwide, including in India. This poses a serious
threat to the existence of all human beings, regardless of nationality. Therefore, it is high time
that we take proactive measures towards sustainable living. As rights and duties are two sides
of the same coin, individuals who exercise their right to a clean environment must also fulfill

pg. 4
their duty to take care of it and live in harmony. We must follow certain norms and regulate
our daily activities to safeguard our ecosystem. Our environment sustains us and meets our
most fundamental requirements for life.

Contributing to environmental protection is essential for providing opportunities for future

generations. There are many small actions we can take in our daily lives to protect the
environment, and it all begins with awareness of the impact we have on it. The Indian
Constitution’s preamble, beginning with “We the People,” outlines its objectives, including
the right to a clean environment. A Sovereign, Socialist, Secular, Democratic, Republic is
proclaimed for our nation. Even though the 42nd amendments subsequently incorporated the
terms ‘Secular and Socialist’ into the Constitution, the document already had a secular and
socialist foundation1.

The constitution has several articles that address the social and secular structures of the
country, with Part IV primarily focusing on the socialist mode of governing and Part III
defining the secular structure of the land. Among these, the term Socialist aims at the welfare
of the people. Societal welfare is impossible if individuals are made to live in filthy
conditions that put their lives and well-being in danger. The phrase ‘Democratic Republic’
emphasizes the idea that individuals are entitled to take part in politics and that the state
should strive for their benefit. This indicates that the authorities would work to ensure, among
other things, a sanitary environment suited for human habitation. Ecological preservation is
one of our traditional cultures and ideals. “Man’s paradise is on earth; this biosphere is the
treasured location of everyone; It possesses the gifts of mother nature’s bounty; people are in
an idyllic mood”, according to the Atharvaveda. The preservation of the environment is a
collective responsibility that serves as humanity’s sanctuary. It is imperative to safeguard
nature to ensure the continuity of life. To achieve this, increasing public engagement, raising
awareness on wildlife conservation, and sensitizing the populace on ecosystem and planet
conservation are necessary measures.

The Preamble’s objective is to establish social, economic, and political justice, which
encompasses environmental protection.2 A nation cannot claim to provide equitable
socioeconomic conditions if the wealthy and powerful disregard nature through unregulated
urbanization and illegal mining. Therefore, ecological governance is crucial to ensure the fair

1
PREAMBLE (The Indian Constitution) Bare Act
2
Bare Act of The Indian Constitution (Part IV of the Indian Constitution)

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use of natural resources. Sustainable governance aims to maintain the well-being of society
and its surroundings.

Part III of the Indian Constitution provides fundamental rights that are essential for individual
growth, including the right to a healthy environment. Articles 21, 14, and 19 of the
Constitution have been applied to environmental stewardship. Guidelines for decision-
making in ecological governance are based on three rights: unrestricted access to information
on natural resources and ecological concerns, the ability to participate in policy-making, and
enforcing the implementation of environmental protection laws or financial compensation in
case of degradation.

RESEARCH QUESTIONS

 The analysis focuses on the different constitutional provisions that acknowledge

environmental protection in India.
 It delves into the question of whether the fundamental Right to Life, as provided in
Article 21, encompasses the Right to a clean environment.
 Moreover, it examines the significance of fulfilling the fundamental duty of
safeguarding the environment, which is crucial in securing the fundamental right over
it.

SCOPE

The purpose of this study is to investigate the importance of constitutional recognition of

environmental protection and its effects on individuals. It presents an overview of
constitutional provisions that establish rights, duties, and principles to safeguard the
environment, thereby safeguarding our fundamental right to life. The study delves into
various environmental protection laws and emphasizes the significance of implementing
proactive measures to preserve our ecosystem.

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 LITERATURE REVIEW

The Indian Constitution has outlined various objectives, one of which is to achieve a social
and secular structure for the nation as stated in its preamble. The Constitution comprises
numerous articles that address the social and secular aspects of the country, with Part IV
primarily focusing on socialist governance and Part III defining the secular structure of the
land. The term "Socialist" aims to promote the welfare of the people; however, it is
impossible to achieve societal welfare if individuals are forced to live in unhygienic
conditions that jeopardize their lives and well-being. Article 21 of the Indian Constitution
guarantees the right to life and personal liberty to every individual. A decent standard of
living and a pollution-free environment are inherent aspects of the right to life.

The judiciary recognizes the ancient concept of the right to a clean environment, which is
also a basic right. The Indian Constitution's Part III outlines fundamental rights essential for
individual growth, which every person is inherently entitled to by their personhood.
Environmental stewardship is covered by this section of the constitution, which includes
articles 21, 14, and 19. A person can't thrive and reach their full potential without the right to
a healthy environment.

Article 48-A and Article 51A (g) were introduced in the Indian Constitution through the
Constitutional (42nd Amendment) Act 1976, making India the first country to grant
significant importance to environmental conservation. Article 48-A mandates the state to
endeavor to protect and preserve the environment, including forests, wildlife, and their
habitats. Article 51A (g) states that it is the fundamental duty of every citizen to protect and
improve the natural environment, including forests, lakes, rivers, and wildlife. Despite these
constitutional provisions, industrialization, modernization, and deteriorating moral values
have contributed to environmental degradation worldwide, including in India. This poses a
grave threat to the survival of the human race, irrespective of national boundaries, and calls
for proactive steps towards sustainable living. To this end, raising awareness about the impact
of human activities on the environment is crucial. The right to a clean environment is a long-
standing legal principle recognized by the judiciary in India, and various court rulings have
upheld this right.

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 INDIAN CONSTITUTION AND ENVIRONMENT PROTECTION

DIRECTIVE PRINCIPLES OF STATE POLICY

Part IV of the Indian Constitution outlines the Directive Principles for State Policy, which
detail the social and economic objectives of the State. While these principles are not legally
enforceable, they are considered essential to the nation's governance. Before the 42nd
Amendment in 1976, there was no explicit clause in Part IV dedicated specifically to
environmental protection. However, the principles outlined in Articles 38, 47, and 50 can be
interpreted as indicative of the Amendment's purpose of preserving the environment.

Article 38 mandates that the State pursue socioeconomic and political justice to promote the
welfare of the people3. As such, socioeconomic and social justice, as well as human welfare,
impose upon the State a responsibility to safeguard and maintain the environment, which is
essential to the welfare of the nation and future generations. Article 47 establishes the
fundamental responsibility of the State to advance national well-being. The atmosphere must
be clean, hospitable to human habitation, and conducive to general health for public health to
flourish4. However, this objective is undermined by the external environment, which is rife
with smoke, toxic metals, and pollutants resulting from unchecked and uncontrolled
industrial growth, infrastructure works, and stubble charring, causing significant lung damage
to residents and other health risks.

Article 51 aims to promote environmental preservation through global commitments. Article

51 encourages the promotion of domestic security and peace, as well as adherence to treaty
commitments and international norms5. The State must therefore strive to implement
international human rights laws and conventions, as well as encourage respect for them,
which is not limited to international commitments relating to environmental preservation.
Consequently, although the 42nd Amendment did not include specific provisions for the
protection of the environment, it implicitly established provisions related to environmental
protection in Part IV through Article 48A, which states that "The State shall endeavor to
protect and improve the environment and to safeguard the forests and wildlife of the country."
3
Bare Act (The Indian Constitution), Directive Principles of State Policy, Part IV
4
Bare Act (The Indian Constitution), Directive Principles of State Policy, Part IV
5
Bare Act (The Indian Constitution), Directive Principles of State Policy, Part IV

pg. 8
 FUNDAMENTAL DUTIES

In the Indian Constitution, Part IV outlines a set of Fundamental duties that every citizen
must uphold. It is crucial to acknowledge that rights and duties are two sides of the same
coin. As such, if an individual exercises their right to a safe and clean environment, they must
also adhere to their fundamental duty of taking care of that environment and living in
harmony with their surroundings. Article 51A(g)6 of the constitution emphasizes the duty to
"protect and improve the natural environment including forests, lakes, rivers, and wildlife,
and to have compassion for living creatures." While this duty is enshrined in the constitution,
the enforcement of these duties was not explicitly stated. Every person has a basic
responsibility to safeguard nature against pollution of all kinds and to enhance the
environmental standard if it has already been harmed. In essence, it is the responsibility of
every individual to protect the ecosystem in the same way that nature has provided it to us all.
Let us uphold our fundamental duties and take care of our surroundings for a better future.

CASE LAWS

 L. K. Koolwal v. State of Rajasthan, AIR 19887 –

The Court's ruling determined that the Municipal corporation had failed in fulfilling its
fundamental responsibility of ensuring adequate hygiene and sanitation in Jaipur, thereby
jeopardizing the lives of its residents. The Court elaborated on the true extent of Article 51-A,
highlighting that while it is traditionally seen as the citizens' duty, in reality, it is their right to
hold the State accountable for fulfilling its obligations and ensuring that basic duties are
carried out in compliance with the law. The Court further expounded that the existence of a
right is dependent on the performance of a corresponding duty and that rights can be enforced
through legal measures. Duty and rights are, therefore, mutually reciprocal.

 Rural Litigation and Entitlement Kendra v. State of Uttar Pradesh8 –

6
Bare Act (The Indian Constitution), Directive Principles of State Policy, Part IV
7
10 L. K. Koolwal v. State of Rajasthan, AIR 1988 Raj 2
8
Rural Litigation and Entitlement Kendra v. State of Uttar Pradesh, AIR 1987 SC 359

pg. 9
In the case at hand, the Dehradun Mussoorie area was involved in mining operations,
specifically limestone extraction via explosives that caused the hills to cave in. This resulted
in numerous landslides, which in turn took lives, destroyed houses and farms, and caused
harm to livestock. A public interest litigation (PIL) was filed with the court seeking relief
from the disaster. The court held that both individuals and the state are responsible for
preserving the environment and ecosystems, as per Article 51-A(g) of the Constitution, which
is a fundamental duty incumbent upon every citizen. The court therefore granted appropriate
relief and recommended policy measures to prevent such natural disasters from occurring
again.

FUNDAMENTAL RIGHTS

The Indian Constitution has some important rules called fundamental rights. One of the most
important is the right to life and personal freedom, which is in Article 21. 9Article 21 says that
nobody can take away someone's life or freedom unless the law says they can. Article 21 also
means that everyone has a right to live in a safe and healthy environment. The courts have
been careful about protecting the environment, and have said that Article 21 means people
have a right to live in a clean place. The courts have also used Article 21 to make some other
rules, like those about the environment, into important rights that people can use.

CASE LAW

 Subhash Kumar v. State of Bihar10

In this case, a person named Subhash Kumar filed a lawsuit against West Bokaro Collieries
and Tata Steel and Iron Corporation. He claimed that these companies were polluting a river
by dumping their waste into it, which was making it unsafe for people to use for farming or
drinking. Subhash Kumar wanted the court to tell the companies to stop polluting and to take
legal action against Tata Steel and Iron Corporation. In the end, the court decided that
Subhash Kumar didn't have the right to file a lawsuit in this case, but they recognized that
everyone has the right to live in a clean environment. If someone's quality of life is threatened
by pollution, they can use the law to protect themselves and their community.

9
12 Bare Act (The Indian Constitution), Fundamental Rights, Part III, pg 11
10
Subhash Kumar vs State Of Bihar And Ors, AIR 9 January, 1991

pg. 10
  B.L. Wadehra v. Union of India11

In this case, the Delhi Municipal Corporation and New Delhi Municipality Corporations were
instructed to fulfill their duties of collecting, removing, and disposing of waste, but they
failed to do so. The court observed that the fundamental right to a clean environment and the
right against ecological degradation, which are enshrined in Article 21, can be upheld along
with the fundamental duty stated in Article 48A. Consequently, the court provided specific
guidelines to the Municipal Corporation, Delhi, and New Delhi Municipal Corporation for
the proper collection and disposal of waste to maintain the city's cleanliness.

 In the case of M.C. Mehta v. Kamal Nath12

the petitioner argued that any interference with the environment, including waterbodies,
woods, atmosphere, and freshwater, would be a violation of the fundamental right protected
by Article 21 of the Constitution. The Supreme Court agreed and held that any disruption of
the essential components of the environment necessary for life, such as air, water, and soil,
would violate Article 21. The court further noted that the public trust doctrine and polluter
compensation principle are applicable in such cases. Additionally, the court expanded the
scope of Article 21 to include the right to livelihood, protecting citizens' ability to support
themselves. This broader interpretation has been useful in maintaining strict control over state
actions that may harm the environment, people's health, and the ability of the poor to support
themselves. Furthermore, the right to a decent environment and the right to live in peace are
guaranteed by Article 19(1)(a) of the Indian Constitution when read in conjunction with
Article 21.

 PA Jacob vs. The Superintendent of Police Kottayam13

In the case of P.A. Jacob, a member of the 'Knanay' Christian group, he requested permission
to conduct religious gatherings and use loud amplifiers to spread his beliefs. However, the
Sub-Inspector of Police first granted, then revoked the approval, fearing potential aggression
from conservative members of the Church. Despite these concerns, the event was
successfully held without disruption, demonstrating that the fear was unfounded.

The Kerala High Court ultimately ruled that the use of loudspeakers or noise amplifiers is not
protected under article 19 (1)(a) of the constitution, and therefore, noise pollution caused by
11
14 B.L. Wadehra v. Union of India, AIR 1996
12
MC. Mehta v. Kamal Nath, AIR 2000 SC 1997
13
PA Jacob vs. The Superintendent of Police Kottayam, AIR 1993 Ker 1

pg. 11
such devices can be regulated. It was also noted that Article 21 provides immunity from
torture.

Institutions must uphold constitutional provisions and regulate behavior for the benefit of
those who elected them. According to Article 4714, the state must consider the increasing
levels of nutrition and standard of living of its citizens, with the primary responsibility of
enhancing public health. The state is obligated to prohibit the use of liquor and narcotics that
could harm people's well-being and endanger their lives, except for medical reasons. The
term "responsibility" encompasses the state's obligation to take necessary, appropriate, and
practical measures to improve the standard of living, health, and environmental awareness of
all citizens. Article 48-A was added to the Constitution in 1976 to provide better
environmental protection and preservation. This clause requires the state to conserve the
country's forests and wildlife and maintain and develop the environment. The term
"environment" is used in various ways in this article. The state must take appropriate
measures to enhance the ecosystem while also acting as a protector.

CASE LAW

 Kinkri Devi And Anr. vs. State Of Himachal Pradesh15 –

The petitioners in this case sought the revocation of a mining lease contract for limestone
excavations due to the potential harm it posed to nearby land, water supplies, meadows,
biodiversity, and the environment. They also sought damages to be paid. The high court's
judgment held that both the state and its citizens have a fundamental obligation to maintain
and enhance the environment, as well as to safeguard natural resources such as forests,
vegetation, animals, waterways, and reservoirs. Failure to fulfill this obligation constitutes a
violation of basic law that both the state and individuals are obligated to uphold and
safeguard.

Article 14 of the Constitution guarantees equal protection under the law and equality before
the law for all individuals. The state cannot violate this fundamental right, which implicitly
requires it to act fairly while pursuing ecological conservation measures. The judicial system

14
Bare Act (The Indian Constitution), Directive Principles of State Policy, Part IV, pg 22
15
Kinkari Devi v. State of Himachal Pradesh, AIR 1988 HP 4

pg. 12
has been vigilant in prohibiting unjustified penalties in situations where state officials have
used their discretionary powers.

In conclusion, this case highlights the importance of upholding fundamental obligations to

maintain and enhance the environment and safeguard natural resources. It also underscores
the need for fairness and adherence to constitutional rights in the pursuit of ecological
conservation measures.

CASE LAW

 Bangalore Medical Trust V. B.S Muddappa16

The City Development Board of Bangalore had a plan to make the city bigger. They wanted
to create a small park in a part of the land. But the chief minister decided to use that land to
build something else. The people who lived there went to the high court because they thought
it was unfair. They said that the building would make it hard for them to have the same things
as other people and they were worried that the people in charge could do whatever they
wanted. The court decided that it was important to have parks and open spaces for everyone.
They said that the land should stay as a park and not be used just to make money for someone
else.

INTERNATIONAL ENVIRONMENTAL AGREEMENTS

As a signatory to numerous international agreements on environmental conservation, India is

bound to interpret and implement the provisions outlined in these multinational treaties. This
responsibility is explicitly outlined in Article 5117 of the Constitution, which mandates the
promotion of adherence to treaty commitments and international norms by the state. 18Given
the statement made at the Stockholm Conference in 1972 that the world shares a single
environment, India is compelled to carry out its obligations as a signatory to these
agreements.

16
Bangalore Medical Trust vs B.S. Muddappa And Ors, AIR 19 July, 1991
17
Bare Act (The Indian Constitution), Fundamental Duties, Part IV, pg 23
18
United Nations Conference on the Human Environment, Stockholm 1972 | United Nations

pg. 13
 CASE LAW

 Vellore Citizens’ Welfare Forum v. Union of India19

The Vellore Citizens’ Welfare Forum filed a petition against the Union of India to put a stop
to the negative impact that Tamil Nadu's leather industry and other businesses were having on
the environment. The petitioners argued that the massive discharge of contaminated
wastewater was causing severe degradation to the state's aquifers and water supply sources.
They further claimed that the groundwater close to these tanneries was so polluted that it was
no longer safe for human consumption.

The court carefully considered the precautionary principle and concluded that the right to life
guaranteed by Article 21 of the Constitution includes an underlying right against biodiversity
loss. Based on this finding, the court issued an order for the closure of any industries that
failed to adhere to the directives of the Pollution Control Board and 'NEERI'. The apex court
also held that local laws must be incorporated into international customary law, as long as
they do not conflict with the latter. This is a well-established legal principle, and the local
legal system considers compliance with international norms to be mandatory.

 Narmada Bachao Andolan v. Union of India20 –

It has been determined that a thorough consideration of the consequences of introducing a

new industry or project is crucial to comprehending its potential impact on the environment.
It is not always the case that modifications will result in ecological catastrophes, but
preventative measures must be taken to maintain ecological equilibrium. By implementing
proactive measures to protect the environment, we can ensure that the implications will be
sustainable in the long run.

CONCLUSION

Based on the presented research, it is evident that the Indian Constitution is indeed a living
constitution, and the Indian court has employed interpretive techniques to acknowledge
several previously unrecognized rights as basic rights. The judiciary has established
19
Vellore Citizens’ Welfare Forum v. Union of India, AIR 1996 SC 2715
20
(2000) 10 SCC 664

pg. 14
environmental protection as a basic right and has developed environmental jurisprudence that
supports important concepts such as the Polluter Pay Principle, the Precautionary Principle,
and the Public Trust Doctrine, as well as various provisions such as the Air (Prevention and
Control of Pollution) Act, 1981, Water (Prevention and Control of Pollution), 1974, and Wild
Life (Protection) Amendment Act, 2002.

The environment is a crucial resource that we must preserve and protect. It is the foundation
for sustaining life, and it is our responsibility to ensure its well-being. However, the current
state of affairs regarding the environment requires more public engagement, concern for
wildlife conservation, and sensitization of the populace to conserve ecosystems and the
planet. Sustainable governance aims to maintain the well-being of society and its
surroundings, but the increasing industrialization, modernization, and declining moral
attitudes have led to environmental degradation worldwide, including in India.

This raises a serious concern regarding the existence of the human species as a whole, and
proactive measures must be taken towards sustainable living. While the judiciary has played
an active role in preserving the environment, environmental degradation is still on the rise. It
is essential that everyone in the community is aware of their social, moral, economic, and
political obligations and takes action to uphold them to safeguard and secure their liberty.

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