Rural Litigation and Entitlement Kendra vs. State of Uttar Pradesh (1985) Summary for UPSC Polity Notes

1. What is the Rural Litigation and Entitlement Kendra vs. State of Uttar Pradesh Case all about?

The Rural Litigation and Entitlement Kendra vs. State of Uttar Pradesh case in 1985 is a landmark judgement that addressed the issue of environmental protection and sustainable development. The case is often referred to as the Dehradun Valley litigation and is one of the earliest instances of judicial intervention in environmental matters in India. It examined the environmental impact of limestone quarrying in the Mussoorie hills of the Dehradun valley and the balance between environmental conservation and economic development.

2. Facts of the Rural Litigation and Entitlement Kendra vs. State of Uttar Pradesh Case Relevant for UPSC

1. Parties Involved:

• Rural Litigation and Entitlement Kendra (RLEK) (petitioner)
• State of Uttar Pradesh and others (respondents)

1. Legal Questions:

• Whether the continued limestone quarrying in the Dehradun valley was causing environmental degradation and violating the fundamental right to life under Article 21 of the Indian Constitution.
• What measures should be taken to balance environmental conservation with economic development and the livelihood of workers dependent on quarrying.

1. Noteworthy Events:

• RLEK, an NGO, filed a public interest litigation (PIL) highlighting the environmental degradation caused by limestone quarrying in the Mussoorie hills.
• The petition argued that the quarrying activities were causing deforestation, soil erosion, and loss of biodiversity, thus endangering the environment and public health.

3. What are the Major Judgements/Changes Brought by Rural Litigation and Entitlement Kendra vs. State of Uttar Pradesh Case?

The Supreme Court delivered a significant judgement that emphasized the importance of environmental protection and sustainable development:

1. The Court ordered the closure of several limestone quarries in the Dehradun valley to prevent further environmental degradation. It recognized the adverse impact of quarrying on the environment and public health.
2. It ruled that the right to a clean and healthy environment is a part of the right to life under Article 21 of the Indian Constitution. The judgement underscored the need to protect and preserve the environment for current and future generations.
3. The Court emphasized the principle of sustainable development, stating that economic development must be balanced with environmental conservation. It called for measures to rehabilitate the affected areas and provide alternative employment to workers affected by the closure of quarries.

4. What was the Impact of Rural Litigation and Entitlement Kendra vs. State of Uttar Pradesh Case on Indian Constitution?

1. Recognition of Environmental Rights: The judgement recognized the right to a clean and healthy environment as an integral part of the right to life under Article 21, reinforcing the state’s obligation to protect the environment.
2. Promotion of Sustainable Development: It promoted the principle of sustainable development, ensuring that economic activities are conducted in a manner that does not harm the environment.
3. Judicial Intervention in Environmental Protection: The ruling set a precedent for judicial intervention in environmental matters, encouraging the judiciary to play an active role in protecting the environment and addressing ecological concerns.

5. Was this Rural Litigation and Entitlement Kendra vs. State of Uttar Pradesh Case Challenged/Reversed in Future?

The principles established in the RLEK case have not been reversed and continue to guide environmental jurisprudence in India. The judgement remains a significant reference for ensuring environmental protection and sustainable development, and it has influenced subsequent environmental litigation and policy-making in the country.

6. Doctrines/Theories/New Concepts

1. Doctrine of Environmental Rights: The case introduced the principle that the right to a clean and healthy environment is an integral part of the right to life under Article 21, ensuring that environmental protection is a fundamental constitutional obligation.
2. Principle of Sustainable Development: The judgement emphasized the need to balance economic development with environmental conservation, promoting the concept of sustainable development.
3. Judicial Activism in Environmental Protection: The ruling highlighted the role of the judiciary in actively intervening to protect the environment and address ecological concerns, setting a precedent for future environmental litigation.