Author: Vignesh Narayanan
Environment as a subject matter is an important aspect. Environment is a broad term which includes a lot of aspects. The main mandate of Environmental jurisprudence revolves 6 major Environmental legislations in India which are Wildlife protection Act 1972 , Environmental protection Act 1986 , Air (Prevention and Control of Pollution) Act, 1981, Water (Prevention and Control of Pollution) Act, 1974 , Forest Conservation Act 1980 and Indian Forest Act 1927. The main concern is in order to protect the environment these legislations need to be Robust in Nature. The question which pertinently arise is are these legislations specific in nature ? Are these legislations detailed and comprehensive in nature ? Are all the provisions of these legislation specific and leave no area of ambiguity? Do these legislations cover all the environmental issues at hand ?
The Subramaniam Committee reports basically gave out certain unique recommendation while reviewing the environmental legislation. Subramanian committee basically recommended introduction of new environmental laws ,repeal some of the old legislation and merge some of the old legislation . An article ‘ India’s umbrella environment law idea triggers renewed concerns ‘ by Jayashree Nandi  emphasised opinions of various environmental expert on implementation of Recommendation of Subramanian Committee. An article titled “ Constitutional Provisions for Environmental Protection in India” by Pooja Kapur emphasised on parts and articles of constitution which deal with environment.
WILD LIFE PROTECTION ACT 1972 
Section 3 of Wildlife protection act 1972 deals with Appointment of directors of Wildlife protection by general or special direction by Central Government however an area which is not touched upon by Section 3 is validity of the direction who can challenge this direction when can this direction be challenged who can revoke this direction . Section 3 does not contain a step wise or stage wise procedure for appointment . Section 3 also does not mention which authority of Central Government is authorized to issue general or special directions.
Section 4 deals with Appointment of Chief wildlife warden and wildlife wardens however this section doesn’t specify the number of wildlife wardens who would be appointed. This section also states that they would be appointed by a general or special direction of the State government the question which arises is who can challenge the validity of this direction when can this direction be challenged who can revoke this challenge . Section 4 does not contain a detailed process of appointment of chief wildlife warden which is a huge aspect which this section is silent on. Section 4 also is silent on which authority of the state government is authorized to issue general or special direction.
Section 5 deals with power to delegate. Section 5(1) deals with How directors of wildlife can delegate powers . However, Section 5(1) does not lay down on which circumstances must a director of wildlife lay down his powers . The section is silent on what would be the format of the order if director of wildlife wants to delegate his powers. This section also says director needs the previous approval of central government to delegate powers but doesn’t specify which authority of central government can give approval. Section 5(2) mentions that Chief Wild Life Warden needs the previous approval of state government to delegate powers but doesn’t specify which authority of state government can give approval neither does this section specify the format of the order.
Section 5A(1) deals with constitution of National Board of Wildlife However Section 5A(1) is silent on various points such as what would be the ground for selection of three members of parliament out of which two would be from Lok Sabha and one from Rajya Sabha as per Section 5A(1) (c) There are no parameters laid down. Section 5A(1)( e ) states that five persons to represent non-governmental organizations to be nominated by the Central Government and Section 5 A(1) (v) states that one representative each from ten States and Union territories by rotation, to be nominated by the Central Government. However, Section 5A(1) (e ) and 5A(1) (v) does not mention on what would be the process of nomination and neither lays down the grounds for nomination. Section 5 A (1) is silent on at what intervals must they have a meeting.
Section5B (2) is silent on what grounds can a vice chairperson nominate from the member of board for standing committee of national board . Section 5B (2) is also silent on whether vice chairperson is obliged to give reasons for nominating a particular member for standing committee of national board. Section 5B (3) is silent on what is the maximum number of committees or study group national board can constitute. Section 5C (e ) is silent on whom the status report is binding. Section 5C (e ) is also silent on possible review mechanism for reviewing status report . Section 6( c) deals with having three members from state legislature or in the case of a Union territory with Legislature, two members of the Legislative Assembly of that Union territory as a part of the state board. However, is silent on what paraments would these members would be selected or nominated. If so then it is silent on the process of selection of these members.
Section 11 a deals with permission for hunting of wild animals . Section 11 a is silent on the fact what are the grounds which chief wild life needs to consider for expressing satisfaction that the wild animals specified in 1st Schedule are dangerous to human life. Chief warden has to write an order stating reasons however this section is silent on would the reason be reviewed if reviewed which authority would review it . Section 17 B , 17 C gives power to chief wildlife warden to grant permit for pick and uproot specified plants and give licence for cultivation of specified plants. However, there is no authority above the chief wildlife warden to monitor his actions.
Section 18 creates an ambiguity where it mentions “ adequate ecological, faunal, floral, geomorphological, natural or zoological significance” . There is no clarification a laid down clause in this legislation in regards with what is adequate floral significance. Section 18 does not also lay down in detail the step wise procedure involved in declaring a place as sanctuary.
Coming to Section 33B deals with Advisory committee however there are certain areas which section 33B do not address are is the advisory committee bound to send reports at regular intervals . Are there any stakeholders who are bound to abide by the advice of advisory committee ? If any advisory board member is held for disciplinary misconduct what action would be taken on him ? these are areas which this section is silent on . Section 35 does not put forward in detail stage wise procedure involved in declaring a place as national park. Section 36 B deals with conservation reserve management committee however it is silent on the tenure of members of conservation reserve management committee. It also does not emphasize on a detailed mandate and powers and functions of convervation reserve management committee various aspects like whether this committee is obliged to send reports. To which authority is this committee answerable are areas which are not addressed in this section. Section 36 D does not mention the term of office of chairman of Community reserve management committee. At what intervals does the community reserve management committee have to meet ? what can the state government do if Community reserve management committee does not implement the plan within a particular span of time is something which is not addressed in this section. Section 38X deals with Tiger Conservation Foundation however the bigger question which is not addressed is which authority would be funding the tiger conservation foundation ? Apart from objectives there is no clarification on the functions of tiger conservation foundation in the section.
ROBUST ASPECTS OF WILDLIFE PROTECTION ACT 1972
There are certain parts of Wildlife Protection Act 1972 which are robust. One of the robust parts are section 38-O which comprehensively describes the powers and functions of tiger conservation Authority. Section 38 – C which describes the functions of authority in holistic manner. Section 18- A to Section 32 are one of the most robust part of legislation which cover all major aspects of sanctuaries and functioning of sanctuaries in detail. Section 38-L to 38-W are comprehensive as they address national tiger conservation authority in detail .
ENVIRONMENTAL PROTECTION ACT 1986 
Section 2 (b) defines Environmental pollutants however it does not classify the environmental pollutants into types and categories. Similarly in section 2 (c ) Environmental pollution is defined but there is no mention or categorization of different types of environmental pollution. As the environmental pollutant is mentioned in section 2 (c ) as types of environmental pollutants are not categorised it makes Section 2 (c) more incomplete . Section 2(e ) defines Hazardous Substance However it does not categorize what are the different types of Hazardous Substance.
Section3 deals with powers of central government to take measures to protect and improve environment However there is a major as per chapter 2 following are the Powers given to Central Government such as Power to give directions as per Section 5 , Rules to regulate environmental pollution as per Section 6 . However, the bigger question which arises is what about state government ? What powers are conferred to state government as per chapter 2 of this legislation. This chapter is basically is silent on what be the powers of state government ? will state government have any form of role in central government decision ? would state government be consulted as a stakeholder ? these are some subjects which are not addressed in chapter 2.
Section 7 deals with non-allowing of excess of the standard of environmental pollutants however it this legislation doesn’t establish or cover what is excess standard. Section 8 emphasizes that people handling hazardous substance to comply with procedural safeguards however what are the basic procedural safeguards is not defined in this legislation. Another area in which this section could be comprehensive is procedural safeguards could be classified into two types which is Additional Procedural safeguard mandatory procedural safeguard . Another area which could have been addressed is which authority is responsible for ensuring procedural safeguards are abided by is something which is not addressed in this legislation. Section 12 deals with Environmental laboratories however one concern is state government have no role in directing the functioning of environmental laboratories . There is another aspect which is not addressed in this section is what is minimum infrastructural requirement for environmental laboratory. Section 12 (b) states that central government has the power to declare a laboratory as environmental laboratory however it is silent on the fact that what are the parameters or grounds on which the government can declare an institute or laboratory as environmental laboratory. Another area which this legislation is silent on is what would be the role of state government in environmental laboratories . Section13 deals with Government analyst. This section just states that central government through notification in in Gazette appoint a government Analyst . However, a pertinent factor is that there is no mention of what would be the minimum Qualification required for one to be appointed as Government Analyst. Section 14 deals with Report of Government Analyst . This section just mentions that signature of government analyst is mandatory however it does not recommend a prescribed fixed format of report of Government Analyst. There no fixed structure of Report of government Analyst. Though the Provisions for Punishment are specific in nature however there lies a minute ambiguity which is in section 17 which is if an offences is committed by department then the head of department would be liable however the minute ambiguity is would the members of the department who committed the offence also be held liable ? Section 20 deals information , returns or reports. Central government can direct any authority to furnish information but however this section does not clearly mention on does the state government have similar powers.
ROBUST ASPECTS OF ENVIRONMENTAL PROTECTION ACT 1986
There are certain parts in Environmental Protection Act 1986 which Comprehensive in nature. Section 10 is a very detailed section which emphasis on power to entry and inspect . Section 11 is a step wise expatiation on power to take sample and procedure to be followed. It explains about how would the samples be collected, who would collect samples and where would the sample be sent. The provisions pertaining to penalty are very specific which are section 15 , 16 and 17. These section if a particular stake holder commits offence what would the punishment. Section 25 which is the most structured robust and comprehensive section of this legislation is a basic ground to lay forth a mandate on role of central government on protecting environment and powers conferred to central government in environmental protection Act. Section21 of Environmental Protection act is also very robust in nature as it confers power of public servant as per section 21 of Indian Penal Code 1860 to any officer of authority under this Act . This Makes the section more robust as definition of Public Servant as per Section 21 of Indian Penal Code is very comprehensive in nature . These are some areas of Environmental protection Act which are Robust in Nature.
THE WATER (PREVENTION AND CONTROL OF POLLUTION) ACT, 1974
Section 2 (e ) defines Pollution however it does classify different types of water pollution. It does not categorise types of water pollution. Section 2 (g) defines Sewage effluents but doesn’t categorize sewage effluents into different types. Section 2 (j) defines Stream and mentions whatever constitutes a stream. It states that stream includes sub-terranean water , inland water , water course and river . However, The Water (Prevention and Control of Pollution) Act 1974 does not define Sub terranean water and inland water , neither does it define Water coarse and river . Thereby leaving major aspect of the definition to interpretation. Section 2(k) defines Trade effluents however it does not classify Trade Effluents into different types . This legislation does not define the term effluents .
Section 3 deals with constitution of central board. Section 3 (2) (a) deals with appointment of full time chairman . This section also mentions practical experience in the field of Environment however this is one of the ambiguous part the question which arises is does practical experience mean 5 years of work experience or 10 years of work experience this is something which is not specified in the legislation . The section also mentions “ having knowledge and experience in administering institution” now the question arises does the term knowledge and experience in administering institution mean a post-graduation in Business Administration or a under graduation in Business Administration or does it mean certain year of work experience in administrative position this is something which is ambiguious in the legislation. The full time chairman has to be nominated by central government however there are no clear grounds laid down which central government must consider before nominating. Section 3 2 ( b) states that 5 members to be nominated by Central Government . However, this legislation does not lay down on what grounds or parameters central government must consider to nominate members to represent them. Can it be cabinet ministers ? Can it be sitting members of parliament ? these are things which are not addressed in this legislation. Section 3 2 (d) deals with three members in the interest of fishing , agriculture or industry or trade to be nominated by central government however it does not state whether these members need to have some minimum qualification in these areas ? What is the minimum education these members need to have to be nominated by central government ? these are some areas which this section does not address.
Section 4 deals with Constitution of State Board. Section 4(2) (a) similar to section 3 (2) (a) deals with appointment of full time chairman. However similar to ambiguities which are present in section 3 (2) (a) which mentions practical experience in the field of Environment However does not lay down what would be considered as practical experience in the field of Environment . Section 4 (2) (a) also mentions “ having knowledge and experience in administering institution” now what question arises is what is considered as knowledge and experience in administering institution is something which has not clarified. Section 4 2 (b) states that 5 members to be nominated by State Government however this section does not state what are the parameters or grounds on the basis of which State Government can nominate these members. Can state cabinet minister be nominated ? Can a sitting Member of Legislative Assembly be nominated ? These are something which this section does not address. Coming to section 8 which states that the board must meet once in three months however it does not state who would be held accountable if the board does not meet once in three months. However there lies one concern the relevant sections pertaining to State Board do not state is it mandatory to maintain minutes of meeting of the sessions when they meet once in three months.
Section 13 deals with establishment of joint board . Section 13 does not address in deep that under what condition and circumstances would a joint board have to mandatorily meet. As per Section 14 deals with composition of joint board however these provisions do not address a situation where there is no unanimous decision by the board what is the board suppose to do ? Section 14 ( c) deals with members being nominated by participating state government however they do not specify what criteria or parameters must the state government consider to nominate them. Section 16 2 (a ) states that one of the functions of central board is to advise the Central government on matters pertaining to prevention of water pollution. However, there is no clarification on what nature would the advice be oral or written or in the form of a report. Another area which is not address is the advice by the central board to central government is binding on central government? This is something which is not addressed.
Section 16 2 (d) deals with the power of central board to plan and organise the training of persons engaged in programmes for prevention of water pollution. However, the Question which lies is ,does the central board have power to plan and organise training in an autonomous manner or the central board can only organise in collaboration with the central government is something which is not clearly specified. Section 16 (3) also states that board may establish or recognise a laboratory or laboratories to enable the Board to perform its functions. However, this legislation does not classify the composition of this laboratory. Who can be appointed by the board to work in this laboratory ? What would the minimum qualification be required to work in this laboratory ? these are the things which are not addressed in this section.
Section 17 deals with power of State Board. Section 17(1) (b) gives power to state board to advise the state government on matters pertaining to prevention of water pollution. However there arises two similar questions one whether the advice is binding on State Government ? the second question which arises is what would be the nature of advice would it be an oral advice or written advice in the form of report ? if a report what would be its structure ? these are the things which have not been addressed in this section. Section 17 (1) (f) deals with the power of state board of inspection of sewage or trade effluents. However, it does not mention once in what durations must there be inspection of sewage or trade effluents be done by state board. After inspection is the state board suppose to prepare a report ? what format would a report have ? would the report be binding ? these are the things which are not addressed. Section 17 (1) (k) confers the power of state board to lay down standards of treatment of sewage. However, the question which is not addressed is whether these standards of treatment of sewage would be published ? Would it be published through notification or would it be released in the form of bulletins ? these are the things which are not addressed in this section. Another question which is not addressed is what would be the procedure to challenge any revocation made by state board.
Section 20 confers state board the power to obtain information however certain areas which are not addressed by the section are can state board exercise this power to obtain information even in case of confidential information ? this is a form of ambiguity as information is not defined in this legislation. Information is not classified into types in this legislation. Section 22 deals with Reports of the result of analysis on samples. There lies an ambiguity which is this section does not prescribe a fixed format for reports in the form of annexures. Section 36 and 37 deal with provision of central board and state board. However, they do not mention which financial mechanism the central and state board follow. Does the central and state board follow General financial rule as a financial mechanism ? these are some areas which are not addressed. Section 39 mentions about annual report to be submitted by central and state board however this legislations do not recommend any fixed format. Section 51 deals with Central water laboratory and 52 State water laboratory . However, both these sections do not offer a detailed explanation of composition structure and basic infrastructural needs of central and state laboratory respectively.
ROBUST ASPECTS OF THE WATER (PREVENTION AND CONTROL OF POLLUTION) ACT, 1974
There are a lot of section which are robust and very extensive in nature. Section 16and 17 are very extensive in nature . Section 16 is extensive in nature as it mentions the function of central board in an extensive manner however there are minute ambiguities in section 16 2 (a ) ,16 2 (d) and 16 (3) . Section 10 to Section 12 deals with Temporary association of person with Board for particular purposes, (Sec 11) Vacancy in Board not to invalidate acts or proceeding, 11A. Delegation of powers to Chairman, (Sec12) Member-secretary and officers and other employees of Board are very comprehensive and extensive in nature. These Section address a large number of areas. Section 21 is very comprehensive section which deal with step wise the Power to take samples of effluents and procedure to be followed . Section 23 is a section in which there is a detailed explanation on the power to enter and inspect premises of state board.
FOREST CONSERVATION ACT 1980
Section 2 of Forest Conservation Act states that State Government without the prior approval of the Central Government cannot deserve, cease reservation of an area reserved as forest. However, in this section does not mention which authority of the Central Government is Incharge of sanction prior approval request of State Government . Another aspect which hasn’t been addressed is which authority of state government is responsible to send the approval request to Central Government.
Section 3 deals with Constitution of advisory committee. However there lies ambiguity which is that there is no fixed structure of the advisory committee. There are no authorities put in place. There is no mention of at an interval of what duration will the advisory committee be meeting ? will the advisory committee be presided by a chairman ? What would be the minimum duration required for one to be a member of advisory committee ? will the advisory committee prepare a report ? if any then will the reports of advisory committee be binding on any stakeholder ? Section 4 deals with power to make rules . As per this section the complete power is conferred to the central government. The pertinent question which arises which the legislation is silent on is whether the state government would have any stakeholder ship in making rules.
THE AIR (PREVENTION AND CONTROL OF POLLUTION) ACT, 1981
Section 2 (a) of the Act addresses the definition of Air pollutant . However, this section is silent on are there any type of air pollutants. Air pollutant could also be classified in this section into different types based on severity. This section does not classify Air pollutants into different types. Section 2 (b ) of the Act addresses the definition of Air pollution. There is one aspect which this section is silent on if addressed could make this section more robust which is air pollution could be categorized into types on the basis of severity. Section 3 of the Air act deals with Central Board for Prevention and Control of Air Pollution. Its functioning is similar to that of Central Board for Prevention and Control of Water Pollution.
In Section 5 2 (a) the terms Special knowledge or Practical experience is not specified and explained in detail. Apart from these two terms there are no specified grounds laid down for nominating the members by Central Government. Similarly, Section 5 2 (b) does not lay down the grounds for nominating the members by State Government .
Section 7(5) speaks of fresh nomination however it does not mention on what grounds or parameters would the fresh nomination be ? Section 15 deals with delegating of power through general or special order to chairman. However, this section does not emphasize on a need for a fixed format of such orders. It does not mention what all must to be mentioned in the order. Analysing Section 16 2 (a) The question which lies is that is the advice given to central government binding on them ? Is central government obliged to follow the advice given by the central board ? Section 16 2 (g) deals with power of central board to collect and publish data however it does not mention which authority is responsible for collecting and publishing data. It also mentions about preparing manuals however it does not mention when would these manuals be published ? should it be published once in year or twice in year ? is preparing manual mandatory for central board or its optional in nature is something which is not clarified in the legislation.
Section 17 1 (g) lays down one of the function of state board which is that they have to down in consultation with central board standards for quality of air and standard of emission of air pollution however there is no mention , through which scientific method can the central and state board establish the standard of emission of air pollution. Another area which is unaddressed is whether the advice of state board is binding on state government ? is the state government mandated to follow the advice is something which is unanswered. Section 20 mentions the power of state board in consultation with the state government to give instruction pertaining to ensuring standards of emission to the concerned authority however there is no specification which is that authority? Section 28 deals with State Laboratories however this section does not clearly lay down the functions of state laboratories , minimum infrastructural requirement for State laboratory. It does not set any limit for state government to issue notifications pertaining to functions of state laboratory. There by making it state laboratories completely discretionary and not statutory in nature. Section 29 deals with government analyst however does not clearly lay down the qualifications required to be an analysist. Section 30 deals with Reports of Analyst However it does not specify the time duration within which a report has to be submitted . Section 31 (2) deals with composition of Appellate authority and it mentions that the members would be appointed by state government however it does not mention what are the grounds on which state government can appoint members of the appellate authority. Section 53 and 54 deals with power of central government and state government to make rules however these section make it more of discretionary in nature and not statutory in nature.
INDIAN FOREST ACT 1927 
Section2 (2) defines Forest Officer and mentions that they may be appointed by state government however it does not mention what are the grounds which state government has to consider for appointment for forest officer. It does not even mention whether there is any prescribed qualification required for the state government to consider the appointment. Section 2(5) defines rivers but does not categorize rivers into different types. Similarly, Section 2(7) defines trees however does not categorize trees into different types. Section 3 does not clearly lay down the grounds for state government to exercise the power to reserve forest . Section 4(3) states that state government shall upon to three to perform the duties of a Forest Settlement-office but does not lay down condition and grounds . Section 7 does not lay down step wise procedure for conducting of inquiry by forest settlement officer. Section 18 (3) does mention about an appeal to forest court however it does not is there any time period allocated to forest court to dispose off the appeal. These are the areas on which this section is silent on. Section 27 deals with Power to declare forest no longer reserved. However, this section does not mention whether State Government is mandated to give reasons for declaring a forest no longer reserved . Section 43 mentions that Government and forest Officer won’t be liable for damage to forest products . However, it does not mention who would be liable or which authority would be in charge to decide.
ROBUST ASPECTS OF INDIAN FOREST ACT 1927
There are certain section of the act which are comprehensive and robust in nature . Section 26 is a detailed provision in the act which stated the Act prohibited in forest and Section 29 which deals with Protected Forest. Section 32 in an elaborate manner explained the Power to make rules for protected forests. Section 11 , 12 ,13 and 14 are very specific elaborate and comprehensive in nature which deals with Power to acquire land over which right is claimed , Order on claims to rights of pasture or to forest-produce , Record to be made by Forest Settlement-officer Record where he admits claim respectively.
Environmental law for sure needs amendments. I partially agree to Subramanian committee report . There needs to be considerable number of changes as there are lot of ambiguities in current Environmental law. The Hon’ble Supreme Court has expressed its view toward protection of environment in the case Rural Litigation and Entitlement Kendra & Ors. v. State of Uttar Pradesh & Ors and M.C. Mehta v. Union of India (Gas Leak In Shriram Factory). The amendments need to happen in such a way where there lies no ambiguity and provisions are made robust . This would help increase Accountability and transparency and the burden of interpretation of these legislations would reduce. There needs to be considerable increase in specifications in the environmental legislation this would enable the concerned stakeholder to reduce the dependency on rules. It is very essential for the act to be comprehensive. The current Environmental laws are partially comprehensive. These legislation do not comprehensively cover the current environmental problems.
- Report Summary High Level Committee to Review Acts Administered by the Ministry of Environment, Forest and Climate Change. PRS LEGISLATIVE RESEARCH . (n.d.). https://prsindia.org/files/policy/policy_committee_reports/1418993231_Report%20Summary-HLC%20Envt%20Laws.pdf
- Nandi , J. (2021, March 18). India’s umbrella environment law idea triggers renewed concerns. Hindustan Times. https://www.hindustantimes.com/environment/indias-umbrella-environment-law-idea-triggers-renewed-concerns-101616052674150.html#:~:text=India’s%20umbrella%20environment%20law%20idea%20triggers%20renewed%20concerns,-The%20ministry%20had&text=When%20a%20top%20environment%20ministry,a%20sense%20of%20d%C3%A9j%C3%A0%20vu.
- Kapur , P. (2019, June 28). All Constitutional Provisions pertinent to Environment Protection in India. iPleaders. https://blog.ipleaders.in/constitution-environment-provisions/.
- The Wild Life (Protection) Act, 1972: Legislative Department: Ministry of Law and Justice: GoI. Legislative Department | Ministry of Law and Justice | GoI. (n.d.). https://legislative.gov.in/actsofparliamentfromtheyear/wild-life-protection-act-1972.
- The Environment (Protection) Act, 1986: Legislative Department: Ministry of Law and Justice: GoI. Legislative Department | Ministry of Law and Justice | GoI. (n.d.). https://legislative.gov.in/actsofparliamentfromtheyear/environment-protection-act-1986.
- The Water (Prevention and Control of Pollution) Act, 1974: Legislative Department: Ministry of Law and Justice: GoI. Legislative Department | Ministry of Law and Justice | GoI. (n.d.). https://legislative.gov.in/actsofparliamentfromtheyear/water-prevention-and-control-pollution-act-1974.
- The Forest (Conservation) Act, 1980: Legislative Department: Ministry of Law and Justice: GoI. Legislative Department | Ministry of Law and Justice | GoI. (n.d.). https://legislative.gov.in/actsofparliamentfromtheyear/forest-conservation-act-1980.
- The Air (Prevention and Control of Pollution) Act, 1981: Legislative Department: Ministry of Law and Justice: GoI. Legislative Department | Ministry of Law and Justice | GoI. (n.d.). https://legislative.gov.in/actsofparliamentfromtheyear/air-prevention-and-control-pollution-act-1981.
- The Indian Forest Act, 1927: Legislative Department: Ministry of Law and Justice: GoI. Legislative Department | Ministry of Law and Justice | GoI. (n.d.). https://legislative.gov.in/actsofparliamentfromtheyear/indian-forest-act-1927.
 Report Summary High Level Committee to Review Acts Administered by the Ministry of Environment, Forest and Climate Change. PRS LEGISLATIVE RESEARCH . (n.d.).
 Nandi , J. (2021, March 18). India’s umbrella environment law idea triggers renewed concerns. Hindustan Times. https://www.hindustantimes.com/environment/indias-umbrella-environment-law-idea-triggers-renewed-concerns-101616052674150.html#:~:text=India’s%20umbrella%20environment%20law%20idea%20triggers%20renewed%20concerns,-The%20ministry%20had&text=When%20a%20top%20environment%20ministry,a%20sense%20of%20d%C3%A9j%C3%A0%20vu.
 Kapur , P. (2019, June 28). All Constitutional Provisions pertinent to Environment Protection in India. iPleaders. https://blog.ipleaders.in/constitution-environment-provisions/.
 Act No. 53 of 1972
 ACT NO. 29 OF 1986
 ACT NO. 6 OF 1974
 ACT NO. 69 OF 1980
 ACT NO. 14 OF 1981
 ACT NO. 16 OF 1927
 1985 AIR 652, 1985 SCR (3) 169
 1987 AIR 1086, 1987 SCR (1) 819