(Vikram Nath and Sandeep Mehta, JJ.)
Suo Moto Writ Petition (Civil) No(s). 8 of 2025, decided on August 7, 2026
In Re: 2 Million Lives at Risk, Contamination in Jojari River, Rajasthan
With
Civil Appeal No(s). 5517-5519 of 2022
Civil Appeal No(s). 8748 of 2022
Civil Appeal No(s). 9057-9058 of 2022
Civil Appeal No(s). 9010-9011 of 2022
Suo Moto Writ Petition (Civil) No(s). 8 of 2025; Civil Appeal No(s). 5517-5519 of 2022; Civil Appeal No(s). 8748 of 2022; Civil Appeal No(s). 9057-9058 of 2022; and Civil Appeal No(s). 9010-9011 of 2022§
The Order of the Court was delivered by
Sandeep Mehta, J.:—
1. This Court, vide order dated 21st July, 2026, took on record the Second Status Report submitted by the High-Level Ecosystem Oversight Committee1, along with its comments on the First Status Report of the Special Investigation Team.2 During the course of the hearing, this Court also handed over to Mr. S.V. Raju, learned Additional Solicitor General appearing for the State of Rajasthan, copies of certain newspaper reports highlighting matters of grave environmental concern across different regions of the State. Upon consideration of the Committee’s reports and the aforesaid newspaper reports, this Court noted prima facie material disclosing grave environmental concerns, including widespread contamination of water bodies, discharge of untreated industrial effluents, degradation of groundwater, agricultural lands and wildlife habitats, possible encroachments upon riverbeds and floodplains, deficiencies in the identification of High Flood Line and buffer zones, and ex facie systemic failures in regulatory enforcement. The Committee had also highlighted issues concerning ecological restoration, protection of riverine ecosystems, strengthening of the institutional framework governing river basin management, and the functioning of the Common Effluent Treatment Plant (CETP), Sangariya, warranting immediate attention.
2. Having regard to the seriousness and emergent nature of the issues brought to its notice, this Court issued a series of interim directions, inter alia, permitting the Committee to examine representations of White Category industries for appropriate relief; directing the State of Rajasthan to facilitate transfer of identified lands to the Forest Department for ecological restoration; requiring the Rajasthan State Pollution Control Board3 to prepare and implement, under the Committee’s supervision, a scientific plan for the treatment and safe disposal of the accumulated effluents at CETP, Sangariya without permitting resumption of industrial operations; and directing the State to file comprehensive affidavits responding to the Committee’s findings and the environmental concerns reflected in the newspaper reports. The Court further required the State to explain the non-invocation of graver penal provisions in environmental prosecutions, directed immediate consideration of such offences particularly those under Sections 272, 326(a), and 326(c) of the Bhartiya Nyaya Sanhita, 2023, and for offences punishable under the Prevention of Damage to Public Property Act, 1984 in pending and future cases, made the Chief Secretary personally responsible for ensuring compliance with the Court’s directions, and directed his appearance through virtual mode on the next date of hearing.
3. Pursuant to the aforesaid order dated 21st July, 2026, the State of Rajasthan has placed on record (i) a Report of the Special Investigation Team in compliance with the directions issued by this Court; and (ii) a comprehensive Compliance Report on behalf of the State, detailing the steps taken in furtherance of the directions contained in the aforesaid order. The State has also brought on record the factual position, after due verification, with regard to the newspaper reports handed over to the learned Additional Solicitor General during the course of the previous hearing, including the action taken by the concerned authorities, the responsibility, if any, fixed, and the remedial measures proposed to address the environmental concerns highlighted therein. The reports further set out the progress made by the State authorities in implementing the directions issued by this Court and the measures undertaken towards ensuring compliance with the previous order.
4. We have carefully perused the Report submitted by the SIT. The Report indicates that the SIT has undertaken a comprehensive review of 16 criminal cases relating to riverine pollution in the Districts of Jodhpur, Pali and Balotra, of which four First Information Reports have been registered pursuant to its constitution. It is further stated that all the reviewed cases have been examined to ascertain whether the offences disclosed therein warranted invocation of the relevant provisions of the Bharatiya Nyaya Sanhita, 2023 and the Prevention of Damage to Public Property Act, 1984, and wherever a prima facie case was found to exist, the said provisions have been invoked and consequential orders passed accordingly. The Report further records that a few persons have been arrested and that the investigation is progressing on multiple fronts, including the collection of documentary, oral and digital evidence, such as CCTV footage, photographs and videography.
5. The SIT has stated that the material collected during the course of investigation prima facie indicates connivance amongst officials of the Common Effluent Treatment Plants4 and their member industrial units in facilitating the discharge of untreated industrial effluents by deliberately bypassing the prescribed treatment process. It has further been stated that the samples collected by the SIT are presently undergoing scientific examination and that the reports thereof are awaited. Simultaneously, several technical aspects, including the SCADA inflow and outflow data, are under detailed analytical examination. The investigation is also stated to be tracing the financial and institutional trail underlying the alleged offences, while independently examining the role of public servants, without fear or favour. The Report further discloses that several preventive measures have been put in place, including intensified surveillance, deployment of Quick Response Teams, joint nakabandi operations and installation of CCTV cameras to prevent any further illegal discharge of untreated industrial effluents. The SIT has, therefore, prayed for grant of further time to carry the investigation to its logical conclusion, submitting that any premature closure of the investigation may leave material investigative leads unexplored and defeat the very purpose for which the SIT was constituted by this Court.
6. Having considered the progress reflected in the Report, it superficially appears that the SIT has taken substantial steps in furtherance of the mandate entrusted to it by this Court. However, it is noteworthy that the steps for invocation of graver offences and the arrests were effected only when the matter was nearing the date fixed by this Court. This puts a question mark on the bona fides of the SIT’s actions. The officials concerned are thus, advised to act with due promptness and efficacy. We are of the further opinion that extensive investigation is necessary to completely unearth the entire conspiracy and, therefore, a more deeper probe must be carried out by the SIT. The allegations involved disclose issues of considerable public importance, having serious ramifications for environmental governance, public health and institutional accountability. It is, therefore, imperative that the SIT examines each and every facet of the matter in a fair, comprehensive and impartial manner, without fear or favour and uninfluenced by the position or status of any person. The investigation shall not remain confined to the immediate acts of illegal discharge of untreated industrial effluents but shall go to the root of the matter by identifying the complete chain of events, the decision-making processes, the financial and institutional mechanisms employed, and the involvement of all persons, whether private individuals, industrial entities or public officials. The role of every public servant whose conduct comes under scrutiny shall be independently verified on the basis of legally admissible evidence, and if any dereliction of statutory duty, abuse of official position, omission or commission facilitating the commission of the offences is disclosed, appropriate action shall be taken strictly in accordance with law. We direct the SIT to continue the investigation with an enhanced degree of diligence, professionalism and independence, so that every person against whom credible evidence emerges is proceeded against in accordance with law, without exception.
7. We have also perused the comprehensive response filed by the State of Rajasthan pursuant to the directions contained in the order dated 21st July, 2026, particularly the factual position placed on record with respect to the newspaper reports handed over to the learned Additional Solicitor General during the previous hearing. Insofar as the report concerning the alleged pink coloration of the pond near the Jojari River at Tanawada is concerned, the State has placed on record that the matter was immediately taken up by the District Administration and a series of remedial and preventive measures were undertaken, including drone surveys, inspections to detect illegal pipelines, constitution of surveillance teams, regular checking of vehicles suspected of transporting untreated effluents, scientific sampling of the pond water, and installation of CCTV cameras. The State has further stated that the RSPCB has engaged the Indian Institute of Technology, Jodhpur to undertake a detailed scientific assessment of the phenomenon. The preliminary opinion furnished by Indian Institute of Technology, Jodhpur indicates that, while the contribution of saline textile wastewater cannot be ruled out, the available material does not establish any specific dye or identifiable discharge source. The Institute has opined that the pink coloration is most likely attributable to a combination of saline and organic contamination from one or more anthropogenic or natural sources, coupled with evaporation, stagnation and microbial activity, while observing that river seepage and idol immersion appear to be comparatively less probable causes. The report has recommended further scientific investigations, including specialised sampling, microscopic and molecular analyses, targeted dye screening, and other technical studies over a period of 10-12 weeks. The State has submitted that the recommendations of IIT Jodhpur are under examination for implementation. We direct that the remedial recommendations shall be implemented expeditiously and without any further delay, subject to the approval of the Committee.
8. Insofar as the second newspaper report concerning the Sanganer-Dravyavati-Nevta region is concerned, the State has placed on record the existing regulatory framework governing the textile processing units operating in the Sanganer area. It has been stated that 1,767 textile processing units have been identified, of which 892 units are members of the 12.3 MLD Zero Liquid Discharge (ZLD)-based CETP, while 875 units remain outside the CETP network. The State has explained that the CETP is presently operating below its designed capacity owing to incomplete connectivity of the remaining member units and the non-operational status of the Reverse Osmosis reject management system. The State has also placed on record the stringent regulatory and enforcement measures undertaken against defaulting industries, including issuance of closure directions under Section 33A of the Water (Prevention and Control of Pollution) Act, 1974 against 814 industrial units, initiation of prosecutions against the management of the CETP as well as 37 illegally operating textile processing units, imposition of environmental compensation upon the CETP, and the ongoing sealing drive pursuant to which 65 industrial units have already been sealed.
9. The State has further submitted that continuous efforts are being made to bring all textile processing units within the statutory regime, complete the remaining conveyance infrastructure and operationalise the CETP at its full designed capacity. In this regard, both short-term and long-term measures are stated to be under implementation, including completion of the remaining pumping infrastructure, SCADA-based monitoring of effluent discharge, installation of individual Zero Liquid Discharge systems by non-member units, and establishment of an additional CETP for units presently outside the existing treatment network. The State has also placed on record that, with a view to strengthening sewage management in the region, the Dravyavati River Rejuvenation Project has been implemented, under which five Sewage Treatment Plants having a cumulative treatment capacity of 170 Million Litres per Day have been established and approximately 47 kilometres of the Dravyavati River channel has been restored. According to the State, these measures are intended to prevent further pollution while ensuring sustainable treatment, reuse and monitoring of wastewater in the region.
10. With regard to the third newspaper report alleging contamination of the Morel Dam on account of industrial effluents originating from the Sanganer-Sitapura industrial belt, the State has placed on record that the Morel Dam is fed by the Dhund and Morel rivers and that, pursuant to the publication of the news report, officials of the RSPCB conducted an inspection of the dam on 30th July, 2026. During the inspection, the reservoir was found to exhibit algal bloom and patches of water hyacinth, though no foul odour or mortality of fish, birds or animals was noticed. Water samples were collected from the Morel Dam, the confluence of the Dhund and Morel rivers, the Dhund River and a nearby groundwater source for scientific analysis. While the analytical reports of the recently collected samples are awaited, the State has submitted that the earlier laboratory analyses did not disclose the presence of heavy metals such as Nickel, Chromium, Lead or Cadmium beyond the prescribed limits, though the presence of Biochemical Oxygen Demand (BOD) and Chemical Oxygen Demand (COD) indicated the possible presence of sewage and/or industrial effluents in the water. The State has further placed on record that there has been no sudden decline in crop yield, reduction in the area under cultivation or adverse impact on soil fertility in the command area of the Morel Dam and has assured this Court that appropriate action shall be taken upon receipt of the analytical reports of the recently collected samples.
11. We have further considered the response furnished by the State to the recommendations contained in the Second Status Report of the Committee. It is evident that the State has accepted several of the principal recommendations of the Committee and has placed on record the measures initiated towards their implementation. In particular, the State has accepted the recommendations relating to the removal and treatment of the accumulated wastewater at the Ambey Valley and Khed HRTS/SEP sites. It has been stated that an Action Plan has already been prepared for treatment of the accumulated wastewater at the CETP, Balotra upon resumption of its operations. The State has further placed on record that the CETP has discontinued the use of the Ambey Valley HRTS for disposal of treated or untreated wastewater in compliance with the directions issued by the RSPCB; that the pipelines connecting the CETP to the HRTS have been dismantled; that nearly 200 Million Litres of accumulated wastewater is presently stored at the site; and that desludging operations have commenced, pursuant to which approximately 1105.08 Metric Tonnes of hazardous sludge has already been scientifically disposed of at an authorised Common Treatment, Storage and Disposal Facility.5 Insofar as the Khed HRTS/SEP site is concerned, the State has stated that reclamation and restoration works have already commenced; out of the nine ponds, four have already been dismantled, approximately 332 Metric Tonnes of hazardous sludge has been scientifically removed and disposed of at the authorised CTDF, and directions have been issued by the RSPCB for complete removal of the remaining sludge before any further reclamation or restoration activity is undertaken.
12. The State has also accepted the recommendation relating to in-situ treatment of the accumulated wastewater in the Nehda Dam reservoir. In this regard, technical assistance has been obtained from the Indian Institute of Technology, Madras, which has opined that in-situ remediation is feasible, subject to effective prevention of further inflow of polluted water. The report recommends deployment of appropriate treatment technologies, including solar-operated surface aerators and installation of real-time monitoring systems for continuous assessment of water quality. The State has further informed this Court that the recommendations of Indian Institute of Technology, Madras have already been forwarded to the concerned departments for implementation and that continuous surveillance is being maintained to ensure that no industrial discharge enters the concerned water bodies.
13. The response further indicates that the process for preparation of comprehensive river restoration blueprints for the rivers Luni, Jojari and Bandi has been undertaken. The State has stated that the requisite surveys and verifications for determination of the High Flood Line and buffer zones are presently under progress in consultation with the concerned District Environment Committees. It has also been brought on record that comprehensive river restoration blueprints based on the revenue records have already been prepared and submitted for finalisation, while the blueprint pertaining to the Bandi River is under rectification. The State has further informed this Court that steps have been taken to reactivate the Rajasthan River Basin and Water Resources Planning Authority for integrated river basin management.
14. The Report further indicates that substantial steps have been undertaken by the State authorities in compliance with the recommendations of the Committee and the directions issued by this Court vide order dated 21st July, 2026. The State has placed on record that the process for transfer of the ecologically significant lands near the villages Dhawa and Doli to the Forest Department has been initiated for their development and preservation as forest and grassland ecosystems. In this regard, meetings have been convened under the Chairmanship of the District Collector, Jodhpur; consequential directions have been issued to the Jodhpur Development Authority for transfer of the subject lands; and proposals have already been forwarded to the Urban Development Department for issuance of the requisite notifications and consequential orders. The Compliance Report further records that, in relation to the accumulated effluent at the CETP, Sangariya, the RSPCB has collected samples for scientific analysis, conducted inspections to ascertain the quantity of accumulated wastewater, engaged the Indian Institute of Technology, Jodhpur for recommending appropriate remedial measures, and initiated implementation of its recommendation for time-bound, controlled chemical treatment of the accumulated wastewater under scientific supervision, while ensuring that no industrial operations recommence without due permission of this Court.
15. The Report also demonstrates that the directions issued by this Court have been taken up for implementation at the highest administrative level. It has been stated that the Chief Secretary, Government of Rajasthan, convened a meeting of all the concerned Departments and stakeholder associations on 27th July, 2026 to review the issues arising in the present proceedings and the measures required for effective implementation of this Court’s directions. The stakeholder associations have thereafter submitted their respective representations and action plans, and a further review meeting has also been scheduled to monitor the progress of the proposed measures. The Report further states that the directions issued by this Court regarding the invocation of graver penal provisions have been acted upon by the SIT by incorporating the relevant offences wherever warranted during the course of investigation.
16. We have heard Mr. S.V. Raju, learned Additional Solicitor General and Mr. Shiv Mangal Sharma, learned Additional Advocate General appearing for the State of Rajasthan; Mr. Pallav Sisodia and Mr. Dama S. Naidu, learned senior counsel; Mr. Avishkar Singhvi and other learned counsel appearing for the respective parties; Mr. Digvijay Singh Jasol, appearing in person; and the Chief Secretary, Government of Rajasthan (appearing through video conferencing).
17. During the course of the hearing, learned counsel appearing for certain White Category Industries submitted that, pursuant to the liberty granted by this Court vide order dated 21st July, 2026, the concerned industrial units have already submitted representations before the Committee seeking de-sealing of their premises and permission to recommence operations. It was submitted that the Committee has, in terms of the said order, conducted physical inspections of the concerned industrial units. However, no final orders have yet been passed on the representations. Learned counsel submitted that the continued closure of such industrial units is adversely affecting the livelihood of a large number of workers and employees dependent thereon. It was, therefore, requested that the Committee may be requested to take an appropriate decision on the pending representations, one way or the other, within a reasonable time.
18. Having bestowed our anxious consideration to the trajectory of the present proceedings over the last nine months, the successive reports submitted by the Committee, the comprehensive replies and compliance reports placed on record by the State of Rajasthan, and the submissions advanced by the learned counsel appearing for the respective parties, we are of the considered opinion that the material placed on record clearly demonstrates severe degradation of the riverine ecosystem, contamination of water bodies, illegal discharge of industrial effluents, deficiencies in land-use regulation, challenges related to the protection of wildlife habitats and restoration of the affected ecology. All these issues involve the functioning of multiple Departments and statutory authorities of the State and cannot be effectively addressed through fragmented departmental interventions. The nature and complexity of these issues necessitate a coordinated, multidisciplinary and institutional response extending across different administrative levels of the State Government.
19. In our considered view, the multiplicity of stakeholders involved in the present matter, including the Departments of Environment, Forest, Water Resources, Urban Development, Industries, Revenue, Local Self Government, Agriculture, the RSPCB and other statutory authorities, renders it imperative that an Integrated Coordination Group be constituted by the State of Rajasthan. Such a mechanism shall ensure effective inter-departmental coordination, facilitate timely implementation of the recommendations made by the Committee and the consequential directions issued by this Court, monitor the progress of ecological restoration and pollution control measures, resolve issues requiring policy-level intervention, and periodically review compliances so that the measures undertaken by the different authorities form part of a cohesive and integrated strategy rather than isolated departmental initiatives. The constitution of the said Group shall also facilitate continuous and effective coordination with the Committee, enable expeditious consideration and implementation of the Committee’s recommendations, ensure timely exchange of information, technical inputs, and administrative support and avoid duplication of efforts, thereby advancing a coordinated, effective and result-oriented approach towards restoration of the riverine ecosystem and protection of the environment.
20. Having emphasized the necessity of an integrated institutional mechanism for effective implementation of the measures directed by this Court, we now proceed to identify certain critical issues which, in our considered opinion, require immediate and time-bound remedial intervention. Foremost amongst them is the protection and restoration of the Jojari-Bandi-Luni river ecosystem. The reports of the Committee, demonstrates that effective rejuvenation of the Jojari-Bandi-Luni river system cannot be achieved unless the river corridor is scientifically identified, mapped and protected. The absence of a scientifically determined High Flood Line and corresponding ecological buffer zones has facilitated indiscriminate industrial development, encroachments upon the riverbed and floodplains and consequent degradation of the river ecosystem. We are, therefore, of the considered view that the State must undertake a comprehensive scientific exercise for determination and demarcation of the High Flood Line and the requisite ecological buffer zone qua all the river systems in the State in consultation with the Committee and such expert institutions as may be considered appropriate. Until the completion of the aforesaid exercise, no fresh permissions facilitating industrial, commercial or residential development within the identified river corridors shall be granted by any Department, statutory authority or local body of the State of Rajasthan.
21. Equally important is the issue relating to the HRTS facilities at Ambey Valley and Khed. The material on record indicates that these facilities were conceived only as temporary arrangements and cannot be permitted to continue as repositories of accumulated industrial wastewater. While the State has initiated desludging, treatment and reclamation measures, it is imperative that the entire quantity of accumulated wastewater is scientifically treated and disposed of in accordance with the applicable environmental norms within a time-bound framework. Immediately thereafter, all RCC storage tanks and associated infrastructure at the HRTS sites shall be dismantled and the land restored through scientifically approved ecological restoration measures under the supervision of the Committee, which shall periodically monitor the progress of the exercise. The reclaimed land shall thereafter be developed as a green ecological zone/urban forest through plantation of native species and biodiversity conservation measures, under the supervision of the Committee and the Forest Department, so as to secure long-term ecological restoration of the area and enhance the environmental resilience of the riverine ecosystem.
22. The present proceedings have also revealed that the environmental degradation affecting the river system is not merely the result of isolated violations by individual industries but reflects the absence of an integrated institutional framework for river basin governance. The material placed on record further indicates that the Rajasthan River Basin and Water Resources Planning Authority, envisaged as the nodal institution for integrated river basin management, has become largely defunct and has failed to effectively discharge the functions for which it was constituted. Accordingly, we direct the State of Rajasthan to constitute an independent and adequately empowered River Commission/River Rejuvenation Authority for the State of Rajasthan, with a mandate to oversee the conservation, rejuvenation and integrated management of rivers and river basins, including the scientific determination and demarcation of the High Flood Line and the protection of riverine ecosystems throughout the State. Having regard to the magnitude and importance of the task, for the present, we direct that the said River Commission/River Rejuvenation Authority shall function under the chairmanship of the Chief Secretary, Government of Rajasthan, who shall be at liberty to associate such officers, domain experts and technical institutions as may be considered necessary for the effective discharge of its functions. The constitution, organisational framework, modalities, scope, powers and functions of the said Commission/Authority, together with the proposed implementation mechanism, shall be placed before this Court by the next date of hearing.
23. The reports placed before us further indicate that excessive dependence upon CETPs has resulted in operational overload, transportation of industrial effluents over long distances and consequent environmental risks. It has, therefore, become necessary to progressively promote decentralised treatment of industrial effluents. In our considered opinion, the State Government may examine the feasibility of encouraging industrial units generating 100 Kilo Litres per Day or more of industrial effluents to establish and operate Captive Effluent Treatment Plants (ETPs), wherever technically and economically feasible and subject to such regulatory safeguards as may be considered appropriate. The competent authority, i.e., the RSPCB shall ensure that all pending applications seeking permission for establishment of Captive Effluent Treatment Plants are processed and decided expeditiously, in accordance with law, so as to facilitate decentralised treatment of industrial wastewater.
24. Insofar as industries generating less than 100 Kilo Litres per Day of industrial effluents are concerned, the State Government and the RSPCB may consider formulation of an appropriate policy to encourage and incentivise the establishment of Captive Effluent Treatment Plants, wherever technically and economically feasible, so as to progressively reduce dependence upon CETPs and strengthen decentralised treatment of industrial wastewater with the ultimate objective of achieving zero liquid discharge. At the same time, the establishment of Captive Effluent Treatment Plants cannot be viewed as a substitute for a robust common treatment infrastructure. Hence, earnest efforts are required to be made to maximise the capacity utilisation and operational efficiency of the existing CETPs, complete the remaining conveyance infrastructure to ensure that all eligible industrial units are connected thereto, and examine the feasibility of establishing additional CETPs in appropriate industrial clusters to cater to small and medium industrial units which may not be in a position, either technically or financially, to establish and operate Captive Effluent Treatment Plants.
25. Another issue of considerable concern relates to the proposed RIICO Industrial Area, Kakani. The material placed before this Court by the Committee indicates that the proposed industrial area has been developed in close proximity to the Luni River, with approximately 12.805 hectares falling within the apparent High Flood Area, while no scientifically determined ecological buffer has been maintained. The Committee has observed that the existing boundary wall of the industrial area itself adjoins the apparent high flood/riverine area and that the proposed textile-processing units would, in effect, be located merely 30 to 60 metres therefrom. The Committee has further noticed that the layout plan itself acknowledges the existence of land falling within the High Flood Line and contemplates construction of a protection embankment to prevent submergence during floods. Such circumstances, coupled with the absence of a scientifically determined High Flood Line and buffer zone, disclose a serious risk of contamination of the river system through effluent discharge, seepage, storm-water runoff and flood-related dispersion of pollutants. We also take note of the subsequent communications issued by the Water Resources Department, RIICO and the RSPCB, whereby further allotment of plots and grant of statutory consents in the said industrial area have been kept in abeyance pending further examination.
26. We are of the considered view that industrial development in close proximity to an active river corridor or the High Flood Area cannot be permitted in a manner that compromises the ecological integrity of the river system. Accordingly, upon the scientific determination and demarcation of the High Flood Line and the requisite ecological buffer, the Integrated Coordination Group in consultation with the Committee, shall undertake a comprehensive review of the layout of the proposed RIICO Industrial Area, Kakani. If any portion of the proposed industrial area is found to fall within or encroaches upon or adversely affects the High Flood Line, floodplains or the ideal ecological buffer, the State Government shall take appropriate corrective measures, including modification of the layout, relocation or shifting of the affected industrial plots and adoption of all such engineering, environmental and regulatory safeguards as may be necessary to secure complete protection of the river corridor and the riverine ecosystem. The State shall further ensure that no untreated or inadequately treated industrial effluent, contaminated storm-water or any other effluent-laden discharge enters the river system, either directly or indirectly, and that all industrial activities in the area are carried out in strict conformity with the applicable environmental norms and the ecological safeguards.
27. Similar concerns arise in relation to the Ambey Valley Industrial Park situated in the vicinity of the Luni River. The Committee has noticed prima facie irregularities concerning the conversion of agricultural land, deviation from the Master Plan, issuance of pattas for industrial purposes in an area earmarked for residential use, and the development of industrial plots in close proximity to, and in certain cases apparently within, the riverbed and the high flood area. The Committee has also recorded serious deficiencies in the maintenance of official records, including the non-availability of the layout approval file and several files relating to allotment of plots. Such circumstances warrant a comprehensive examination by the competent authorities. The Chief Secretary, Government of Rajasthan shall, therefore, undertake an appropriate inquiry into the legality of the land-use conversions, approvals and allotments made in respect of the Ambey Valley Industrial Park and direct such remedial, regulatory and corrective measures as may be warranted in accordance with law.
28. Protection and sustainable management of groundwater resources constitute an equally important aspect of environmental restoration in the present matter. Excessive dependence upon groundwater for industrial purposes, coupled with contamination of surface water bodies, has placed considerable stress on the groundwater resources and has contributed to the progressive depletion of the water table in the affected regions. The State Government shall, therefore, formulate a comprehensive strategy for sustainable groundwater management, including regulation of groundwater extraction by industrial units, promotion of reuse and recycling of treated wastewater, augmentation of groundwater recharge, periodic assessment and monitoring of groundwater levels and quality, and adoption of such other scientific and regulatory measures as may be necessary to ensure long-term conservation and sustainable utilisation of groundwater resources. We emphasize that no industries which are water intensive shall be henceforth permitted in areas which have been identified as dark zones (over-exploited zones) with reference to the groundwater availability.
29. Vide order dated 21st July, 2026, this Court had directed the State of Rajasthan and all concerned authorities to take expeditious steps for issuance of all necessary notifications and consequential orders for transfer of the lands referred to in the communications dated 7th July, 2026 issued by the Office of the Deputy Forest Conservator (Wildlife), Jodhpur, together with any further communications issued in that behalf, to the Forest Department, so as to facilitate their development and preservation as forest and grassland ecosystems. The Compliance Report placed before this Court indicates that the State Government has initiated the process in furtherance of the aforesaid directions. It has been brought on record that meetings have been convened under the Chairmanship of the District Collector, Jodhpur; consequential directions have been issued to the Jodhpur Development Authority for transfer of the subject lands; and proposals have been forwarded to the Urban Development Department for issuance of the requisite notifications and consequential orders. This process shall now be expedited and taken to its logical conclusion at the earliest. The State Government shall ensure that all necessary notifications and consequential orders are issued within a reasonable time so that the identified lands stand transferred to the Forest Department without any further delay. Thereafter, the Forest Department shall undertake appropriate ecological restoration measures, including afforestation, grassland development, habitat improvement, biodiversity conservation and protection of wildlife corridors, in consultation with the Committee.
30. We have also been apprised about the issue of encroachments and illegal mining upon riverbeds, floodplains and other environmentally sensitive areas. Such encroachments and illegal mining activities adversely affect the natural course of rivers, reduce flood-carrying capacity, impair ecological functions and increase the risk of environmental degradation. The Integrated Coordination Group shall ensure a comprehensive survey for identification of all encroachments and illegal mining sites within the riverbeds, High Flood Line and ecological buffer zones of the Jojari-Bandi-Luni river system and shall initiate appropriate proceedings for the removal of encroachments and abatement of illegal mining activities in accordance with law. The exercise shall be carried out in a phased and time-bound manner after following due process, with due regard to the recommendations of the Committee and the scientific determination of the High Flood Line, so as to restore and preserve the integrity of the riverine ecosystem.
31. The aforesaid issues are of pivotal importance to the effective restoration of the riverine ecosystem and the long-term protection of the environment in the State of Rajasthan. The issues identified during the course of these proceedings are closely interlinked and cannot be addressed through isolated interventions. They require a coordinated, multidisciplinary and sustained approach involving continuous consultation amongst the various stakeholders, scientific institutions and regulatory authorities. In our considered opinion, these issues merit the highest priority and must be addressed with the utmost sincerity, commitment and institutional coordination.
32. We further provide that the Integrated Coordination Group shall hold consultative deliberations with the Committee on the various issues arising in the present proceedings, including the recommendations made by the Committee from time to time. Such deliberations would facilitate the formulation of a Comprehensive Resolution Plan, incorporating clearly identified objectives, measurable action points, defined responsibilities of the concerned Departments and authorities, realistic timelines, and an effective implementation and monitoring framework. In our opinion, such an integrated roadmap would provide the necessary administrative coherence and institutional continuity for addressing the environmental concerns which have engaged the attention of this Court and would considerably strengthen the implementation of the measures envisaged in these proceedings. The Integrated Coordination Group, while formulating the aforesaid Resolution Plan, shall also take into consideration the latest technological advancements, including digitisation of land records, geo-spatial and satellite mapping, Geographic Information System (GIS)-based monitoring, Artificial Intelligence (AI)-enabled surveillance and analytics, and such other technological tools which may facilitate effective environmental governance, monitoring and enforcement.
33. In view of the foregoing discussion, the material placed on record, the successive reports submitted by the Committee and the SIT, the compliance reports filed by the State of Rajasthan, and the submissions advanced on behalf of the respective parties, we are of the considered opinion that certain further directions have become imperative to ensure effective implementation of the measures already initiated, secure institutional coordination amongst the concerned authorities, and facilitate the long-term restoration and protection of the riverine ecosystem and the environment in the State of Rajasthan. Accordingly, we issue the following directions:—
A. The State of Rajasthan shall, within a period of seven days, constitute an “Integrated Coordination Group” headed by the Chief Secretary who shall be at liberty to include in the said group senior officers of the concerned Departments of the State Government, including the Departments of Environment, Forest, Water Resources, Industries, Urban Development, Revenue, Local Self Government, Agriculture, the RSPCB and such other statutory authorities and experts as may be considered necessary, so as to ensure effective inter-departmental coordination and implementation of the directions issued by this Court.
B. The Integrated Coordination Group shall hold detailed consultative deliberations with the Committee on the issues highlighted in the present order, the previous orders passed by this Court, the recommendations made by the Committee from time to time, and such other ancillary or connected issues as may arise during the course of such deliberations, with a view to evolving an integrated, coordinated and time-bound framework for implementation of the measures contemplated herein.
C. Upon completion of the aforesaid deliberative exercise, the Integrated Coordination Group, in consultation with the Committee, shall prepare a Comprehensive Resolution Plan for prevention of environmental degradation, pollution abatement, ecological restoration, conservation of riverine ecosystems, protection of groundwater resources, preservation of biodiversity and strengthening of the institutional framework governing river basin management. The Resolution Plan shall identify the action points, the authority responsible for implementation, the implementation framework, measurable milestones and definite timelines for completion of each component.
D. The Integrated Coordination Group shall function under the overall supervision and chairmanship of the Chief Secretary, Government of Rajasthan, who shall periodically review the implementation of the Resolution Plan and ensure effective inter-departmental coordination.
E. The CETPs, industrial units through their recognised associations, trade bodies, and any other stakeholder having a direct interest in the issues arising in the present proceedings shall be at liberty to submit representations before the Integrated Coordination Group as well as the Committee. Any such representation/s shall be considered on its own merits and in accordance with law, keeping in view the larger objective of environmental protection and sustainable development. However, there shall be no requirement to provide oral audience in the exercise to be conducted by the Integrated Coordination Group.
F. The Integrated Coordination Group, after holding due consultations with the Committee, shall formulate and place before this Court, within a period of three weeks from the date of its constitution, a Comprehensive Resolution Plan, containing clearly identified action points, implementation timelines, monitoring mechanisms and the responsibilities of the concerned Departments and statutory authorities.
G. The State of Rajasthan shall constitute an independent and adequately empowered River Commission/River Rejuvenation Authority for the State of Rajasthan, with a mandate to oversee the conservation, rejuvenation and integrated management of rivers, river basins and catchment areas, including the scientific determination and demarcation of the High Flood Line, protection of riverine ecosystems and coordinated river basin governance throughout the State. The said Commission/Authority shall for the present function under the chairmanship of the Chief Secretary, Government of Rajasthan, who shall be at liberty to associate such officers, domain experts, technical institutions and other stakeholders as may be considered necessary for the effective discharge of its functions. The constitution, organisational framework, modalities, scope, powers, functions and implementation mechanism of the said Commission/Authority shall be placed before this Court by the next date of hearing.
H. The Special Investigation Team shall intensify the investigation process in all pending criminal cases with due diligence and carry the same to its logical conclusion. The investigation shall comprehensively examine the role of all persons, including public servants, industrial units, office-bearers of CETPs and any other persons against whom credible material emerges during the course of investigation, without fear or favour, and appropriate action shall be taken strictly in accordance with law.
I. Insofar as the representations submitted by the White Category Industries pursuant to Direction A contained in this Court’s order dated 21st July, 2026 are concerned, the Committee shall, after considering the inspection reports and the material placed before it, pass appropriate orders on the pending representations, as expeditiously as possible and preferably within a period of seven days from the date of this order.
J. The State of Rajasthan shall establish an Integrated Public Reporting and Environmental Grievance Redressal Mechanism to facilitate timely reporting of environmental violations and allied illegal activities affecting the riverine ecosystem. The mechanism shall provide for a QR Code-based digital platform, with QR Codes prominently displayed on the website of RSPCB as well as at the industrial areas, CETPs, Government offices, Gram Panchayat offices, Forest Check Posts, municipal offices and such other conspicuous locations as may be identified by the Integrated Coordination Group. The platform shall enable any person having credible information to report instances of illegal discharge of industrial effluents, unauthorised operation of industrial units, illegal extraction of groundwater, encroachments upon riverbeds, illegal dumping of hazardous waste, destruction of wildlife habitats and any other environmental violations by uploading photographs, videos, geo-tagged information or such other electronic material as may be necessary. The mechanism shall provide for confidential reporting, generate a unique complaint registration number for every complaint received, ensure immediate electronic transmission of the complaint to the jurisdictional authorities concerned, including the RSPCB, District Administration, Police, Forest Department and such other authorities as may be necessary for prompt action, and facilitate digital monitoring of the action taken thereon. The State Government shall also examine the feasibility of instituting an appropriate incentive scheme for rewarding credible information leading to the detection of serious environmental violations, while ensuring adequate confidentiality and protection of the identity of informants.
K. The Committee shall continue to monitor the implementation of the directions issued by this Court and the progress made by the State Government and the Integrated Coordination Group, and shall be at liberty to issue such recommendations and advisories as may be necessary for effective implementation of the mandate issued by this Court.
L. All Departments of the State Government, statutory authorities, local bodies, public authorities, the Rajasthan State Pollution Control Board, RIICO, CETP Trusts and all other agencies concerned shall continue to extend full cooperation to the Committee, the Integrated Coordination Group and the SIT, and shall make available all records, technical data and other information as may be required for effective implementation of the directions issued by this Court.
M. The Chief Secretary, Government of Rajasthan, shall continue to personally monitor compliance with the directions issued by this Court and shall ensure that all Departments and statutory authorities act in close coordination so that the objectives sought to be achieved by the present proceedings are implemented in a timely and effective manner.
N. We are constrained to observe that the report submitted by the State Government is totally silent regarding the action taken, if any, against the responsible officers of the RSPCB. The details of the action taken/proposed to be taken shall be placed before the Committee within the next three days.
34. Before parting, we deem it appropriate to clarify that the issues relating to industrial pollution, illegal operation of industries and environmental degradation in Jaipur and its adjoining areas, which have also been noted by this Court during the course of the present proceedings, shall be taken up for consideration on the next date of hearing. At this stage, our endeavour is to ensure that the institutional framework and remedial measures directed herein are effectively implemented in relation to the Jojari-Bandi-Luni river ecosystem. Once the aforesaid exercise is substantially completed and the efficacy of the institutional mechanism and the remedial measures directed by this Court is assessed, this Court shall examine the feasibility of adopting and extending a similar framework, with such modifications as may be necessary, to other river systems and regions of the State of Rajasthan facing comparable issues of environmental degradation, industrial pollution and ecological imbalance.
35. The Registry shall forward a copy of this order to Hon’ble Mr. Justice Sangeet Lodha, Judge (Retd.), High Court of Judicature for Rajasthan on his email address: j.sangeetlodha@gmail.com, as well as to Mr. Shiv Mangal Sharma, learned Additional Advocate General for the State of Rajasthan for information and necessary compliance.
36. List the matters on 22nd September, 2026 as part-heard for considering the Comprehensive Resolution Plan to be submitted by the Integrated Coordination Group in consultation with the Committee.
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1 Hereinafter, being referred to as the “Committee”.
2 Hereinafter, being referred to as the “SIT”.
3 For short, “RSPCB”.
4 For short, “CETPs”.
5 For short, “CTDF”.
§ 2026 INSC 812
