A) ABSTRACT / HEADNOTE

This case, Samaj Parivartana Samudaya & Ors. v. State of Karnataka & Ors., focuses on addressing illegal mining activities in the districts of Bellary, Chitradurga, and Tumkur, Karnataka. It underscores the Supreme Court’s measures to impose environmental safeguards, regulate mining activities, and ensure compliance with environmental laws. The court’s interventions include implementing district-level production ceilings, reclamation and rehabilitation (R&R) plans, and mandating contributions to a Special Purpose Vehicle (SPV) for environmental restoration. It highlights the court’s determination to balance development and environmental protection through strict oversight mechanisms involving the Central Empowered Committee (CEC), Monitoring Committees, and scientific methods.

Keywords: Environmental Law, Illegal Mining, Reclamation Plans, SPV Contributions, District-level Production Ceilings

B) CASE DETAILS

i) Judgement Cause Title:
Samaj Parivartana Samudaya & Ors. v. State of Karnataka & Ors.

ii) Case Number:
Writ Petition (Civil) No. 562 of 2009

iii) Judgement Date:
14 March 2024

iv) Court:
Supreme Court of India

v) Quorum:
Justice Sanjiv Khanna, Justice M.M. Sundresh, Justice Bela M. Trivedi

vi) Author:
Justice Sanjiv Khanna

vii) Citation:
[2024] 3 S.C.R. 1291

viii) Legal Provisions Involved:

• Article 32 of the Constitution of India
• Environmental Protection Act, 1986
• Mines and Minerals (Development and Regulation) Act, 1957

ix) Judgments Overruled by the Case (if any):
None explicitly stated.

x) Case is Related to which Law Subjects:
Environmental Law, Constitutional Law, Mining Laws

C) INTRODUCTION AND BACKGROUND OF JUDGEMENT

The case arises from rampant illegal mining activities causing severe environmental degradation in Karnataka’s Bellary, Chitradurga, and Tumkur districts. This led to a writ petition by Samaj Parivartana Samudaya, invoking Article 32 of the Constitution to seek judicial intervention. The Court had previously imposed mining bans, set production ceilings, and mandated reclamation measures. This judgment consolidates past orders while introducing further directives to enhance regulatory mechanisms, implement sustainable mining practices, and ensure compliance with environmental laws.

D) FACTS OF THE CASE

• Mining activities in the districts caused extensive environmental degradation and resource depletion.
• Illegal mining practices were pervasive, with mining leases operating beyond permitted boundaries.
• The Central Empowered Committee (CEC) reported severe encroachments and violations.
• In 2011, the Supreme Court imposed a mining ban, followed by graded production ceilings.
• Reclamation and Rehabilitation (R&R) Plans were mandated as a precondition for mining resumption.
• Contributions to a Special Purpose Vehicle (SPV) for restoration were enforced, with 10% levies on sales.
• This judgment addresses pending applications for lease demarcation, compliance with MPAP limits, and objections to the SPV levy.

E) LEGAL ISSUES RAISED

1. Illegal Mining and Environmental Impact:
   How should the court address illegal mining practices and their impact on the environment?

2. District-Level Production Ceilings:
   Should production caps for mining leases be revised or re-evaluated?

3. Reclamation and Rehabilitation (R&R) Plans:
   What measures ensure effective reclamation and sustainable mining practices?

4. SPV Contributions:
   Is the continuation of the 10% levy on iron ore sales to the SPV justified?

5. Demarcation of Mining Leases:
   How should boundary disputes and demarcation issues be resolved?

F) PETITIONER/APPELLANT’S ARGUMENTS

• Illegal mining activities necessitate strict judicial oversight.
• District-level ceilings should align with environmental sustainability and rehabilitation plans.
• The SPV levy is essential for long-term environmental restoration.
• Boundary disputes require scientific methods for resolution to ensure fairness.

G) RESPONDENT’S ARGUMENTS

• Mining leases should be granted flexibility to enhance economic development.
• SPV levies impose excessive financial burdens on mining operators.
• The state is already implementing measures for compliance, making additional judicial directions redundant.

H) JUDGEMENT

a. Ratio Decidendi:
The Court emphasized the need for strict compliance with environmental and mining laws. It upheld production ceilings and R&R Plans as essential mechanisms to prevent further degradation. It directed scientific demarcation methods for disputed leases and endorsed SPV contributions as necessary for comprehensive restoration.

b. Obiter Dicta:
The judgment stressed balancing environmental sustainability with economic development, urging regulatory authorities to adopt innovative practices like satellite mapping and e-auctions.

c. Guidelines:

1. Demarcate mining leases using advanced methods, including satellite imagery and ground surveys.
2. Continue district-level production ceilings with periodic evaluations.
3. Enforce MPAP limits for individual leases to prevent exceeding overall caps.
4. Strengthen R&R Plan implementation by penalizing non-compliance.
5. Maintain the 10% SPV levy until substantial progress in restoration is demonstrated.

I) CONCLUSION & COMMENTS

This judgment reiterates the Court’s commitment to environmental justice and sustainable mining practices. By upholding SPV contributions and enforcing stringent oversight, it reinforces accountability and long-term restoration goals.

J) REFERENCES

a. Important Cases Referred:

1. State of Andhra Pradesh v. Obulapuram Mining Co. (P) Ltd., (2011) 12 SCC 491
2. Samaj Parivartana Samudaya v. State of Karnataka, (2013) 8 SCC 209
3. T.N. Godavarman Thirumulpad v. Union of India & Ors., (2002) 10 SCC 606

b. Important Statutes Referred:

1. Environmental Protection Act, 1986
2. Mines and Minerals (Development and Regulation) Act, 1957
3. Article 32 of the Constitution of India