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M/S Triveni Engineering and Industries Ltd. vs State of Uttar Pradesh & Ors.

Not available · 2025 INSC 1060Decided 1 Sept 2025
Not available
Justice Manoj Misra · Justice Ujjal Bhuyan

Background

The appellant, a sugar mill company, challenged two orders of the National Green Tribunal (NGT) that found it had violated environmental norms, including illegal disposal of untreated effluent and lacking proper effluent-treatment monitoring, based on an original complaint filed against the State of Uttar Pradesh. The NGT had directed a joint committee to assess past violations and recover compensation, relying on an administrative committee's recommendations rather than following the statutory investigation procedure.

Decision Breakdown

The Supreme Court held that the NGT could not bypass the statutory procedure laid down under Sections 21 and 22 of the Water (Prevention and Control of Pollution) Act, 1974, by instead outsourcing the fact-finding investigation to an administrative committee. It found this approach violated principles of natural justice and was not within the NGT's remit, calling it "a classic case where in the quest for doing justice, NGT has ended up doing just the reverse." Rather than sending the matter back to the NGT to redo the exercise, the Court set aside both impugned NGT orders outright, while clarifying that the UP Pollution Control Board remains free to carry out fresh inspections and take remedial action following the proper legal procedure.

Lesson Learnt

Environmental tribunals and regulators must follow the specific statutory procedure for investigating pollution violations. They cannot shortcut it by relying on ad hoc administrative committees, even when acting in the public interest, because doing so can itself violate the natural-justice rights of the party being investigated.

Official source (sci.gov.in)View Judgment (PDF)

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