Vanashakti v. Union of India 2025 INSC 961 - EIA Notification - Sustainable Development
A country cannot progress unless the development takes place -Precaution is needed to be taken so that the least damage is caused to the environment and ecology.
EIA Notification - notification dated 29th January, 2025 bearing number S.O. 523(E) issued by the Ministry of Environment, Forest and Climate Change and the Office Memorandum dated 30th January, 2025 issued by the MoEF&CC upheld- Note 1 to Entry 8(a) of the notification dated 29th January, 2025 is quashed and set aside- The exemption of applicability of 2006 notification, by way of Note 1 in column 5 of Entry 8(a) of the impugned notification, to the projects or activities for industrial shed, school, college and hostel for educational institution does not appear to be in tune with the purpose for which the Environment Protection Act has been enacted
Interpretation of Statutes - While interpreting any legislation including a subordinate legislation, the first principle that has to be adopted is the literal rule of interpretation. (Para 26)
Environmental Law - Sustainable Development - A country cannot progress unless the development takes place - while development is permitted to be undertaken, it is also required that a precaution is needed to be taken so that the least damage is caused to the environment and ecology -Mitigation and compensatory measures so as to compensate the loss which is caused to the environment and ecology on account of the damage that would be caused by the developmental activities. (Para 33-34)
Education - Education is no more exclusively a service oriented activity and that it has in fact become a flourishing and thriving industry. (Para 43)
Case Info
Case Name and Neutral Citation
- Case Name: Vanashakti v. Union of India
- Neutral Citation: 2025 INSC 961
Coram (Judges)
- B.R. Gavai, Chief Justice of India (CJI)
- K. Vinod Chandran, J
Judgment Date
- Date: August 5, 2025
Caselaws and Citations Referred
The judgment refers to several previous Supreme Court decisions:
- Vellore Citizens’ Welfare Forum v. Union of India and Others
- (1996) 5 SCC 647 : 1996 INSC 952
- Jagannath v. Union of India and Others
- (1997) 2 SCC 87 : 1996 INSC 1466
- Consumer Education & Research Society v. Union of India and Others
- (2000) 2 SCC 599 : 2000 INSC 81
- Intellectuals Forum, Tirupathi v. State of A.P. and Others
- (2006) 3 SCC 549 : 2006 INSC 101
- Tata Housing Development Company Limited v. Aalok Jagga and Others
- (2020) 15 SCC 784 : 2019 INSC 1203
- State of Uttar Pradesh and Others v. Uday Education and Welfare Trust and Others
- (2022) SCC OnLine SC 1469 : 2022 INSC 1129
- In Re: Zudpi Jungle Lands
- 2025 INSC 754
- In Re: Construction of Park at Noida near Okhla Bird Sanctuary
- (2011) 1 SCC 744
Statutes/Laws Referred
- Environment (Protection) Act, 1986
- Wild Life (Protection) Act, 1972
- Water (Prevention and Control of Pollution) Act, 1974
- Air (Prevention and Control of Pollution) Act, 1981
- National Green Tribunal Act, 2010 (implied, as NGT decisions are discussed)
- Notifications:
- Notification dated 14th September, 2006 (MoEF&CC)
- Notification dated 22nd December, 2014
- Notification dated 9th December, 2016
- Notifications dated 14th and 15th November, 2018
- Notification dated 29th January, 2025 (impugned)
- Office Memorandum dated 30th January, 2025