In Re: Illegal Sand Mining In The National Chambal Sanctuary And Threat To Endangered Aquatic Wildlife vs The State Of Rajasthan
- Court
- Supreme Court
2026 INSC 549
REPORTABLE
IN THE SUPREME COURT OF INDIA
INHERENT JURISDICTION
SUO MOTO WRIT PETITION (CIVIL) NO. 2 OF 2026
“IN RE: ILLEGAL SAND MINING IN THE NATIONAL
CHAMBAL SANCTUARY AND THREAT TO
ENDANGERED AQUATIC WILDLIFE”
WITH
TRANSFERRED CASE (C) NO(S). 151 OF 2026
O R D E R
Mehta, J.
I. INTRODUCTION
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1. This Court vide order dated 14 May, 2026,
upon consideration of the compliance affidavits filed
by the States of Madhya Pradesh and Uttar Pradesh,
the note submitted by the learned Amicus Curiae , and
the report of the Central Empowered Committee,
recorded that while certain preliminary measures
Signature Not Verified
had been initiated by the concerned States in
Digitally signed by
SONIA BHASIN
Date: 2026.05.26
16:40:12 IST
Reason:
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furtherance of the directions previously issued by the
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Court vide order 17 April, 2026, the compliances
undertaken thus far remained at a nascent stage and
substantial measures were yet to be effectively
operationalised at the ground level. The Court noted
that the State of Madhya Pradesh had commenced
the process for strengthening surveillance and
enforcement mechanisms by initiating tenders for
procurement and installation of requisite
infrastructure, including high-resolution CCTV
surveillance systems and allied technological
mechanisms intended to facilitate effective
monitoring of vulnerable stretches and routes prone
to illegal sand mining activities. At the same time, the
Court observed that, having regard to the seriousness
and emergent nature of the issues involved and the
continuing concerns relating to rampant illegal sand
mining activities, further directions in the matter had
become imperative.
2. The Court further expressed serious
displeasure at the lacklustre response of the State of
Rajasthan in failing to comply with the directions
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issued vide earlier orders dated 2 April, 2026 and
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17 April, 2026, and observed that the material
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placed on record disclosed an abysmal state of
compliance and complete lethargy in implementation
of even the core directions issued by the Court. Upon
consideration of the report submitted by the Central
Empowered Committee, the Court recorded that
despite identification of several vulnerable locations,
adequate surveillance mechanisms, live monitoring
systems, GPS integration measures, inter-State
coordination protocols, and enforcement
infrastructure had not been effectively established,
thereby reflecting a disturbing degree of
administrative apathy and institutional paralysis in
addressing organized and brazen illegal mining
activities within protected forest and wildlife
conservation areas, resulting in grave ecological
degradation and failure of effective enforcement.
3. The Court also took note of the alarming
circumstances brought on record regarding the
continued operation of a substantial number of
unregistered and unidentified vehicles and earth
moving machinery suspected of being engaged in
illegal mining and transportation activities in blatant
violation of the provisions of the Motor Vehicles Act,
1988 and the Central Motor Vehicles Rules, 1989.
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The Court observed that the continued and
unchecked movement of such vehicles within and
around the National Chambal Gharial Sanctuary
demonstrated a serious failure of enforcement and
regulatory oversight and had evidently facilitated
illegal mining and transportation activities in
complete disregard of law. The Court further recorded
that the inability of the enforcement machinery to
identify, trace, or verify the ownership of such
vehicles severely impeded effective interception,
seizure, investigation, and prosecution, while
simultaneously enabling organized illegal mining
networks to operate with impunity and evade legal
accountability. The Court additionally took note of
the grave concerns arising from the extensive illegal
excavation activities carried out in dangerously close
proximity to the pillars and supporting structures of
the bridge situated on National Highway-44 near the
Morena-Dholpur border, thereby posing a serious
threat to its structural integrity and gravely
endangering public safety. The Court noted that the
said illegal excavation activities had been verified
during inspection conducted by the Central
Empowered Committee and that such indiscriminate
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mining operations continued unabated in the vicinity
of the bridge, which constituted a vital inter-State
connectivity link carrying substantial vehicular
traffic on a daily basis.
4.
In view of the aforesaid circumstances and the
grave concerns arising therefrom, the Court
proceeded to issue further mandates and directed the
Additional Chief Secretary, Home Department; the
Principal Secretary, Department of Mining and
Geology; the Principal Secretary, Finance
Department; the Principal Secretary, Forest,
Environment and Climate Change Department; and
the Principal Secretary, Transport and Road Safety
Department, State of Rajasthan, to remain personally
present before the Court along with comprehensive
individual compliance affidavits indicating the steps
undertaken in furtherance of the directions
previously issued and the timelines for
implementation of the remaining measures. The
Court further directed the Principal Secretary,
Transport and Road Safety Department, State of
Madhya Pradesh, to remain personally present along
with a detailed affidavit specifically addressing the
issue concerning operation of unregistered and
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unidentified vehicles and earthmoving machinery
and the enforcement measures undertaken in that
regard. The Court also directed impleadment of the
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National Highways Authority of India as a party
respondent and called upon the said Authority to
place on record the measures undertaken or
proposed to safeguard the structural integrity and
security of the aforesaid bridge, including installation
of appropriate CCTV surveillance and monitoring
mechanisms in the concerned area. The matter was,
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thereafter, directed to be listed on 20 May, 2026 for
further consideration.
5. When the matter was taken up for hearing on
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20 May, 2026, all the officers who had been directed
to remain personally present before the Court
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pursuant to the order dated 14 May, 2026 were
present in Court. The learned apprised
Amicus Curiae
the Court that the State of Rajasthan had filed five
separate affidavits through the concerned
departments in compliance with the directions
previously issued, and that the States of Madhya
Pradesh and Uttar Pradesh had also placed on record
1
For short, “NHAI’.
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their respective affidavits specifically dealing with the
issue concerning operation of unregistered and
unidentified vehicles allegedly engaged in illegal
mining and transportation activities, as well as the
enforcement measures undertaken and proposed in
that regard. The learned Amicus Curiae further
submitted a note furnishing a consolidated summary
of the compliance affidavits filed by the respective
States. This Court was also apprised by the learned
Amicus Curiae that two interlocutory applications
had been filed in the present proceedings, one on
behalf of a Non-Governmental Organization,
2
Conservation Action Trust , and the other on behalf
of the Madhya Pradesh Forest Employees
3
Association. Learned counsel appearing on behalf of
the National Highways Authority of India also
submitted an affidavit addressing the concerns
relating to the structural integrity and security of the
bridge situated on National Highway-44 near the
Morena-Dholpur border and the measures proposed
to be undertaken in that regard.
2
Interlocutory Application No. 143798 of 2026.
3
Interlocutory Application No. 143904 of 2026.
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II. Consideration of the Compliance Affidavits
filed on behalf of States of Rajasthan, Madhya
Pradesh, Uttar Pradesh, and National Highways
Authority of India
A. State of Rajasthan
6. The State of Rajasthan has filed five separate
compliance affidavits through the concerned
departmental officials, namely, the Home
Department, Finance Department, Forest
Department, Transport and Road Safety Department,
and the Mines and Geology Department. The
affidavits disclose that, pursuant to the directions
issued by this Court, the State has initiated certain
measures towards strengthening surveillance and
enforcement mechanisms in the affected areas. It has
been stated that financial approval amounting to
approximately Rs. 65.47 crores has been accorded for
installation of IT-enabled surveillance and
monitoring systems by the Forest Department. The
State has further proposed installation of 118 CCTV
cameras across five vulnerable routes, which are
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intended to be integrated with the existing “Abhay
Command Centre” surveillance programme, for
which additional financial sanction of Rs. 30 lakhs
has also been granted. The material placed on record
further indicates that financial approval to the tune
of Rs. 2.5 crores has been accorded for hiring of
vehicles and procurement of equipment necessary for
enforcement operations and that CCTV monitoring
on the transportation route from Dholpur to Agra has
already been made operational through
approximately 50 CCTV cameras.
7. The affidavits further disclose that Rajasthan
Armed Constabulary battalions have been deployed
at vantage points for effective prevention and control
of illegal mining activities and that 40 vulnerable
locations across the sanctuary region within the
State have been identified for focused surveillance
and enforcement action. It has also been stated that
24 permanent camps and 7 temporary check-posts
have been established at critical locations to monitor
and prevent illegal mining and transportation
activities. The Forest Department has additionally
stated that no action has been undertaken pursuant
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to the notification dated 23 December, 2025 after
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passing of the order dated 2 April, 2026 and that all
further proceedings pursuant thereto have been kept
in abeyance subject to final orders of this Court.
8. The State of Rajasthan has further placed on
record statistical data pertaining to FIRs registered,
arrests effected and vehicles seized in relation to
illegal mining activities in the concerned districts.
According to the data furnished by the Home
Department, in the district of Dholpur alone, 625
FIRs were registered, 630 arrests were effected and
688 vehicles were seized between the years 2023 to
2025, while during the year 2026, 105 FIRs have
been registered, 95 arrests effected and 129 vehicles
seized. Similarly, in Karauli district, 39 FIRs were
registered, 88 arrests effected and 64 vehicles seized
during the period 2023-2025, while in the year 2026,
13 FIRs have been registered, 11 arrests effected and
13 vehicles seized. The data further discloses that in
Kota district, 28 FIRs were registered, 48 arrests
effected and 31 vehicles seized during the period
2023-2025, whereas in the year 2026, 5 FIRs have
been registered, 3 arrests effected and 5 vehicles
seized. In Bundi district, 12 FIRs were registered, 18
arrests effected and 13 vehicles seized during the
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period 2023-2025, while in the year 2026, 1 FIR has
been registered, 1 arrest effected and 1 vehicle seized.
The Forest Department has further placed on record
that 55 cases of illegal mining were detected during
the financial year 2023-2024, 50 cases during 2024-
2025, 83 cases during 2025-2026 and 26 cases
during 2026-2027, pursuant to which FIRs were
registered and vehicles involved in such activities
were seized by the concerned authorities.
9. The affidavits further indicate that steps have
now been initiated towards implementation of the
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directions contained in the order dated 17 April,
2026. In this regard, directions have been issued
authorising initiation of the tender process for
installation of CCTV cameras across multiple
districts, while the Director General of Police,
Rajasthan, has issued instructions for continuous
monitoring of transportation of illegally mined sand
through the Abhay Command Centres and deployed
enforcement squads. It has further been stated that
the newly installed cameras shall in future also be
linked to the centralised control system established
by the Forest Department at its Headquarters. The
Transport and Road Safety Department has issued
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directions to the Regional Transport Officers for
taking action under the provisions of the Motor
Vehicles Act against vehicles involved in illegal
mining activities, while the Department of Mines and
Geology has directed immediate seizure of vehicles
and machinery found involved in illegal sand mining
operations. The State has also constituted District
Level Task Forces in Dholpur, Sawai Madhopur,
Kota, Bundi and Karauli under the chairmanship of
the respective District Collectors for coordinated
enforcement operations amongst the Forest, Police
and district authorities and has sought assistance
from the Wildlife Institute of India for preparation of
an appropriate conservation plan.
B. State of Uttar Pradesh
10. The affidavit filed on behalf of the State of Uttar
Pradesh indicates that action against vehicles
operating without registration particulars or number
plates is being undertaken through coordinated
efforts of the Police Department, Transport
Department and Mining Department. It has been
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stated that during the period from 1 April, 2026 to
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15 May, 2026, the Transport Department in District
Agra issued challans to 69 vehicles operating without
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High Security Registration Plate (HSRP) number
plates, seized or impounded 9 vehicles, and recovered
approximately Rs. 1.70 lakhs by way of compounding
fees. The affidavit further records that, according to
the Senior Mines Officer, no case involving
transportation of illegally mined material outside the
National Chambal Gharial Sanctuary area had come
to light during the financial years 2025-2026 and
2026-2027 up to the relevant date.
11. The affidavit additionally places on record
details of criminal proceedings initiated in relation to
illegal mining activities within the Agra
Commissionerate region. It has been stated that in
the West Zone, Commissionerate Agra, a total of 83
cases under the Mining Act were registered between
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the year 2021 and 30 April, 2026, out of which 81
chargesheets and 2 final reports have already been
submitted before the competent Court, and 620
challans have been issued upon detection of
irregularities. Similarly, in the City Zone,
Commissionerate Agra, 36 cases under the Mining
Act were registered during the said period, out of
which 33 chargesheets and 2 final reports have been
submitted, while investigation in one case remains
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pending. The affidavit further records that 689
challans have been issued in the City Zone upon
detection of irregularities.
C. State of Madhya Pradesh
12. The State of Madhya Pradesh has filed an
affidavit in continuation of its earlier affidavit dated
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9 May, 2026. The affidavit discloses that action
taken reports were sought from the Collectors and
Superintendents of Police of the concerned districts
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and that the same were received on 18 May, 2026.
The material placed on record indicates that
substantial enforcement action has been undertaken
during the preceding month, particularly in the
district of Morena, where approximately 1641
vehicles were challaned and an amount of
approximately Rs. 23.55 lakhs was recovered by way
of penalties and compounding fees.
13. The affidavit further states that the State has
proposed establishment of static check-points at
eight identified locations within the districts of
Bhind, Morena and Sheopur for strengthening
surveillance and enforcement mechanisms in the
affected areas and has sought a period of thirty days
for operationalisation of the said measures. However,
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it is evident that the specific issue concerning
operation of vehicles without registration number
plates and other violations of the provisions of the
Motor Vehicles Act, 1988 has not been
comprehensively addressed in the affidavit placed on
record.
D. National Highways Authority of India
14. The affidavit states that the bridge situated at
Chainage Km. 59+400 to Km. 60+000 on the Morena-
Dholpur section of National Highway-44 over the
Chambal River constitutes a vital inter-State
connectivity structure carrying substantial vehicular
traffic between the States of Madhya Pradesh and
Rajasthan. It has been asserted that the NHAI
remains conscious of the seriousness of the concerns
expressed by this Court regarding illegal sand mining
activities in the vicinity of the bridge foundations and
has reiterated its commitment towards ensuring the
safety, structural integrity and uninterrupted
operation of the National Highway infrastructure
under its jurisdiction. At the same time, the NHAI has
stated that regulation and enforcement against illegal
riverbed mining activities fall primarily within the
jurisdiction of the concerned local and statutory
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authorities, including the Mining Department,
District Administration, Forest Department,
Irrigation Department and other regulatory agencies,
and that the role of the NHAI is confined to
maintenance and management of National Highway
infrastructure within the Right of Way.
15. The material placed on record further indicates
that upon receipt of reports regarding alleged illegal
excavation activities in the vicinity of the bridge
foundations, the matter was examined by the NHAI
through its field officials, Operation and Maintenance
Contractor and the Independent Engineer. It has
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been stated that vide communication dated 10
April, 2026, the matter was brought to the notice of
the District Collector, Morena, and that a preliminary
report submitted by the Independent Engineer,
namely, M/s L.N. Malviya Infrastructure Pvt. Ltd. in
association with CASTA Engineering Pvt. Ltd., did not
reveal any serious structural issue affecting the
bridge as per the applicable technical parameters.
Thereafter, the Regional Office of the NHAI at Bhopal
constituted a Committee comprising representatives
of the Public Works Department, MPRDC Morena, the
Independent Engineer and officials of the NHAI for
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conducting a detailed site inspection of the bridge
foundations. Pursuant thereto, a joint inspection was
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carried out on 15 April, 2026, whereupon it was
observed that the prevailing scour levels remained
within permissible design limits and that the bridge
continued to be safe for operation of present traffic.
It has further been observed in the inspection report
that, in accordance with prevailing Ministry of Road
Transport and Highways/NHAI practices, no mining
activity ought to be carried out within 1 kilometre
upstream and 0.5 kilometre downstream of bridge
structures so as to prevent adverse scouring and
ensure long-term safety of bridge foundations.
16. The affidavit further discloses that, in view of
the seriousness of the situation, the NHAI addressed
communications to the Divisional Forest Officer,
Morena, and other concerned local authorities
requesting immediate intervention for protection of
the riverbed, active water flow and ecology of the
National Chambal Gharial Sanctuary from illegal and
unauthorized excavation activities in the vicinity of
the bridge structure. It has additionally been stated
that upon receiving communication from the Deputy
Conservator of Forest (Wildlife), Dholpur regarding
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repair and monitoring of the Chambal bridge
structure, the NHAI informed the concerned
concessionaire, namely, M/s Agra Gwalior Highway
Private Limited, that installation of CCTV
surveillance infrastructure on the Morena-Dholpur
section of National Highway-44, including the bridge
area, was required to be implemented on priority.
Directions in that regard were also issued to the
Operation and Maintenance Contractor as well as the
Independent Engineer for time-bound monitoring
and compliance.
17. The affidavit further indicates that the NHAI has
proposed and undertaken various structural safety,
monitoring and surveillance measures in relation to
the bridge in question. It has been stated that
periodic technical inspections of the bridge
foundations and surrounding riverbed profile shall
continue to be undertaken through the NHAI
officials, Independent Engineers and technical
experts and that scour levels and hydraulic
conditions around vulnerable piers shall be
continuously monitored, particularly before and after
monsoon periods. It has further been stated that
immediate remedial and protective measures shall be
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undertaken in the event any abnormal scour, erosion
or structural vulnerability is detected. The NHAI has
also stated that coordination mechanisms with the
concerned local authorities shall continue for prompt
reporting of illegal excavation activities noticed near
the bridge structure and that highway patrolling
teams have already been deployed on the Agra-
Gwalior section of National Highway-44 for regular
monitoring of the bridge area. The affidavit finally
records that, as per the latest technical inspection
available on record, the bridge presently remains
structurally safe for operation and no immediate
structural distress threatening operational safety has
been reported.
III. Assessment of Compliance and Necessity of
Further Judicial Intervention
18. We have heard the submissions advanced by
the learned Amicus Curiae , Mr. Nikhil Goel, Senior
Advocate, and Ms. Rupali Samuel, learned Advocate-
on-Record; Mr. C.P. Goyal appearing on behalf of the
Central Empowered Committee; Ms. Aishwarya
Bhati, learned Additional Solicitor General and
Mr. Shiv Mangal Sharma, learned Additional
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Advocate General appearing for the State of
Rajasthan; Mr. S.V. Raju, learned Additional Solicitor
General appearing for the State of Madhya Pradesh;
Ms. Ruchira Goel, learned counsel appearing for the
State of Uttar Pradesh; and Ms. Madhu Sweta,
learned counsel appearing for the NHAI.
19. Having given anxious consideration to the
compliance affidavits placed on record by the State of
Rajasthan, this Court finds that, subsequent to the
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order dated 14 May, 2026, certain significant
measures have now been initiated by the concerned
departments towards strengthening surveillance,
enforcement and inter-departmental coordination
mechanisms in the affected regions. The material
placed before this Court indicates that substantial
financial sanctions have now been accorded for
establishment of IT-enabled surveillance
infrastructure, including installation of CCTV
cameras across vulnerable stretches and
transportation routes; District Level Task Forces
have been constituted for coordinated enforcement
operations; permanent camps and temporary check-
posts have been established at critical locations; and
directions have been issued for strict enforcement
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action against vehicles and machinery found involved
in illegal mining activities. The Court also takes note
of the steps now being undertaken for integration of
surveillance systems with centralized command and
monitoring mechanisms as well as the efforts
initiated towards preparation of an appropriate
conservation plan in consultation with expert
institutions.
20. At the same time, this Court cannot overlook the
fact that the affidavits filed by the State of Rajasthan
themselves indicate substantially prolonged
timelines for implementation of several critical
measures proposed therein. The material placed on
record discloses that establishment and
operationalisation of CCTV surveillance systems,
integrated monitoring infrastructure and certain
allied technological mechanisms are proposed to be
completed over a period extending between 18 to 36
months. Similar timelines have also been indicated in
relation to recruitment and augmentation of forest
protection personnel, including Forest Guards. In the
considered view of this Court, such timelines do not
comport with the emergent nature of the situation
presently prevailing in the affected regions. The
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continuing illegal mining activities, ongoing
ecological degradation, destruction of protected
wildlife habitats and risks posed to public
infrastructure cannot brook prolonged
administrative delays in implementation of essential
surveillance and enforcement mechanisms.
Measures intended to secure ecologically sensitive
areas and ensure effective enforcement of law must
be undertaken with a sense of immediacy and
institutional urgency and cannot remain deferred
over extended periods while illegal activities continue
unabated on the ground.
21. This Court further notes that the affidavits now
filed disclose a degree of administrative movement
and institutional coordination which was
conspicuously absent when the matter was
previously considered. The fact that multiple
departments of the State have now come forward with
specific proposals, enforcement measures, budgetary
allocations and operational plans demonstrates that
the gravity of the situation has at least now been
acknowledged at the appropriate administrative
levels. The statistical data relating to FIRs registered,
arrests effected and vehicles seized in connection
22
with illegal mining activities also indicates that
enforcement measures are now being undertaken
with greater seriousness in certain affected districts.
These developments, though undoubtedly belated,
constitute a step in the correct direction and deserve
to be noticed by this Court.
22. However, while taking note of the aforesaid
measures, this Court cannot ignore the disturbing
fact that a substantial number of the actions now
projected before this Court appear to have been
initiated only after stringent directions were issued
requiring personal presence of senior officers of the
State of Rajasthan before this Court. The chronology
emerging from the record indicates that
prima facie
several crucial decisions relating to surveillance
infrastructure, constitution of enforcement
mechanisms, operational coordination, seizure
protocols and inter-departmental action plans were
undertaken only after judicial intervention assumed
a more coercive and supervisory character. Such a
state of affairs reveals an apathic administrative
tendency which responds to grave environmental and
governance issues only upon direct judicial scrutiny
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and compulsion, rather than through timely
institutional initiative and responsible governance.
23. The issues arising in the present proceedings
are not isolated instances of regulatory breach but
concern continuing ecological destruction,
degradation of protected wildlife habitats, organized
illegal mining operations, erosion of public
infrastructure, and a serious breakdown of the rule
of law in ecologically sensitive regions. Such concerns
require an unabated, sustained, vigilant and
proactive institutional response from the State
machinery at all levels. Environmental governance
cannot be reduced to a reactive exercise undertaken
only after repeated judicial intervention or upon
threat of personal accountability before
constitutional Courts. The constitutional obligations
flowing from Articles 21, 48A and 51A(g) of the
Constitution of India cast a continuing duty upon the
State and its instrumentalities to anticipate
environmental harm, prevent ecological degradation
and ensure preservation of fragile ecosystems
through effective governance and enforcement. This
Court, therefore, expects that the measures now
initiated by the States shall not remain confined to
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affidavits, proposals or temporary compliance
exercises as defensive responses to the present
proceedings, but shall be translated into concrete,
continuous and time-bound action on the ground
through active monitoring, institutional
accountability and sustained enforcement so as to
effectively curb the continuing menace of illegal sand
mining activities within and around the National
Chambal Gharial Sanctuary.
24. At this stage, this Court is constrained to
observe that the compliance affidavits filed by the
States of Rajasthan, Madhya Pradesh and Uttar
Pradesh do not satisfactorily address the specific
issue concerning operation of unregistered and
unidentified vehicles allegedly engaged in illegal
mining and transportation activities, nor do they
disclose any concrete or effective enforcement
framework evolved for dealing with such violations.
While the affidavits broadly refer to challans issued,
penalties recovered and general enforcement
measures undertaken by the authorities concerned,
the material placed on record does not indicate the
existence of any systematic mechanism for
identification, seizure, blacklisting, confiscation of
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vehicles or prosecution of owners of the vehicle
operating without registration particulars in blatant
violation of the provisions of the Motor Vehicles Act,
1988 and the Central Motor Vehicles Rules, 1989.
The continued operation of such unidentified vehicles
in ecologically sensitive regions and protected
sanctuary areas raises serious concerns regarding
both regulatory failure and possible facilitation of
organized illegal mining activities through deliberate
evasion of legal accountability.
25. The statistics placed on record by the State of
Madhya Pradesh themselves reveal the inadequacy of
the enforcement measures presently being
undertaken. The material furnished before this Court
indicates that during the first five months of the
current year, more than 250 vehicles were challaned
for violations under Section 192 of the Motor Vehicles
Act, 1988 which deals with operation of vehicles
without valid registration. However, it appears that
the said vehicles were merely released upon payment
of fines to the tune of approximately Rs. 5,000/- and
no further coercive or deterrent action was initiated
either against the drivers or the owners of such
vehicles. The record does not disclose initiation of
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prosecution proceedings, seizure and confiscation
measures, suspension of permits, investigation into
ownership patterns, or any attempt to identify
whether such vehicles were repeatedly involved in
illegal mining and transportation activities.
26. This Court also takes note of the submission
made on behalf of the State of Madhya Pradesh that
static check-points are proposed to be established at
eight identified locations within the districts of
Bhind, Morena and Sheopur for strengthening
surveillance and enforcement mechanisms in the
affected areas. It has further been submitted on
behalf of all the concerned States that measures are
also being contemplated to ensure that no fuel is
supplied to vehicles not displaying authentic
registration particulars or otherwise found operating
in violation of the provisions of the Motor Vehicles
Act, 1988 and the Central Motor Vehicles Rules, 1989
and involved in illegal mining and transportation
activities. While such measures may constitute
preliminary superficial regulatory and monitoring
mechanisms, this Court is of the considered opinion
that the same, by themselves, would be wholly
insufficient to effectively address the magnitude,
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organized nature and continuing impunity with
which illegal mining operations are being carried out
in the region. Mere establishment of check-posts,
issuance of challans or ancillary restrictions relating
to fuel supply, without stringent and immediate
coercive action against the offending vehicles and
their operators, and more particularly, the behind the
scene kingpins is unlikely to produce any meaningful
deterrent effect. In the considered view of this Court,
unless vehicles found repeatedly involved in illegal
mining and transportation activities are subjected to
immediate seizure, confiscation and denial of release
except in accordance with law, the existing
enforcement framework would continue to remain
ineffective and incapable of curbing organized
environmental crime being perpetrated in the affected
regions.
27. This Court is of the considered view that the
issue under consideration transcends the realm of
routine traffic regulations or isolated instances of
statutory non-compliance. The operation of vehicles
without registration particulars in and around
regions affected by rampant illegal mining activities
constitutes a serious law enforcement concern
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having direct nexus with organized illegal mining
operations and systematic evasion of regulatory
oversight. Permitting such vehicles to continue
operations merely upon payment of nominal
monetary penalties not only defeats the object and
purpose of the statutory framework but also creates
an atmosphere of complete impunity wherein illegal
mining networks are able to treat penal
consequences as insignificant operational costs.
Effective enforcement in such matters necessarily
requires a far more stringent, coordinated and
deterrent approach involving immediate seizure,
prosecution, tracing of ownership networks,
cancellation of permits and accountability of officials
responsible for permitting continued operation of
such unidentified vehicles in the affected regions.
28. Another serious issue which was highlighted
during the course of hearing concerns the substantial
vacancies presently existing in the Forest
Departments of the concerned States, particularly in
relation to field-level personnel, including Forest
Guards and other frontline enforcement staff
entrusted with protection and monitoring duties
within the sanctuary and adjoining regions. The
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material placed on record prima facie indicates that a
significant number of sanctioned posts continue to
remain vacant for prolonged periods, thereby severely
affecting the capacity of the field machinery to
undertake effective surveillance, patrolling,
interception and enforcement operations in areas
affected by rampant illegal mining activities.
29. This Court is of the considered view that
effective environmental governance and protection of
ecologically sensitive regions cannot be ensured
merely through issuance of administrative directions
or installation of technological infrastructure in the
absence of an adequately staffed and functional field
enforcement mechanism. Frontline personnel such
as Forest Guards constitute the first and most critical
layer of protection against illegal mining,
encroachments and destruction of wildlife habitats.
Persistent vacancies in such posts inevitably weaken
institutional capacity on the ground and
substantially impede timely detection, prevention
and enforcement action against illegal activities being
carried out within protected areas.
30. The continuing existence of large-scale
vacancies in the enforcement machinery, despite the
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grave and recurring nature of the issues involved in
the present proceedings, reflects a serious
institutional deficiency which requires immediate
attention at the highest administrative levels. The
States are under a continuing obligation to ensure
adequate augmentation and strengthening of the
enforcement machinery entrusted with protection of
ecologically sensitive regions and implementation of
environmental and mining laws. Effective
surveillance, patrolling and enforcement operations
cannot be sustained in the absence of sufficient field-
level personnel and functional administrative
infrastructure. The existence of huge vacancies in
critical posts such as Forest Guards and other
frontline enforcement personnel inevitably weaken
the capacity of the State machinery to effectively
monitor vulnerable areas, prevent illegal mining
activities and ensure timely enforcement action on
the ground.
31. During the course of hearing, this Court also
interacted with the Additional Chief Secretary,
Forest, Environment and Climate Change
Department, State of Rajasthan, who fairly conceded
that substantial vacancies presently exist in the
31
cadre of Forest Guards and other field-level personnel
entrusted with enforcement and protection duties in
the affected regions. It was further submitted that the
last recruitment for the post of Forest Guards had
been undertaken approximately four years ago and
that requisitions for recruitment to various posts
within the Forest Department had already been
forwarded to the concerned recruitment agency in the
year 2025. However, despite the continuing and grave
concerns arising from rampant illegal mining
activities and degradation of protected forest areas,
no effective progress appears to have been made in
expediting the recruitment process, which prima facie
appears to be proceeding at an unduly slow pace. The
aforesaid state of affairs reflects a disturbing degree
of administrative lethargy and lack of institutional
urgency in addressing critical deficiencies within the
enforcement machinery entrusted with protection of
ecologically sensitive regions and implementation of
environmental laws.
32. This Court is of the considered view that any
level of technological initiatives such as CCTV
surveillance systems, monitoring infrastructure and
control centres, though necessary, cannot by
32
themselves act as a substitute for an adequately
staffed and operational field enforcement
mechanism. The efficacy of surveillance and
enforcement ultimately depends upon the existence
of trained personnel capable of carrying out regular
patrolling, interception, seizure operations and
coordinated enforcement action in difficult and
vulnerable terrain. The States must, therefore,
undertake urgent and time-bound measures for
filling up vacant posts in the Forest Department and
allied enforcement agencies and ensure that the
enforcement framework in the affected regions is
meaningfully strengthened both in terms of
infrastructure as well as manpower so as to
effectively curb the continuing menace of illegal
mining activities.
33. Now, coming to the issue concerning extensive
excavation and illegal mining activities in and around
the bridge situated on the Morena-Dholpur section of
National Highway-44 over the Chambal River, as well
as the affidavit filed by the National Highways
Authority of India pursuant to the directions issued
th
by this Court vide order dated 14 May, 2026. It
emerges from the material placed on record that,
33
upon receiving information regarding illegal
excavation activities in the vicinity of the bridge
foundations, the matter was examined through field
officials, the Operation and Maintenance Contractor
and the Independent Engineer. The affidavit discloses
that communications were addressed to the
concerned District Authorities and Forest Officials
highlighting the issue and seeking immediate
intervention. A joint inspection of the bridge
foundations was also conducted through a
Committee comprising representatives of the NHAI,
the Public Works Department, MPRDC and the
Independent Engineer, pursuant whereto it was
opined that the prevailing scour levels remained
within permissible limits and that the bridge
presently continued to remain structurally safe for
flow of traffic. The affidavit further indicates that
directions have been issued to the concerned
concessionaire, namely, M/s Agra Gwalior Highway
Private Limited, for installation of CCTV surveillance
infrastructure on the Morena-Dholpur section of
National Highway-44, including the bridge area, and
that highway patrolling teams have also been
34
deployed for regular monitoring of the stretch
concerned.
34. The NHAI has further sought to contend that
regulation and enforcement against illegal mining
activities primarily fall within the domain of the
concerned departments and statutory authorities of
the respective States, including the Mining
Department, Forest Department, District
Administration and Police Authorities, and that the
role of the NHAI is essentially confined to
maintenance and management of the National
Highway infrastructure within the Right of Way. It
has additionally been stated that surveillance and
monitoring obligations in relation to the highway
stretch are being undertaken through the concerned
concessionaire and the Operation and Maintenance
Contractor entrusted with maintenance of the said
National Highway section.
35. While this Court takes note of the stand taken
by the NHAI that regulation and enforcement against
illegal mining activities primarily fall within the
domain of the concerned State authorities, it cannot
lose sight of the fact that the NHAI, being a statutory
authority entrusted with development, maintenance
35
and management of National Highway infrastructure,
cannot absolve itself of the responsibility of
safeguarding infrastructure under its control from
activities that pose a foreseeable threat to its safety,
stability and long-term structural integrity. The
material placed on record, including the inspection
reports and observations recorded in the earlier
orders of this Court, prima facie indicates that
extensive illegal excavation and mining activities
have been carried out in dangerous proximity to, and
in certain instances even beneath, the pillars and
supporting structures of the bridge situated on
National Highway-44 near the Morena-Dholpur
border.
36. The indiscriminate and continuing excavation of
riverbed material in the vicinity of the bridge is liable
to alter the river morphology, aggravate scouring
around the foundations and adversely affect the
stability of the bridge over a period of time. The issue,
therefore, transcends a mere question of routine
maintenance and directly implicates concerns
relating to public safety, uninterrupted inter-State
connectivity and protection of critical public
infrastructure. Once serious concerns regarding
36
illegal excavation activities in the immediate vicinity
of the bridge were brought to the notice of the NHAI,
a corresponding obligation arose upon the Authority,
as well as the concessionaire entrusted with
operation and maintenance of the highway stretch, to
take all reasonable preventive, protective and
surveillance measures necessary to safeguard the
bridge and ensure its long-term structural security.
The obligation to maintain safe transportation
infrastructure necessarily includes a duty to
anticipate and address external threats capable of
compromising such infrastructure and cannot be
confined to undertaking remedial measures only after
damage has already occurred.
37. In the considered view of this Court, the
prevailing circumstances necessitate a far more
vigilant, proactive and technologically integrated
surveillance framework in and around the bridge
area. The NHAI and the concerned concessionaire
cannot adopt a passive approach by merely reporting
instances of illegal mining to the State authorities.
Effective protection of the bridge requires continuous
monitoring, timely detection of violations and
coordinated preventive action aimed at ensuring that
37
illegal mining and excavation activities are not
permitted to endanger the structural integrity of the
bridge and the National Highway infrastructure
connected therewith. The material placed on record
indicates that installation of robust surveillance
infrastructure and real-time monitoring systems has
now become indispensable not only for purposes of
curbing illegal mining activities but equally for
ensuring long-term protection of the bridge and the
safety of the travelling public. In this regard, the
NHAI, in consultation/collaboration with the
concerned concessionaire, shall ensure the
establishment and augmentation of surveillance
infrastructure, including installation of CCTV
cameras, monitoring systems and allied protective
measures in and around the bridge area.
38. The Central Empowered Committee has also
highlighted another matter of serious concern
relating to dumping of waste into the Chambal River
from the bridge spanning the river. The Central
Empowered Committee has recorded that during its
site visit, substantial quantities of waste were found
being discarded into the river from the bridge by
commuters and travellers. It was observed that
38
various kinds of waste material were being thrown
through gaps and openings in the protective railings
and barriers installed on both sides of the bridge. The
material placed on record, including photographic
evidence, reveals accumulation of waste at the base
of bridge piers and the existence of visible gaps in the
protective structures through which such waste is
being routinely discarded. The photographs also
depict aquatic wildlife, including crocodiles and
muggers, in close proximity to such accumulated
waste, thereby underscoring the adverse impact of
such activities upon the fragile riverine ecosystem.
The observations of the Central Empowered
Committee disclose a disturbing state of affairs and
indicate a continuing threat to the ecological integrity
of the Chambal River and the National Chambal
Gharial Sanctuary.
39. Another issue of considerable significance has
been highlighted by the Central Empowered
th
Committee in its Report dated 7 May, 2026,
concerns the maintenance of Environmental Flows
(“E-Flows”) in the Chambal River and its tributaries.
The material placed on record indicates that
environmental flow is not merely a question of water
39
availability but relates to maintenance of the
quantity, timing, depth and seasonal flow patterns
necessary to sustain the ecological integrity of the
riverine ecosystem, including habitat connectivity,
breeding grounds, nesting islands, aquatic
biodiversity and overall geomorphological stability of
the National Chambal Gharial Sanctuary. The
Central Empowered Committee has, in this regard,
relied upon the scientific assessment undertaken by
the Wildlife Institute of India concerning the
ecological status of the Chambal River and the
requirements necessary for maintaining viable
habitats for endangered riverine species.
40. The scientific assessment referred to by the
Central Empowered Committee indicates that while
monsoon flows in the Chambal River have not
witnessed any substantial long-term decline, there
has been a significant reduction in lean-season and
summer flows over the last three decades. The report
records that discharge levels progressively decline
from November onwards and approach critically low
levels during the summer months, resulting in
habitat fragmentation, reduction in dissolved oxygen
levels, increase in water temperatures and severe
40
restrictions upon movement of aquatic fauna. The
report further highlights that major hydraulic
structures and water regulation projects (Dams) have
significantly affected downstream flows and that the
Chambal River is becoming increasingly dependent
upon its tributaries for maintenance of ecological
flows during the lean season. The assessment
cautions that any further interception, abstraction or
diversion of tributary flows may result in seasonal
fragmentation of the river system with serious
ecological consequences for species such as gharials,
dolphins, freshwater turtles and several avian
species dependent upon the riverine ecosystem.
41. The Central Empowered Committee has also
drawn attention to the deliberations of the Standing
Committee of the National Board for Wildlife in its
th th
90 meeting held on 6 April, 2026, wherein the
findings of the Wildlife Institute of India were
considered in the presence of the Central Water
Commission and other stakeholders. The material
placed on record indicates that both the Wildlife
Institute of India and the Central Water Commission
emphasized the necessity of maintaining
scientifically determined environmental flows in the
41
Chambal River and recommended a basin-level
assessment involving all relevant stakeholders. The
recommendation of the Central Empowered
Committee is that the Wildlife Institute of India, in
coordination with the Ministry of Jal Shakti, the
Central Water Commission and the concerned States,
should undertake a basin-level assessment regarding
maintenance of minimum environmental flows in the
Chambal River and its tributaries and that, pending
such assessment, no project adversely affecting
ecological flows within the National Chambal Gharial
Sanctuary should be permitted except essential
drinking water projects where no viable alternative
exists.
42. Another issue which merits consideration
concerns the notification issued by the State of
Rajasthan seeking de-notification of a portion of land
forming part of the National Chambal Gharial
Sanctuary. This Court was earlier apprised that
approximately 732 hectares of land falling within the
Sanctuary area was sought to be de-notified by virtue
rd
of the notification dated 23 December, 2025,
th
published on 9 March, 2026 under Section 18 of the
Wild Life (Protection) Act, 1972. Having regard to the
42
serious environmental implications arising from the
proposed reduction of the Sanctuary area, this Court,
nd
vide order dated 2 April, 2026, directed that the
aforesaid notification shall remain stayed.
43.
Pursuant thereto, the Ministry of Environment,
4
Forest and Climate Change has placed on record its
th
reply dated 19 May, 2026 stating that this Court, by
th
order dated 13 November, 2000 passed in Writ
Petition (Civil) No. 337 of 1995, had directed that,
pending further orders, no de-reservation of forests,
sanctuaries or national parks shall be effected. The
MoEF&CC has further pointed out that under the
th
Guidelines dated 15 March, 2011 issued by it, any
proposal for de-notification of a wildlife sanctuary,
after obtaining recommendation of the Standing
Committee of the National Board for Wildlife, is
required to be placed before this Court for obtaining
th
final approval in view of the aforesaid order dated 13
November, 2000. The Ministry has specifically relied
upon the stipulation contained in the said Guidelines
that, after recommendation by the Standing
Committee of the National Board for Wildlife, the
4
For short, “MoEF&CC”.
43
State Government or user agency is required to
approach this Court for final clearance before any de-
notification of a wildlife sanctuary can be
undertaken.
44.
The stand taken by the MoEF&CC raises
substantial issues touching upon the legality of the
impugned notification and the procedure required to
be followed before any portion of a notified wildlife
sanctuary can be de-notified. Since the notification
presently remains stayed by virtue of the order dated
nd
2 April, 2026, the issue shall be considered on the
next date after the concerned parties place their
respective stands on record.
IV. Operative Directions and Further Measures
45. In view of the aforesaid discussion, the material
placed on record, the compliance affidavits filed by
the respective States and the NHAI, and having
regard to the continuing and grave concerns relating
to rampant illegal sand mining activities, degradation
of protected wildlife habitats, operation of
unregistered and unidentified vehicles, inadequacy of
enforcement mechanisms and the threat posed to
critical public infrastructure in the affected regions,
44
this Court is of the considered opinion that further
directions have become necessary to ensure effective
enforcement, institutional accountability and
immediate operationalisation of surveillance and
preventive measures on the ground. Accordingly, in
exercise of the powers conferred upon this Court
under Article 142 of the Constitution of India, and
with a view to ensuring complete justice and effective
implementation of environmental and statutory
safeguards in the affected regions, the following
directions are issued: -
A. The States of Rajasthan, Madhya Pradesh and
Uttar Pradesh are directed to undertake immediate
and effective steps for augmentation of the field-
level enforcement officials in the respective Forest
Departments, including recruitment to vacant
posts of Forest Guards and other frontline
enforcement personnel entrusted with protection,
surveillance and patrolling duties in the affected
regions. The recruitment process in respect of
such posts shall be expedited and the concerned
States shall ensure that the process for
recruitment and filling up of vacant posts is
initiated forthwith and completed, as far as
45
practicable, within a period of one year from the
date of this Order. We, therefore, direct the Chief
Secretaries of all the three States i.e., Madhya
Pradesh, Rajasthan and Uttar Pradesh, to file
affidavits detailing concrete measures for advance
identification of vacancies and initiation of
recruitment process so that these crucial posts do
not remain vacant except under compelling
circumstances.
B. The States of Rajasthan, Madhya Pradesh and
Uttar Pradesh shall take immediate and effective
steps for establishment and operationalisation of
surveillance and monitoring infrastructure in the
affected regions, including CCTV surveillance
systems, integrated monitoring mechanisms,
control centres and allied technological
infrastructure. The said process shall be
undertaken on a war footing and all substantial
surveillance measures proposed pursuant to the
earlier orders of this Court shall be fast-tracked
and operationalised, as far as practicable, within a
period of six months from the date of this Order.
C. The concerned authorities of the States of
Rajasthan, Uttar Pradesh and Madhya Pradesh
46
are directed to undertake stringent, continuous
and coordinated enforcement action against
vehicles and machinery involved in illegal mining
and transportation activities within and around
the affected regions of the National Chambal
Gharial Sanctuary. The concerned authorities
shall ensure immediate interception, seizure and
initiation of confiscation proceedings, in
accordance with law, against all vehicles including
tractors, trolleys, excavators, dredgers, dumpers,
loaders and other machinery found operating
without valid registration particulars, with fake or
tampered number plates, without display of
registration marks, or otherwise in violation of the
provisions of the Motor Vehicles Act, 1988 and the
Central Motor Vehicles Rules, 1989.
D. The concerned States shall ensure initiation of
appropriate criminal prosecution under the
relevant provisions of the Motor Vehicles Act,
1988; the Bharatiya Nyaya Sanhita, 2023; the
Mines and Minerals (Development and Regulation)
Act, 1957; and other applicable statutory
enactments, not merely against the drivers of the
vehicles involved in illegal mining and
47
transportation activities, but also against the
owners, financiers, operators, contractors and all
other persons forming part of, facilitating or
otherwise connected with the organized illegal
mining network operating in the affected regions.
E. The concerned States shall ensure that all FIRs
and criminal proceedings relating to illegal mining
and transportation activities are effectively and
comprehensively investigated not merely against
the drivers of the vehicles involved, but also
against the owners, financiers, operators,
contractors and all other persons involved in
organizing, facilitating, financing or otherwise
benefiting from such illegal mining operations,
including identification of ownership networks and
financial beneficiaries connected therewith. The
concerned authorities shall further maintain
complete digital records pertaining to seizure
operations, confiscation proceedings, ownership
details, prior violations, criminal antecedents and
consequential enforcement action undertaken in
respect of such vehicles and machinery so as to
facilitate coordinated investigation, monitoring
48
and effective prosecution of persons involved in
organized illegal mining activities.
F. Having regard to the nature of duties discharged
by Forest Guards and other frontline enforcement
personnel and the increasing instances of attacks
upon such personnel while undertaking anti-
illegal mining, wildlife protection and forest
enforcement operations, the States of Rajasthan,
Madhya Pradesh and Uttar Pradesh shall examine
the need for issuing appropriate notifications
under Section 218(3) of the Bharatiya Nagarik
Suraksha Sanhita, 2023 [corresponding to Section
197(3) of the Code of Criminal Procedure, 1973], in
respect of such categories of enforcement
personnel as may be considered appropriate, so as
to afford protection in respect of bona fide actions
undertaken by them in discharge of their official
duties. The decision taken by the respective States
in this regard shall be placed on record by way of
affidavits by the next date of hearing.
G. The NHAI shall, in consultation with the Central
Empowered Committee, undertake installation of
high-resolution CCTV surveillance cameras
equipped with night vision capability on
49
appropriate high-mast structures on the bridge
and covering the area extending up to 1 kilometre
upstream and 500 metres downstream of the
bridge situated on National Highway-44 near the
Morena-Dholpur border. The surveillance
infrastructure shall be positioned in a manner that
effectively covers the riverbed and vulnerable
stretches falling within the aforesaid zone so as to
deter and detect illegal mining and excavation
activities in the vicinity of the bridge foundations
and supporting structures.
H. The live feed and surveillance access of the CCTV
cameras installed pursuant to the aforesaid
directions shall be made available by the NHAI to
the Police Department, Forest Department and/or
any other concerned enforcement authorities of
the States of Rajasthan and Madhya Pradesh so as
to facilitate coordinated monitoring, interception
and enforcement action in relation to illegal mining
and transportation activities in the affected region.
The NHAI shall further ensure that appropriate
access and connectivity mechanisms are
established for uninterrupted sharing of
surveillance data with the concerned authorities.
50
I. The surveillance infrastructure established by the
NHAI shall remain operational on a 24-hour basis.
The NHAI shall further ensure that the
surveillance system is equipped with adequate
storage, backup and connectivity facilities so as to
facilitate continuous monitoring, preservation of
footage and effective coordination with the
concerned enforcement agencies in the event of
any illegal activity being detected in the area
concerned.
J. The NHAI, the concerned State Authorities and the
District Administrations shall undertake
immediate measures to prevent dumping of waste,
debris and other materials into the Chambal River
from bridges and other public infrastructure
falling within or adjoining the National Chambal
Gharial Sanctuary. The NHAI shall install tamper-
proof fencing, protective mesh or such other
appropriate structures on the bridge concerned
and shall ensure sealing of all gaps, openings and
vulnerable locations so as to completely block all
avenues through which waste material may be
discarded into the river. The concerned authorities
shall further undertake regular monitoring of such
51
locations, install appropriate warning and
awareness signage, and ensure strict enforcement
action, including imposition of penalties in
accordance with law, against persons found
responsible for dumping waste or otherwise
polluting the river ecosystem.
K. The concerned States shall examine the feasibility
of formulating appropriate special employment
schemes, skill-development programmes and
livelihood generation initiatives, or effectively
operationalising and strengthening existing
welfare and employment schemes, for providing
sustainable employment opportunities to persons
residing in the sensitive regions affected by
rampant illegal mining activities, so as to reduce
economic dependence upon and local participation
in such unlawful mining operations. The States
shall particularly endeavour to create employment
opportunities for local youth and economically
vulnerable sections residing in and around the
affected areas so as to reduce economic
dependence upon illegal mining activities and
discourage local participation, facilitation and
52
support extended to organized illegal mining
networks operating in the region.
L. The concerned States shall also explore the
feasibility of involving local communities in
conservation, afforestation, eco-tourism, eco-
restoration, surveillance support and other
environmentally sustainable activities connected
with protection and preservation of the National
Chambal Gharial Sanctuary and adjoining
ecologically sensitive regions, so as to promote
community participation in environmental
protection and strengthen grassroots-level
conservation efforts in the affected areas.
M. The concerned Departments of the States of
Rajasthan, Madhya Pradesh and Uttar Pradesh
dealing with water resources, irrigation,
environment and forests, along with the Ministry
of Jal Shakti, Union of India and the Central Water
Commission, shall file separate affidavits by the
next date of hearing indicating the measures
presently being undertaken and the further steps
proposed to be taken for maintenance,
preservation and augmentation of environmental
flows in the Chambal River and its tributaries. The
53
affidavits shall specifically indicate the existing
flow management mechanisms, ongoing and
proposed projects having potential impact upon
ecological flows, inter-departmental coordination
measures, and the action plan formulated for
ensuring maintenance of adequate environmental
flows necessary for protection of the National
Chambal Gharial Sanctuary and its dependent
riverine ecosystem.
N. The States of Rajasthan, Madhya Pradesh, Uttar
Pradesh, Ministry of Jal Shakti and Central Water
Commission shall also specifically respond to the
recommendation made by the Central Empowered
Committee concerning maintenance of
Environmental Flows in the Chambal River and its
tributaries. The affidavits shall indicate the stand
of the respective States on the recommendations
made by the Central Empowered Committee, the
feasibility and manner of implementation thereof,
and the proposed timelines within which such
measures can be operationalised and whether any
existing or proposed water diversion, abstraction,
irrigation or river regulation projects are likely to
have an adverse impact upon the ecological flows
54
of the Chambal River and the steps proposed to
mitigate such impacts.
O. The Chief Secretaries of the States of Rajasthan,
Madhya Pradesh and Uttar Pradesh shall
periodically review compliance of the directions
issued by this Court at least once every two
months and place status reports before this Court
indicating the progress made in implementation of
surveillance, enforcement and recruitment
measures.
P. The Registry shall, forthwith, implead the Ministry
of Jal Shakti, Union of India, and the Central
Water Commission as party respondents in the
present proceedings. The Registry shall also
transmit a copy of this order to the Ministry of Jal
Shakti and the Central Water Commission for
compliance and for filing their respective affidavits
in terms of the directions contained hereinabove.
46. In the event of any difficulty arising in
implementation of the directions issued by this
Court, the States of Rajasthan, Madhya Pradesh and
Uttar Pradesh, the Ministry of Jal Shakti, Union of
India, the Central Water Commission, the National
Highways Authority of India and any other concerned
55
authority shall be at liberty to seek assistance from
and consult the Central Empowered Committee for
purposes of facilitating effective compliance with the
directions contained in the present order. The
Central Empowered Committee shall extend such
assistance as may be necessary and appropriate in
that regard.
47. The aforesaid directions are being issued in
furtherance of, and in continuation with, the
directions previously issued by this Court vide order
th
dated 17 April, 2026, having regard to the
continuing and emergent nature of the issues arising
in the present proceedings and the necessity of
ensuring effective implementation of surveillance,
enforcement and environmental protection measures
in the affected regions.
48. The States of Rajasthan, Madhya Pradesh and
Uttar Pradesh shall furnish fresh status/progress
reports indicating compliance with the directions
th
issued by this Court orders dated 17 April,
vide
2026 as well as the directions contained in the
present order, including the steps undertaken
towards strengthening surveillance infrastructure,
enforcement mechanisms, recruitment of field-level
56
personnel, seizure and confiscation proceedings, and
action taken against vehicles and persons involved in
illegal mining and transportation activities. The NHAI
shall also place on record a detailed progress report
indicating the steps undertaken pursuant to the
directions issued in the present order, particularly
with regard to installation and operationalisation of
surveillance infrastructure in and around the bridge
situated on National Highway-44 near the Morena-
Dholpur border. The aforesaid reports shall be filed
by the next date of hearing.
V. Interlocutory Application No. 143798 of
2026 [Filed by: Conservation Action Trust]
49. Having regard to the pleadings made in the
application, the submissions advanced by the
learned Amicus Curiae and the learned counsel
appearing on behalf of the intervenor (Conservation
Action Trust), and considering the nature of the
proceedings in seisin of this Court, the said
interlocutory application is disposed of with liberty to
the intervenor (Conservation Action Trust), to share
such information, material, inputs and suggestions
as it may consider appropriate with the learned
57
Amicus Curiae for assisting this Court in the present
proceedings.
VI. Interlocutory Application No. 143904 of
2026 [Filed by: Madhya Pradesh Forest
Employees Association]
50. The instant Interlocutory Application has been
filed on behalf of the Madhya Pradesh Forest
Employees Association, an association representing
Forest Guards, Forest Rangers, Foresters and other
frontline forest personnel engaged in protection of
forests, wildlife and natural resources within the
State of Madhya Pradesh. The applicants have sought
intervention in the present proceedings primarily on
the ground that the issues involved in the instant
matter concerning illegal mining, forest protection
and wildlife preservation are intrinsically connected
with the safety, welfare and service conditions of
frontline forest personnel entrusted with enforcement
and protection duties in ecologically sensitive
regions.
51. The application highlights the hazardous
conditions under which Forest Guards and other field
personnel are required to discharge their duties,
58
including risks arising from illegal mining operations,
poaching activities and attacks by organized groups
involved in forest offences. It has been contended that
despite several incidents involving death and fatal
injuries suffered by forest personnel while performing
official duties, there exists no comprehensive and
uniform policy within the State of Madhya Pradesh
governing compensation, compassionate
appointment, insurance coverage and other welfare
measures for the families of such personnel. The
applicants have further pointed out instances where
ex gratia compensation publicly announced by the
State authorities was allegedly not disbursed despite
lapse of considerable time and have sought
formulation of a comprehensive policy framework for
recognition, compensation and welfare measures in
respect of forest personnel who lose their lives in the
line of duty.
52. Having considered the pleadings made in the
application, the submissions advanced by the
learned Amicus Curiae and the learned counsel
appearing on behalf of the intervenor, namely, the
Madhya Pradesh Forest Employees Association, we
are of the considered opinion that the issues raised
59
in the present application disclose genuine concerns
affecting frontline forest personnel engaged in
protection and preservation of forests and wildlife in
vulnerable regions affected by illegal mining activities
and other environmental offences. The concerns
raised in the application also bear direct nexus with
the efficacy of enforcement and protection
mechanisms forming subject matter of the present
proceedings. Though the present application has
been instituted primarily in relation to the State of
Madhya Pradesh, we are of the considered opinion
that the issues highlighted therein are not confined
to one State alone but appear to be pervasive in
nature and have direct bearing upon frontline forest
personnel and enforcement staff functioning in all the
concerned States involved in the present
proceedings.
53. Accordingly, we issue notice in Interlocutory
Application No. 143904 of 2026. The States of
Madhya Pradesh, Rajasthan and Uttar Pradesh shall
file their respective replies to the aforesaid
interlocutory application by the next date of hearing,
specifically indicating therein the existing policy
framework, if any, governing compensation, ex gratia
60
assistance, compassionate appointment, insurance
coverage, welfare measures and other service benefits
extended to Forest Guards and other frontline forest
personnel who suffer death or fatal injuries in the
course of discharge of official duties, together with
details of implementation of such policies and the
measures proposed to be undertaken for
strengthening the welfare and protection framework
applicable to such personnel.
nd
54. List the matters on 22 July, 2026 for further
consideration.
….……………………J.
(VIKRAM NATH)
...…………………….J.
(SANDEEP MEHTA)
NEW DELHI;
MAY 26, 2026.
61