Facts
The petitioner filed a Public Interest Litigation (PIL) challenging Notification S.O 134(1) dated 07.01.2025, which constituted the State Environment Impact Assessment Authority (SEIAA) and the State Expert Appraisal Committee (SEAC) for Madhya Pradesh
Source reference: p. 1-2These bodies were established by the Ministry of Environment, Forest & Climate Change (MoEF&CC) under the Environment Protection Act, 1986, and the EIA Notification, 2006
Source reference: para. 2The petitioner alleged that the SEIAA and SEAC were functioning in gross violation of statutory provisions, having granted numerous environmental clearances contrary to environmental objectives across 65 meetings
Source reference: para. 4, 6Consequently, the petitioner sought the disbandment and fresh constitution of these bodies
Source reference: para. 5Issues
1. Whether the High Court should exercise its writ jurisdiction to quash the constitution of SEIAA and SEAC based on general allegations of statutory non-compliance
Source reference: para. 62. Whether the pendency of a similar matter before the Supreme of India regarding the same regulatory bodies precludes interference by the High Court
Source reference: para. 8Law Applied
The court's decision was governed by the Environmental Impact Assessment (EIA) Notification, 2006, and Section 3 of the Environment Protection Act, 1986, which provide the framework for the constitution and functioning of regulatory authorities like SEIAA and SEAC
Source reference: para. 2Furthermore, the court applied the principle of judicial restraint and comity, whereby a High Court refrains from adjudicating upon a matter when the same subject matter is already sub-judice before the Supreme Court of India
Source reference: para. 8Reasoning
The court noted that while the petitioner sought the abolition of the committees on grounds of alleged failure to fulfill the objectives of the Environmental Policy, 2006, the allegations were general in nature
Source reference: para. 6The respondents demonstrated that the Supreme Court of India was already seized of the matter in Vijay Kumar Das v. State of Madhya Pradesh (S.L.P. No.689/2025), where notices were issued on 23.07.2025
Source reference: para. 7-8In that Special Leave Petition (SLP), the reliefs sought specifically included declaring environmental clearances issued by the same respondent authority as illegal and seeking investigations into the conduct of the Member Secretary of SEIAA
Source reference: para. 7The High Court reasoned that since the Apex Court was already examining the transparency, accountability, and functioning of the SEIAA and SEAC in Madhya Pradesh, it would be inappropriate for the High Court to interfere in parallel proceedings
Source reference: para. 8Holding
The court held that no grounds for interference existed as the Supreme Court is currently examining the functioning of the SEIAA and SEAC
The High Court answered the issues in the negative and dismissed the Writ Petition
Source reference: para. 9Original Court PDF
Pradeep MishravsUnion Of India
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