The Supreme Court dismissed the appeals, upholding the NGT’s decision that the petrol pump complied with environmental norms under CPCB guidelines. It imposed costs of ₹50,000 for suppressing parallel proceedings before the High Court, emphasizing judicial integrity. The Court clarified that challenges under state municipal laws remain open for independent adjudication.
Facts Of The Case:
The case involved a dispute over the construction of a petrol pump by Reliance BP Mobility Ltd. on Khasra No. 109/1/2 in Bhopal, Madhya Pradesh. The appellants, including Arun Kumar Sharma and others, challenged the project before the National Green Tribunal (NGT), alleging violations of environmental guidelines, including improper distance from residential areas, schools, and hospitals as per CPCB norms. They also contested the No-Objection Certificate (NOC) issued by the District Collector, claiming it violated the Petroleum Rules, 2002.The NGT constituted a Joint Committee, which found no designated residential areas, schools, or hospitals within the prohibited 50-meter radius. The tribunal dismissed the application, ruling that the project adhered to legal requirements. The appellants then filed a civil appeal before the Supreme Court, which discovered they had simultaneously pursued a writ petition in the High Court challenging the same NOC under the Madhya Pradesh Nagar Tatha Gram Nivesh Adhiniyam, 1973, without disclosing this parallel litigation.The Supreme Court dismissed the appeals, imposing ₹50,000 in costs for suppressing material facts and initiating frivolous litigation, possibly to serve the business interests of one appellant. However, it clarified that the High Court could independently examine the municipal law challenge. The judgment reinforced the importance of transparency and bona fide conduct in judicial proceedings.
Procedural History:
The procedural history of the case began with the appellants filing an original application before the National Green Tribunal (NGT) in March 2024, challenging the establishment of a petrol pump by Reliance BP Mobility Ltd. in Bhopal. They alleged violations of environmental guidelines and improper issuance of the No-Objection Certificate (NOC) by the District Collector. The NGT constituted a Joint Committee to inspect the site, which submitted a report in July 2024 confirming compliance with the Central Pollution Control Board (CPCB) norms. Based on these findings, the NGT dismissed the application in August 2024, and a subsequent review petition was also rejected in October 2024.The appellants then filed civil appeals before the Supreme Court, which discovered they had simultaneously initiated a writ petition in the High Court challenging the same NOC under municipal laws without disclosing this parallel proceeding. The Supreme Court dismissed the appeals in July 2025, imposing costs for suppressing material facts and abusing the judicial process. It clarified that the High Court could independently adjudicate the pending writ petition, ensuring no overlap with the environmental issues already resolved by the NGT. The judgment underscored the importance of procedural integrity and transparency in litigation.
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Court Observation:
The Supreme Court made critical observations on judicial propriety and environmental compliance in its judgment. It noted the appellants’ failure to disclose parallel proceedings before the High Court while pursuing the NGT appeal, characterizing this as a suppression of material facts that undermined the integrity of the judicial process. The Court emphasized that access to justice must be accompanied by bona fide intentions, particularly in environmental matters where public interest is paramount.On substantive issues, the Court accepted the NGT’s findings that the petrol pump project complied with CPCB guidelines, particularly regarding the mandatory 50-meter distance from residential areas and sensitive establishments. It observed that the Joint Committee’s report provided conclusive evidence of compliance, and found no merit in the appellants’ environmental concerns. However, the Court clarified it was not examining the separate challenge under municipal laws pending before the High Court, preserving that issue for independent determination.Significantly, the Court expressed skepticism about the appellants’ motives, suggesting the litigation appeared driven by business rivalry rather than genuine environmental concerns. This observation formed the basis for imposing exemplary costs, serving as a deterrent against frivolous litigation and forum-shopping tactics that waste judicial resources. The judgment reinforced the principle that environmental regulations must be balanced against bona fide commercial development when statutory compliance is established.
Final Decision & Judgement:
The Supreme Court delivered a decisive judgment dismissing the civil appeals and upholding the National Green Tribunal’s (NGT) decision approving the petrol pump’s construction. The Court imposed costs of ₹50,000 on the appellants for suppressing material facts and initiating parallel proceedings before the High Court without disclosure, finding this conduct amounted to an abuse of judicial process. While affirming the NGT’s conclusion that the project complied with environmental norms under CPCB guidelines and Petroleum Rules, the Court expressly reserved all questions regarding alleged violations of the Madhya Pradesh Nagar Tatha Gram Nivesh Adhiniyam, 1973 for independent determination by the High Court in the pending writ petition. The judgment underscored that environmental litigation must be pursued with clean hands and bona fide intentions, particularly when challenging projects that have secured all requisite statutory approvals after due diligence. By distinguishing between the resolved environmental compliance issues and the outstanding municipal law questions, the Court balanced its role in upholding regulatory compliance with preserving the High Court’s jurisdiction over separate legal challenges.
Case Details:
Case Title: Arun Kumar Sharma & Ors. vs. State of Madhya Pradesh & Ors. Citation: 2025 INSC 826 Civil Appeal No.: Civil Appeal Nos. 3263-3264 of 2025 Date of Judgment: July 14, 2025 Judges/Justices:Justice Pamidighantam Sri Narasimha & Justice Joymalya Bagchi
Download The Judgement Here