From Tapovan to the Paris Agreement: Local Environmental Failures and Global LegalObligations in Indian Law

ABSTRACT

India stands at a crossroads. On one side is its constitutional promise to protect and improve the environment; on the other is the relentless pressure of economic development, energy poverty, and industrial growth. This paper critically examines how India's environmental and energy law framework navigates this tension — not merely on paper, but in real-world application. The objective of this research is to evaluate the adequacy, coherence, and enforceability of India's existing legal architecture in the context of contemporary environmental challenges, with particular focus on the transition from fossil fuels toward renewable energy. The methodology employed is doctrinal and analytical: primary sources including constitutional provisions, central statutes such as the Environment (Protection) Act, 1986, the Air (Prevention and Control of Pollution) Act, 1981, the Water (Prevention and Control of Pollution) Act, 1974, and the Energy Conservation Act, 2001 are examined alongside judicial decisions of the Supreme Court of India and the National Green Tribunal (NGT). Secondary sources including policy documents, international treaty obligations under the Paris Agreement, and academic commentary are also drawn upon. A key contemporary case study — the ongoing controversy over the felling of thousands of trees in Nashik's Tapovan area for the Simhastha Kumbh Mela 2026-27 — is examined as a live illustration of how enforcement deficits, institutional conflicts of interest, and civic resistance interact within India's environmental legal framework. Key findings reveal that while India possesses a robust statutory and constitutionalfoundation for environmental protection, significant gaps persist in enforcement, inter-

agency coordination, and the legal treatment of renewable energy transitions. The paper highlights three critical fault lines: the weak integration of energy policy into environmental law, the limited mandate of the NGT in energy-related disputes, and the tension between state-level discretion and national environmental standards. This research contributes an original analytical lens by approaching India's environmental and energy law not as two separate domains but as a deeply interconnected legal system that must evolve together to achieve meaningful climate justice.

keywords:- Environmental Law, Energy Transition, National Green Tribunal, Paris Agreement, Tree Protection Law, Constitutional Environmentalism, Climate Justice, Tapovan Nashik.

1. Introduction

There is a peculiar irony embedded in the way India talks about its environment. The nation that gave the world the doctrine of Vasudhaiva Kutumbakam — the idea that the entire earth is one family — now finds itself ranked among the most polluted countries on the planet. Its rivers carry industrial effluents; its cities choke under particulate matter; its forests are fragmented by development corridors. Yet, at the same time, India has erected one of the most elaborate statutory frameworks for environmental protection in the developing world, complete with constitutional mandates, a specialised tribunal, and voluntary international commitments that go beyond what many richer nations have pledged.

The tension between legal ambition and ground-level reality is nowhere more visible than at the intersection of environmental law and energy law. Energy is not simply a policy matter in India — it is a question of dignity. Hundreds of millions of Indians have historically lived without reliable access to electricity, and the state's drive to provide universal energy access has often come into conflict with environmental protection norms. Coal-fired power plants expanded even as pollution laws tightened. Forest land was diverted for thermal and hydropower projects even as courts upheld the public trust doctrine. The law, in short, has been asked to serve two masters simultaneously.

This paper does not simply catalogue the statutes and case law. Instead, it asks a harder question: does India's legal framework, as it currently stands, have the internal coherence and institutional strength to manage the environmental challenges that development and energy transition together demand? The answer, as this paper argues, is that the framework is structurally sound in parts but systemically fragmented in its totality. This fragmentation is not merely theoretical — it has real consequences on the ground, as the 2025-26 controversy over mass tree felling in Nashik for the Simhastha Kumbh Mela dramatically illustrates. Bridging these gaps is the central legal challenge of the coming decade.

2. Background: The Historical Architecture of Environmental and EnergyLaw in India

India's engagement with environmental law did not begin with environmental consciousness — it began with public health anxiety. The earliest environmental legislation, such as the Shore Nuisance (Bombay and Kolaba) Act, 1853 and the Merchant Shipping Act, 1858, were colonial instruments concerned primarily with navigation and sanitation, not ecological preservation. The real shift came in the 1970s, catalysed by two events: the 1972 United Nations Conference on the Human Environment in Stockholm, which India attended and actively shaped, and the domestic political context of the Emergency period, which paradoxically enabled sweeping legislative action.

The 42nd Constitutional Amendment of 1976 was a watershed moment. It insertedArticles 48-A and 51-A(g) into the Constitution of India, creating for the first time a constitutional obligation upon the state to protect and improve the environment and a corresponding fundamental duty upon every citizen to do the same. These provisions, though placed in the non-justiciable Directive Principles and the chapter on Fundamental Duties respectively, were progressively read by the Supreme Court as constitutionally significant obligations that could inform and even restrict the exercise of legislative and executive power.

The decade that followed saw rapid statutory development. The Water (Prevention and Control of Pollution) Act, 1974 established the Central and State Pollution Control Boards with powers to set standards and take enforcement action. The Air (Prevention and Control of Pollution) Act, 1981 extended a similar framework to air quality . The Environment (Protection) Act, 1986, enacted in the wake of the Bhopal Gas Tragedy of 1984, served as an umbrella legislation empowering the Central Government to take measures for environmental protection, 5 issue directions, and delegate authority to regulatory bodies. These three statutes form the legislative spine of India's environmental law even today. At the state level, Maharashtra enacted the Maharashtra (Urban Areas) Protection and Preservation of Trees Act, 1975 — a law that would become centrally relevant to the Nashik tree-felling episode four decades later.

Energy law, by contrast, developed along a parallel but largely separate track. The Electricity Act, 2003 was a landmark reform that unbundled the vertically integrated state electricity boards, introduced competition, and set up the Central Electricity Regulatory Commission (CERC) and State Electricity Regulatory Commissions (SERCs). However, its primary frame of reference was economic efficiency and access, not environmental protection. Renewable energy obligations — the Renewable Purchase Obligations (RPOs) — were introduced as mechanisms within this regulatory framework, but they operated more as market instruments than as legally binding environmental standards with penal consequences for non-compliance. The Energy Conservation Act, 2001, amended significantly in 2022, 7 created the Bureau of Energy Efficiency (BEE) and introduced the concept of energy intensity standards for industries. The 2022 amendment introduced a Carbon Credit Trading Scheme, bringing India's energy law for the first time into formal dialogue with climate law. Yet this integration remains nascent, and the legal relationship between carbon markets, environmental regulation, and energy transition is still to be authoritatively defined by courts or through comprehensive legislation.

3. Legal Analysis

3.1 Constitutional Environmentalism and Judicial Expansion

The most distinctive feature of India's environmental law is the extraordinary role played by the judiciary in expanding constitutional guarantees to cover environmental rights. In M.C. Mehta v. Union of India (1987), the Supreme Court held that the right to life under Article 21 of the Constitution necessarily includes the right to a wholesome environment. This interpretive move transformed environmental law from a purely statutory domain into one with constitutional backing, 9 enabling courts to issue sweeping directions to state and private actors alike. The Court developed indigenous legal doctrines to fill gaps in legislation. The absolute liability principle, articulated in M.C. Mehta v. Union of India (Oleum Gas Leak Case, 1987), 10 held that enterprises engaged in hazardous activities are absolutely liable for harm caused by their operations, without the defence of due care available under the English rule of Rylands v. Fletcher. The public trust doctrine, imported from American jurisprudence and applied in M.I. Builders Pvt. Ltd. v. Radhey Shyam Sahu (1999) 11 , held that natural resources such as rivers, forests, and air are held by the state in trust for the people and cannot be alienated for private commercial use without meeting a high threshold of public interest.

These doctrines have been applied in energy-related disputes with significant consequences. In Lafarge Umiam Mining Pvt. Ltd. v. Union of India (2011), the Supreme Court held that forest diversion for mining or energy projects requires not just procedural compliance with the Forest (Conservation) Act, 1980 but a substantive assessment of cumulative environmental impact. The precautionary principle — another judicially imported doctrine — requires that where there is uncertainty about environmental harm, the burden of proof lies on the project proponent to demonstrate safety, not on the state or affected communities to prove harm.

3.2 The National Green Tribunal: Promise, Performance, and Jurisdictional Limits

The National Green Tribunal Act, 2010 created a specialised judicial body with original jurisdiction over environmental disputes 14 . The NGT was designed to remedy a significant institutional weakness: that environmental litigation in ordinary civil courts was slow, technically complex, and inaccessible to affected communities. The Tribunal was given the power to award compensation, issue directions for restoration of the environment, and enforce compliance with environmental laws.

In practice, the NGT has been a mixed success. It has been prolific — issuing thousands of orders on issues ranging from river pollution to construction in eco-sensitive zones — and in several cases its interventions have produced measurable environmental improvement. The odd-even vehicle scheme in Delhi, while primarily a policy measure, was implemented within a legal framework that the NGT actively monitored. Similarly, its directions on industrial effluent discharge into the Ganga basin have compelled government action that administrative processes alone had failed to produce.

However, the NGT's jurisdiction is explicitly limited to statutes listed in its Schedule, and critically, neither the Electricity Act, 2003 nor the Energy Conservation Act, 2001 16 is included. This means that renewable energy projects, thermal power plants, and grid infrastructure — all of which have significant environmental footprints — fall outside the

NGT's direct jurisdiction. Disputes involving such projects must typically be routed through the regulatory commissions established under the Electricity Act, which have no mandate to adjudicate environmental harm, or through the High Courts and the Supreme Court under

Articles 226 and 32 respectively, which are not specialised environmental forums. This jurisdictional gap represents one of the most significant structural deficiencies in India's environmental and energy law interface. A coal-fired power plant that violates emission norms falls under the NGT's jurisdiction through the Air Act; the same plant's decision to expand capacity — which may involve forest diversion, water extraction, and increased emissions — falls under the CERC's jurisdiction, where environmental considerations are secondary. The result is fragmented adjudication and regulatory arbitrage.

3.3 India's International Obligations and Domestic Implementation

India is a party to the United Nations Framework Convention on Climate Change (UNFCCC) and its Paris Agreement, adopted in 2015. Under its Nationally Determined Contribution (NDC) submitted and updated in 2022, India committed to reducing the emissions intensity of its GDP by 45 percent from 2005 levels by 2030, achieving approximately 50 percent of its cumulative electric power installed capacity from non-fossilfuel-based energy resources by 2030, and creating an additional carbon sink of 2.5 to 3 billion tonnes of CO2 equivalent through additional forest and tree cover — a commitment rendered

deeply ironic in the light of the Nashik episode discussed below.

These commitments are politically significant but legally complex in their domestic translation. The Paris Agreement 19 operates on the principle of nationally determined contributions — states set their own targets and the international mechanism is one of transparency and peer pressure, not binding legal obligation with enforcement consequences.

In domestic law, India's NDC targets have not been translated into binding statutory obligations. There is no Indian statute that creates a legally enforceable right to a specific level of emissions reduction, as exists in the United Kingdom through the Climate Change Act, 2008. The Environment (Protection) Act, 1986 does empower the Central Government to issue notifications setting emission standards, and this power has been used to introduce progressively stricter norms for thermal power plants. However, compliance remains inconsistent, and the legal consequences for non-compliance — typically notices and

prosecution under the EPA — are widely regarded as inadequate deterrents for large industrial operators.

4. Discussion: Three Fault Lines in the Framework

4.1 The Enforcement Deficit

The most frequently cited problem with India's environmental law is not its content but its enforcement. The Pollution Control Boards, which are the primary enforcement agencies under the Water and Air Acts, are chronically underfunded, technically understaffed, and institutionally compromised. 21 Studies by the Comptroller and Auditor General and by independent researchers have consistently found that a significant proportion of industrial units operate without valid consents, that effluent monitoring is irregular, and that prosecutions for violations are rare and slow.

The reasons for this enforcement deficit are structural rather than merely

administrative. The Pollution Control Boards are state-level bodies that depend on state governments for funding, and state governments are simultaneously the promoters of industrial development that the Boards are meant to regulate. This conflict of interest is not hypothetical — it manifests in the routine grant of environmental clearances to politically favoured projects, the dilution of conditions attached to clearances, and the tolerance of violations by economically significant industries.

4.1.1 Case Study: The Nashik Tapovan Tree Felling and the Simhastha

Kumbh Mela (2025-2026)

Few episodes in recent Maharashtra history illustrate the enforcement deficit in environmental law as vividly — or as uncomfortably — as the ongoing controversy over the proposed felling of thousands of trees in Nashik's Tapovan area for the Simhastha Kumbh Mela, scheduled to run from October 2026 to July 2027 along the banks of the Godavari river. The sequence of events that unfolded from late 2025 onwards is not simply a story about trees. It is a story about what happens when development ambition, political competition, and institutional accountability collide in a legal framework that is structurally ill-equipped to manage the conflict. The Simhastha Kumbh Mela is held once every twelve years in Nashik and Trimbakeshwar. For the 2027 edition, the Nashik Municipal Corporation (NMC) proposed a dramatic expansion of the Sadhugram — the temporary residential settlement built for the sadhus and religious orders who anchor the festival. In 2015, the Sadhugram had occupiedapproximately 350 acres in the Tapovan area. For 2027, the NMC proposed expanding this to nearly 1,200 acres, driven by projections that the number of attending sadhus would grow from 2.5 lakh to approximately 10 lakh, and that overall pilgrim footfall could reach eight crore. The NMC's ambition was openly calibrated against what Prayagraj had achieved during the 2025 Maha Kumbh Mela — an event budgeted at over Rs. 73 billion — and Maharashtra was determined to match that scale.

The land chosen for this expansion, however, was not empty. It was Tapovan — a green lung of Nashik, home to hundreds of trees, many of them decades old, some reportedly over a century in age, including ancient banyan and peepal trees that had shaped the ecological character of the Godavari riverbank for generations. In November 2025, the NMC published a notice proposing the removal of approximately 1,700 trees from the Tapovan area, 23 inviting public objections as required under the Maharashtra (Urban Areas) Protection and Preservation of Trees Act, 1975. The response was immediate and fierce. Environmental activists Raaju Desle, Rohan Deshpande, and Rajendra Bagul led what was described as a Chipko Andolan-style protest, 24 with citizens physically embracing tree trunks to prevent their felling, holding placards reading 'Save Trees, Save the Environment;; and 'Clean Nashik', Green Nashik; The public hearing held by the NMC on objections descended into scenes of civic anger that the corporation had not anticipated.

What made the controversy legally significant — and constitutionally troubling — was the revelation that the NMC had already been acting before this public process had even begun. Before the Tapovan row became public, the NMC had quietly felled 1,273 trees in September and October 2025 to make way for new solid waste management systems, with no public consultation that activists or citizens were aware of. Trees were simply gone, and the city did not notice until months later. When this came to light, it changed the texture of the debate entirely. It was no longer about one site or one proposal — it was about a pattern. A civic body that treated tree-felling as an administrative detail rather than an ecological decision requiring legal compliance. By December 2025, the total number of trees proposed for removal across all Kumbh-related works had grown to over 4,000, with plans extending to the Godavari riverbank, approach roads, ghats, and parking infrastructure. The political dimension of the controversy sharpened quickly. MNS chief Raj Thackeray publicly accused the government of using the Kumbh Mela as a pretext to clear land that would ultimately be transferred to industrialists close to the ruling party. Actor Sayaji Shinde, himself a member of the NCP which forms part of the ruling coalition, joined the opposition, stating he would speak against his own government if it persisted with the felling plan. Shiv Sena (UBT) leader Aaditya Thackeray described the plan as ;mindless environmental vandalism; in the name of religious tourism, warning that it amounted to 'Raavan Raj' Simultaneously, in a politically awkward turn, the strongest opposition from within the religious community itself emerged with several saints and mahant questioning whether the destruction of the ancient trees was compatible with the spiritual purpose of the kumbh mela at all.

The judiciary intervened at multiple levels. The NGT's Pune bench, approached by advocate Shriram Pingle alleging violations of mandatory environmental procedures, granted an immediate stay on tree felling and constituted a joint committee to inspect the site and submit a report with recommendations. 25 Separately, the Bombay High Court directed that no tree shall be cut in the Tapovan area without its prior permission, 26 after the state's Advocate General confirmed that the Tree Authority process was still underway and no final decision had been taken. The NGT extended its stay multiple times through early 2026 — first until January 15, then until April 6, and subsequently until April 28 — as the committee's report, filed on February 20, 2026, was not circulated to all parties in time for them to file responses. Despite these orders, reports from Nashik in April 2026 indicated that approximately 1,000 trees had already been felled on the ground, including century-old banyans, before and during the pendency of judicial proceedings.

From the standpoint of environmental law, this episode exposes three specific legal failures that deserve close attention. First, it reveals a structural conflict of interest at the heart of the Maharashtra Trees Act: the NMC, which is itself the designated Tree Authority under

the 1975 Act in urban Nashik, was simultaneously the applicant seeking permission to fell thousands of trees and the body empowered to grant that permission. This is not an incidental administrative oddity — it is a design flaw that makes genuine independent oversight structurally impossible without external intervention from courts or the NGT. Second, the episode demonstrates the irreversibility problem in environmental enforcement. By the time the NGT granted its stay and the High Court issued directions, 1,273 trees had already been felled without any judicial scrutiny. Environmental harm, unlike financial fraud, cannot be undone by a court order. A tree that has stood for a century cannot be restored by a tribunal direction, and the NMC's suggestion of transplanting grown trees sourced from Andhra Pradesh was dismissed by experts as having a survival rate too poor to constitute meaningful remediation. Third, and most ironically, the government simultaneously sought to brand the 2027 event a ;green Kumbh; while proposing to fell nearly 1,800 grown trees for its infrastructure — a contradiction so glaring that even sympathetic commentators found it impossible to reconcile, and one that illustrates how ecological commitment functions in Indian governance more as a public relations exercise than as a legal obligation.

The Nashik Tapovan controversy, still unresolved as of mid-2026 with NGT proceedings ongoing, stands as a living case study in what this paper has called the enforcement deficit. It shows how the absence of prior environmental oversight, the conflict of interest within regulatory bodies, the slow pace of judicial intervention relative to the speed

of physical destruction, and the inadequacy of compensatory measures combine to render legal protection of urban ecology hollow in practice, even where statutes providing that protection nominally exist.

In the energy sector, the enforcement problem takes a different but equally structural form. Large thermal power plants are often owned by state utilities, creating situations where the regulated entity and the regulator's principal are the same. Private sector renewable energy

developers operate in a more commercially competitive environment, but they face different enforcement challenges — rapid project approvals that sometimes bypass environmental due diligence, inadequate assessment of cumulative impacts of multiple wind or solar installations in a single landscape, and the displacement of local communities whose legal rights are often inadequately assessed.

4.2 The Renewable Energy Paradox

Renewable energy is widely understood as the solution to India's environmental and climate challenges, and the legal framework has increasingly supported its expansion. The Electricity Act's RPO mechanism, the Solar Energy Corporation of India, the National Solar

Mission, and numerous state-level incentive schemes have collectively driven an extraordinary growth in solar and wind capacity. India's installed renewable energy capacity crossed 200 GW in 2024, making it one of the world's largest renewable energy markets.

Yet the expansion of renewable energy is not environmentally neutral, and this uncomfortable reality has been slow to enter legal discourse. Large-scale solar parks in Rajasthan and Gujarat have been developed on land previously classified as wasteland — but much of this land supported significant biodiversity, including grassland ecosystems that are among the most threatened in India. Wind farms in the Western Ghats, an internationally recognised biodiversity hotspot, have been associated with raptor mortality and habitat fragmentation. Hydropower projects in the Himalayan region have faced scrutiny following the 2021 Chamoli disaster, which demonstrated that the cumulative environmental impacts of multiple run-of-the-river projects in a single river basin can be catastrophically underestimated.

The legal framework has not adequately responded to these challenges. The environmental impact assessment process under the EIA Notification, 2006 28 is project- specific and does not mandate cumulative impact assessments for all categories of renewable energy projects. The Draft EIA Notification, 2020 proposed further dilutions to public consultation requirements, 29 generating significant civil society opposition. The result is that renewable energy, which ought to be the legal system's preferred option, proceeds through a framework 30 as inadequately equipped to manage its environmental risks as it is to manage those of fossil fuels.

4.3 Centre-State Tensions and the Federal Dimension

Environmental law in India operates in a complex federal space. Entry 17 of the State List in the Seventh Schedule assigns water — including water supplies, irrigation, and canals — to the states, while Entry 56 of the Union List gives Parliament power to regulate interstate rivers. Entry 48 of the State List covers industries subject to state control, while Entry 52 of the Union List covers industries regulated by Parliament in the public interest. The result is a patchwork of concurrent, exclusive, and disputed jurisdictions that creates significant legal uncertainty.

The Nashik episode also has a federal dimension worth noting. Tree protection in urban areas falls primarily under state law — the Maharashtra Trees Act — and the Tree Authority is a municipal body. The Central Government's Ministry of Environment, Forest and Climate Change (MoEFCC) has no direct jurisdiction over urban tree felling that does not involve forest land. This means that when a municipal corporation decides to clear thousands of trees for an event, the central environmental regulatory apparatus is effectively a bystander, and protection depends entirely on the initiative of NGOs, individual petitioners, and the willingness of state High Courts and the NGT to intervene.

In energy law, this federal complexity is compounded by the political economy of electricity. Distribution of electricity is a state subject, and state governments have historically subsidised agricultural power consumption at levels that make the electricity sector financially unviable, creating barriers to private investment and distorting the economics of the energy transition. When the Central Government attempts to impose uniform renewable energy obligations or carbon pricing mechanisms, states with different energy endowments and political priorities resist. The legal resolution of these disputes will be critical in determining whether India can implement the coherent national energy transition strategy that its climate commitments require.

5. Conclusion

India's environmental and energy law framework is neither the failure its critics suggest nor the success its architects intended. It is something more complex and more interesting: a legal system that contains the intellectual and doctrinal resources to manage the transition to a sustainable energy future, but that is held back by institutional fragmentation, enforcement deficits, and a federal architecture that resists the central coordination which climate policy demands. The Nashik tree-felling controversy of 2025-26 distils all of these systemic weaknesses into a single, concrete, ongoing episode — one that is unfolding not in some remote industrial corridor, but in a riverine heritage city, in the name of a religious festival, with the full knowledge of the state government and the judiciary alike.

Three reforms emerge from this analysis as particularly urgent. First, the conflict-of- interest problem in urban tree governance must be resolved by separating the Tree Authority function from the municipal corporation that is also the primary applicant for tree-felling permissions. An independent, professionally staffed district-level Tree Authority — insulated from the municipal body seeking clearances — would go some distance toward ensuring that the public hearings required under state law are not mere procedural theatre.

Second, the jurisdictional mandate of the National Green Tribunal should be expanded to include the Electricity Act and the Energy Conservation Act, enabling the Tribunal to exercise integrated oversight over the environmental impacts of energy decisions. Equally, the NGT's capacity for prior restraint — its ability to intervene before environmental harm occurs rather than after — needs to be strengthened through procedural reforms that allow petitioners to approach it on an emergency basis with shorter notice requirements.

Third, India requires legislation that translates its Paris Agreement NDC commitments into domestic legal obligations with defined timelines, measurable indicators, and accountability mechanisms. The model of the United Kingdom's Climate Change Act — which created independent statutory targets, a monitoring body, and parliamentary accountability — offers one template, though it would need significant adaptation to India's federal and institutional context. Without such a statute, India's commitment to creating additional carbon sinks through forest and tree cover — a commitment undermined, even symbolically, by events in Nashik — remains aspirational rather than legally operative.

Ultimately, the challenge facing India's environmental and energy law is not a shortage of good law. It is a shortage of legal seriousness — the institutional willingness to treat environmental obligations as real constraints rather than procedural hurdles to be managed. The gap between India's constitutional promise and its environmental reality will be closed, if at all, not by new statutes alone but by a legal culture that takes those statutes at their word — and by citizens who, like those who embraced the trees of Tapovan, are willing to insist that it does.

References / Bibliography

1. M.C. Mehta v. Union of India, AIR 1987 SC 1086 (Oleum Gas Leak / Absolute Liability Case).

2. M.C. Mehta v. Union of India, (1987) 4 SCC 463 (Right to Wholesome Environment under Article 21).

3. M.I. Builders Pvt. Ltd. v. Radhey Shyam Sahu, AIR 1999 SC 2468 (Public Trust Doctrine).

4. Lafarge Umiam Mining Pvt. Ltd. v. Union of India, (2011) 7 SCC 338 (Cumulative Impact Assessment).

5. Vellore Citizens Welfare Forum v. Union of India, AIR 1996 SC 2715 (Precautionary Principle; PolluterPays).

6. T.N. Godavarman Thirumulpad v. Union of India, (1997) 2 SCC 267 (Ongoing Forest Conservation).

7. Constitution of India, 1950 — Articles 21, 48-A, 51-A(g), and Seventh Schedule (Lists I, II, III).

8. The Environment (Protection) Act, 1986.

9. The Water (Prevention and Control of Pollution) Act, 1974.

10. The Air (Prevention and Control of Pollution) Act, 1981.

11. The Forest (Conservation) Act, 1980.

12. The Electricity Act, 2003.

13. The Energy Conservation Act, 2001 (as amended by the Energy Conservation (Amendment) Act, 2022).

14. The National Green Tribunal Act, 2010.

15. The Maharashtra (Urban Areas) Protection and Preservation of Trees Act, 1975.

16. The Maharashtra Trees (Preservation) Act, 1975.

17. Environment Impact Assessment Notification, 2006, Ministry of Environment, Forest and Climate Change(MoEFCC).

18. India's Updated Nationally Determined Contribution, MoEFCC, Government of India, 2022.

19. United Nations Framework Convention on Climate Change (UNFCCC), 1992.

20. Paris Agreement, 2015, UNFCCC.

21. Climate Change Act, 2008 (United Kingdom) — comparative reference.

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24. Comptroller and Auditor General of India, Report on Environmental Clearances and Post- ClearanceMonitoring (2016).