Criminal Law – Quashing of Prosecution – Abuse of Process – Arms Licence Scam Allegation – Appellant, an IAS officer and District Magistrate-cum-Licensing Authority, Saharsa, accused of issuing arms licences without due verification – Chargesheet filed after 15 years of FIR, despite earlier closure report finding allegations against him to be false – Sanction under Section 197 CrPC held to be non-speaking and mechanical – Held: Prosecution is liable to be quashed due to inordinate delay, lack of fresh evidence, improper sanction, and violation of Article 21 (right to speedy trial) [Paras 2, 4, 5, 6, 8, 10, 11, 12, 13, 14, 19, 20].

Service Law – Departmental Proceedings – Exoneration – Appellant had been subjected to departmental enquiry for irregularities in issuance of arms licences – Explanation submitted by appellant was accepted and departmental proceedings were closed in 2016 – Held: Discharge from departmental proceedings assumes relevance when criminal prosecution is based on the same facts and there is absence of any act of corruption or criminal conspiracy [Paras 5, 8, 20].

Criminal Procedure – Section 197 CrPC – Sanction for Prosecution – Sanction granted to prosecute appellant was vague, lacking application of mind, and failed to evaluate material evidence – Mere reproduction of statutory language is not sufficient – Held: Sanction must reflect objective consideration of facts and evidence; failure to do so renders sanction order invalid, thereby vitiating cognizance – All consequential actions including chargesheet and cognizance quashed [Paras 10, 11, 12].

Criminal Procedure – Delay in Investigation – Right to Speedy Trial – Delay of 11 years between permission for further investigation and filing of supplementary chargesheet – No explanation offered for such delay – Appellant kept under cloud of criminal prosecution despite earlier closure of case – Held: Delay in investigation constitutes violation of right under Article 21; investigation cannot continue endlessly without justification – Chargesheet and prosecution quashed on this ground as well [Paras 13, 14, 19].

Arms Act – Discretion under Section 13(2A) – Appellant relied on discretionary power to issue licences without police verification if report is not received in time – However, in one instance, licence was issued within 2 days of calling for report – Held: Though such discretion exists, it must be exercised reasonably; one unjustified instance not sufficient for prosecution when other licences not similarly scrutinised and departmental authorities have already accepted explanation [Paras 7, 8, 9, 20].

Criminal Procedure – Supplementary Chargesheet – Further Investigation – Leave granted under Section 173(8) CrPC implies ongoing judicial stewardship – Held: Courts not functus officio after granting such leave – They are duty-bound to ensure investigation proceeds fairly and reasonably – Inordinate delay must be accounted for and explained [Para 21(i)].

Judicial Directions – Delay in Investigation and Sanction – Courts directed to: (i) Ensure investigating agencies explain prolonged delays when highlighted by accused; (ii) Recognise that unreasonable investigation delays can vitiate prosecution; (iii) Ensure sanctioning authorities apply mind to material evidence; (iv) Allow accused or complainant to seek updates or quashing in cases of prolonged or unjustified investigation [Para 21(ii)–(iv)].

Decision: Appeal allowed – Cognizance order and prosecution quashed – Appellant discharged from all criminal proceedings – Pending applications disposed of [Para 20].

Environmental Law – Conservation of Aravali Hills – Need for uniform definition – Aravali Hills and Ranges spanning four states held ecologically vital for biodiversity, desertification prevention, and climate resilience – Dispute arose over differing definitions by states – Court accepted Committee’s recommendation using elevation-based criteria (100m) for defining Aravalis – Court directed preparation of geo-ecological Management Plan for Sustainable Mining (MPSM) across Aravali districts, similar to Saranda study, before any new leases – No mining to be permitted in core/inviolate zones including tiger reserves, Ramsar sites, aquifer zones, and ESZs [Paras 1-5, 29-30, 38, 50].

Mining Regulation – Sustainable Mining – Ongoing mining to continue strictly per Committee’s safeguards – New leases to be withheld till MPSM is finalized – Recommendations for expert monitoring, reclamation of abandoned mines, prohibition in ecologically sensitive areas, and restriction on explosive use accepted – Illegal mining flagged; ILMS system to be implemented for real-time oversight [Paras 7-9, 18, 38, 49-50].

Judicial Oversight – Role of Amicus Curiae – Special Bench constituted to harmonize issues from M.C. Mehta and Godavarman cases – Court recognized and recorded appreciation for Amicus and legal team for their sustained contribution to ecological jurisprudence [Paras 20, 51].

Decision:

Committee Report – Definition of Aravalis – Accepted – The Court accepted the operational definition of Aravali Hills and Ranges as recommended by the Committee constituted by the MoEF&CC, based on elevation from local relief – Court held that this uniform definition will guide mining regulation across Delhi, Haryana, Rajasthan, and Gujarat [Para 50(i)].

Mining in Core/Inviolate Areas – Prohibition Upheld – Mining in designated core/inviolate zones (including protected areas, tiger reserves, Ramsar sites, aquifer zones, areas with government plantations) shall remain prohibited – Exceptions allowed only for critical, strategic, and atomic minerals as per MMDR Act [Para 50(ii)].

Sustainable Mining – Conditional Approval – Recommendations for regulated sustainable mining accepted – Existing legal mining operations allowed to continue with strict compliance of safeguards outlined in Committee Report (Para 8) – No new leases to be granted until a Management Plan for Sustainable Mining (MPSM) is prepared [Paras 50(iii), 50(v), 50(vii)].

Management Plan for Sustainable Mining (MPSM) – Mandatory – Directed MoEF&CC to prepare MPSM for entire Aravali range through ICFRE – Plan to identify zones for mining, conservation, ecological thresholds, and post-mining restoration measures – Only after MPSM finalization can new mining activities be permitted [Para 50(iv)-(vi)].

Ban on New Mining Leases – Interim Restriction – No new mining leases to be granted in Aravalis until MPSM is finalized – Ensures scientific, ecologically sensitive and uniform mining policy across the region [Para 50(v)].

Complete Ban Refused – Blanket prohibition on all mining rejected – Court held total bans may incentivize illegal mining and lead to criminalisation of resource extraction – Maintained that legal mining with proper safeguards should continue [Paras 47-48].

Motor Vehicles Law – Cashless Treatment Scheme – Section 162(1) MV Act – The Court considered the plea for a cashless treatment scheme for road accident victims during the "Golden Hour" – Held: The Justice A.M. Sapre Committee is requested to deliberate on the reliefs sought regarding cashless treatment, reimbursement of post-discharge expenses, and integration with the Ayushman Bharat Pradhan Mantri Jan Arogya Yojana (AB-PMJAY) to ensure immediate medical care. [Paras 4-5].

Road Safety – Electronic Monitoring and Enforcement – Section 136A MV Act – Implementation of Swift Response Protocols – Context of high fatality rates on highways – Held: States and Union Territories must work on developing Swift Response Protocols to ensure immediate help reaches accident victims. NHAI directed to file an affidavit regarding the implementation of electronic monitoring and patrolling protocols. [Paras 11(2)-11(3)].

Constitutional Law – Repugnancy and Abatement of Trials – Article 254(2) Constitution of India – Validity of UP Act No. 4 of 2023 – Context where the State of UP enacted a law abating trials for MV Act offences pending on 31.12.2021 – Held: The abatement of proceedings for offences like Drunken Driving (Section 185 MV Act) removes deterrence and may be arbitrary. The Court expressed serious concern over the blanket abatement of trials for non-compoundable offences, noting that such legislative action might violate Article 14 by creating disparity between those who paid fines and those who did not. The State of UP is directed to file an affidavit justifying section-wise abatement. [Paras 9, 15-25].

Motor Vehicles Law – Drunken Driving – Section 185 MV Act – Impact of Abatement – Held: Section 185 is a non-compoundable offence intended to deter dangerous driving. Abating such trials merely due to pendency undermines road safety and allows offenders to go scot-free. The argument that offenders could be charged under IPC does not justify the abatement of the special statute offences. [Paras 16-20].

Decision: Directions issued to the Justice Sapre Committee to examine the cashless treatment scheme; NHAI and States directed to implement safety protocols; State of UP directed to justify the abatement of MV Act trials. List on 22.01.2026.

Registration Act – Assignment of decree – Specific performance – Nature of decree – No interest in immovable property created – Decree only confers a right to seek sale deed execution – Assignment of such decree does not fall under Section 17(1)(e) – Registration not compulsory – Contrary view in K. Bhaskaram overruled – Held: Assignment deed of decree for specific performance does not require registration [Paras 18, 21–22, 26–28, 31–34].

Specific Relief – Assignment of Decree for Specific Performance – Requirement of Registration – Decree for specific performance does not create or assign any interest in immovable property – Assignment of such a decree does not require registration – Appeal dismissed – High Court judgment upheld – Held: Section 17(1)(e) of the Registration Act not applicable to assignment of such a decree [Paras 2, 14, 18, 20, 21, 26, 28, 34].

Civil Procedure – Execution of Decree – Order 21 Rule 16 CPC – Assignment of Decree – Assignment of decree in writing permitted – Assignee entitled to execute the decree as if he were the original decree-holder – No challenge raised regarding notice under Order 21 Rule 16 – Held: Assignment deed (Ex. B1) valid and enforceable – Registration not required [Paras 28, 29].

Property Law – Contract for Sale vs. Sale – Transfer of Property Act – Agreement for sale or decree for specific performance does not create any title or interest – Ownership passes only upon execution and registration of sale deed – Mere decree for specific performance does not confer ownership [Paras 20, 21, 22, 31].

Registration Act – Section 17(1)(e) – Scope and Applicability – Only applies if decree or order itself creates or declares rights, title or interest in immovable property – A decree for specific performance does not do so – Assignment of such decree is not compulsorily registrable [Paras 25, 26, 27, 30].

Legal Nature of Decree for Specific Performance – Decree does not extinguish the contract – Court retains control post-decree – Relief is equitable and does not automatically confer ownership – Execution required to complete sale [Paras 16, 17, 18, 19, 23, 24].

Case Law Referred – Babu Lal v. Hazari Lal Kishori Lal – Suraj Lamp & Industries – Hungerford Investment Trust – Amol v. Deorao – Held: Passing of decree does not vest title – Registration not needed for assigning decree for specific performance [Paras 17, 21, 24, 27].

Incorrect Law Declared – K. Bhaskaram v. Mohammad Moulana – Held: Does not lay down the correct position in law regarding requirement of registration for assignment of decree for specific performance [Para 33].

Decision – Appeal dismissed – Decree-holder validly assigned decree to Respondent No.1 – Assignment deed not compulsorily registrable – High Court judgment allowing execution rightly passed – No costs imposed [Paras 34, 35].

Land Acquisition – Compensation by Agreement – Statutory Interest – Estoppel – Once compensation is voluntarily and conclusively fixed through an agreement under Section 7(2) of the Tamil Nadu Acquisition of Land for Industrial Purposes Act, 1997, the agreement becomes final and binding – Supreme Court held that such a concluded contract excludes the applicability of Section 12 (interest provision) – High Court erred in awarding interest despite holding the agreement was a “complete package” that foreclosed further claims – Interest cannot be claimed when the agreement does not contemplate it [Paras 3–8, 21–25].

Statutory Interpretation – Contract Superseding Statutory Entitlements – Section 12 applies only when possession is taken without prior payment or deposit – When compensation is determined by consent under Section 7(2), such consent ousts other provisions of the Act including Section 12 – Rights and liabilities are governed exclusively by the agreement, not by the statute once contract is concluded [Paras 5–8, 21–22].

Doctrine of Approbate and Reprobate – Estoppel from Resiling – Landowners accepted 250% enhancement over guideline value through negotiation without protest – Later claims under Section 12 are hit by estoppel – Parties cannot accept benefits of a contract while repudiating its burdens – Equity principle bars selective adoption of contract terms [Paras 21, 23].

Writ Jurisdiction – No Interference in Concluded Contracts – Supreme Court reiterated that Article 226 cannot be invoked to rewrite voluntarily concluded agreements unless tainted by fraud or coercion – No such allegations were present – High Court wrongly used writ jurisdiction to disturb a binding settlement [Paras 22, 24].

Decision: Appeals allowed – High Court’s judgment set aside to the extent it directed payment of interest under Section 12 – Parties bound by terms of the agreement – No costs.

Constitutional Law – Tribunal Reforms Act, 2021 – Validity – Reenactment of Struck Down Provisions – Challenge to Tribunal Reforms Act, 2021 on grounds of violating judicial directions issued in MBA (IV) and MBA (V) – Court found that impugned provisions in the 2021 Act merely replicated those in the 2021 Ordinance which had already been struck down – Age bar of 50 years, truncated tenure of 4 years, requirement of two-name panel for selection, and equivalence with civil servants in terms of HRA and status – All these were held to undermine judicial independence and violate Articles 14 and 50 – Held: Legislature cannot nullify binding judgments without curing the defects – Repetition of invalidated law amounts to legislative override and violates constitutional supremacy [Paras 87, 90, 93, 103, 104, 116, 124, 126, 132, 140, 141, 142].

Separation of Powers – Judicial Independence – Legislative Encroachment – Court reiterates that separation of powers and judicial independence are part of the basic structure – Parliament’s attempt to reintroduce invalidated provisions by non obstante clauses struck down – Repeated re-enactment of unconstitutional provisions criticised – Judicial scrutiny into structure and functioning of tribunals warranted heightened review – Held: The legislature cannot repackage the same unconstitutional provisions under a new label to bypass court rulings – Doing so is a direct intrusion into the judicial sphere [Paras 89, 94, 124-128, 134, 141-142].

Constitutional Supremacy – Parliament cannot neutralise binding judicial directions issued under Articles 141 and 142 by mere re-enactment – Legislature may cure defects but cannot resurrect invalidated provisions without addressing constitutional infirmities – Directions in MBA (IV) were mandamus, not advisory; contrary statutory provisions void [Paras 84, 110-120, 135-142].

Minimum Age Requirement – Section 3: Bar on appointment below 50 years arbitrary – Discriminatory & violative of Article 14 – Contrary to MBA (IV) which restored 10 years’ practice rule for advocates – Excludes capable candidates and frustrates tribunal independence – Struck down [Paras 72, 84, 96-103].

Tenure – Section 5: Four-year term with maximum ages 70 (Chairperson) and 67 (Members) unconstitutional – Earlier judgments mandated minimum five-year tenure to ensure independence – Legislature cannot reintroduce invalid tenure model – Struck down [Paras 39-40, 68, 90-91].

Appointments – SCSC – Section 3(7): Requirement of recommending panel of two names per post invalid – Reintroduces provision struck down in MBA (IV) – Judicial primacy required – SCSC must recommend one name + one waiting list candidate only [Paras 35-36, 87-89].

Executive Delay – Provision allowing the Government to act “preferably within three months” on SCSC recommendations unconstitutional – Causes vacancies, undermines rule of law and access to justice [Paras 61, 75, 89].

Service Conditions – Sections 7 & provisos: Executive equivalence of allowances with civil servants contrary to judicial directions – Attempts to reverse MBA (IV)’s HRA directions impermissible – Second and third provisos struck down [Para 85].

Housing Allowance – Enhancement of HRA as directed in MBA (IV) upheld – Legislature cannot reduce by amendment – Judicial independence requires dignified conditions of service [Paras 70, 86].

Removal & Administrative Control – Excessive executive power over tenure, allowances, removals & rule-making violates independence of tribunals – Subordinate legislation cannot override judicial safeguards [Paras 33, 64-67, 110-120].

Reference to Larger Bench – Request rejected – No new substantial constitutional question; settled by long line of judgments from Sampath Kumar to MBA (V) – Belated request; reference would delay justice [Paras 105-109].

Validity of Impugned Act – Entire scheme of Section 184 as amended by 2021 Ordinance and the Tribunal Reforms Act held unconstitutional where it re-enacts struck-down provisions; valid only to extent conforming with MBA (IV)/MBA (V) [Paras 116-142].

Protection of Incumbent Members – Tenure of those appointed under earlier Acts & Rules protected – Appointments made prior to enforcement of the 2021 Act continue under old regime – Members appointed before commencement but notified later protected [Paras 129-138, 147-155].

National Tribunals Commission – Union directed to constitute NTC within four months – Will supervise appointments, administration & discipline of tribunals – Until then, Ministry of Finance to maintain independent Tribunals Wing [Paras 78-79, 152-153].

Final Directions – Impugned Act and offending amendments struck down – Appointments, tenure, salary, allowances, qualifications, reappointment & service conditions to be governed by MBA (IV) and MBA (V) until Parliament enacts valid legislation consistent with constitutional mandates [Paras 142, 151, 153].

Judicial Service – Inter se Seniority in Higher Judicial Service – Annual 4-Point Roster – Loss of ‘Birthmark’ – Merit-cum-Seniority – Service in Lower Judiciary Not Relevant – Proposals for Extra Weightage / Quota for Promotees Rejected – Uniform Guidelines Issued Under Art. 142 – Directions to Amend State HJS Rules [Paras 38–52, 53–66, 70–86, 97–101].

Judicial Services – Inter Se Seniority – Higher Judicial Services (HJS) – Determination of Seniority – Issue concerning comparative seniority between Direct Recruits (DR), Regular Promotees (RP), and Limited Departmental Competitive Examination (LDCE) recruits – Constitution Bench constituted to address imbalance and heartburn arising from divergent career progressions – Held: All officers lose the “birthmark” of recruitment source upon entry into HJS; Seniority must be determined through a uniform 4-point annual roster system – Merit, not length of service in lower judiciary, is key for further career advancement [Paras 1 to 3, 5, 6, 17, 31, 37, 50, 55, 60, 65, 70, 100(v), 100(x)].

Judicial Independence – Control over Subordinate Judiciary – Articles 233 to 235 of the Constitution – High Court’s primacy in regulating judicial service conditions acknowledged – However, Supreme Court empowered under Articles 32, 141, and 142 to lay down uniform principles for national consistency in judicial structure and functioning – Directions issued herein are binding and to be incorporated into statutory service rules by respective States in consultation with High Courts [Paras 18 to 20, 31 to 37, 36, 100(xiv), 101].

Service Law – Seniority – Judicial Cadres – Promotees’ Claim for Preferential Treatment Based on Longer Judicial Service in Lower Cadres – Rejected – Experience as Civil Judge (Junior or Senior Division) not a valid basis for preferential seniority in HJS – No intelligible differentia to justify separate classification – Past judicial service can justify entry into HJS through promotion or competitive recruitment, but cannot carry forward into HJS seniority – Any attempt to create such preference violates equality under Articles 14 and 16 [Paras 12, 13, 38 to 42, 47, 49, 64, 91 to 94, 100(vi), 100(vii)].

Roster System – Inter Se Seniority – Introduction of Uniform Annual 4-Point Roster – Two points for RPs, one each for LDCE and DR – Roster applicable per recruitment year – If recruitment from any source is delayed but completed within next year without overlapping new year’s appointments, such delayed appointees may claim placement in original year’s roster – Otherwise, seniority linked to actual year of appointment – Vacancies unfilled from LDCE or DR to be filled by RP but without claiming the diverted source’s roster position [Paras 66 to 80, 85, 86, 100(x) to (xiii)].

Judicial Promotions – Selection Grade and Super Time Scale – Basis for Advancement – Merit-cum-Seniority within HJS only – Length or performance in lower judiciary irrelevant – Promotions and administrative roles such as Principal District Judge depend on performance within HJS cadre – Earlier judicial service has no bearing after promotion or direct entry into HJS [Paras 47 to 49, 55, 64, 94, 100(vi)].

Recruitment Source – Irrelevance Post-Entry – 'Birthmark Theory' – Once officers from DR, RP, and LDCE enter HJS, their source of recruitment becomes immaterial – No classification based on source permitted – Relying on precedents including Roshan Lal Tandon, Triloki Nath Khosa, and Direct Recruit Class II Engineers Assn. – Seniority to be reckoned only within HJS based on date and roster position, not feeder service [Paras 53 to 63, 100(v), 100(vii)].

Bar Experience vs. Judicial Experience – Equivalence – Experience at the Bar and in Judicial Service both valued but neither considered superior – Decision in Rejanish K.V. clarified as recognising equivalence, not superiority of judicial service – Claim of DRs being unfairly advantaged rejected – DRs also face disadvantage due to mandatory ten-year minimum for HC elevation under R. Poornima [Paras 40 to 43, 100(i), 100(ii)].

Accelerated Promotion – Multiple Career Pathways – RPs and LDCEs have equal opportunities to advance via LDCE or DR exams – Rejanish K.V. and Sixth AIJA enable fast-track promotions and broader eligibility – Additional benefit of competing in direct recruitment exams also acknowledged – Heartburn due to age or speed of DR entry not a valid ground for special treatment [Paras 42, 44, 51, 52, 100(ix)].

Uniformity vs. State Variations – High Courts’ Role – While High Courts may vary in service rules and implementation, overarching uniformity essential – Separate seniority lists or State-specific preference rules may cause inequality and are not permissible unless incorporated through valid statutory rules – Preferential treatment must be rational, reasonable, and rule-based [Paras 68 to 70, 65, 94, 100(xiv)].

Data – Not Reliable Basis – Disparities in data across States and recruitment years over three decades render statistical reliance untenable – Varying rules and eligibility for entry into judicial service over time make present moment unfit for granting additional weightage to RPs based on lower cadre experience – Performance in HJS alone should determine career progression [Paras 87 to 90, 93, 94, 100(ii) to (iv)].

Decision: Interlocutory Application dismissed – General and mandatory guidelines issued for determining inter se seniority in HJS to be incorporated into statutory rules within 3 months – Existing seniority not to be reopened – Subject to future reconsideration depending on the impact of Rejanish K.V. and Sixth AIJA [Paras 95 to 104].

Land Acquisition – Compensation Agreement – Interest – The parties entered into a negotiated agreement under Section 7(2) of the 1997 Act fixing compensation for acquired land – High Court, while recognising the finality of the agreement, erroneously granted interest under Section 12 from the date of acquisition notice – Held: Once compensation is fixed through agreement, statutory provisions like Section 12 are excluded – Statutory interest cannot be claimed post-agreement [Paras 5–8, 21–22].

Contract Law – Concluded Agreements – Estoppel – Landowners having voluntarily agreed to compensation and accepted payments without protest are estopped from later invoking statutory rights inconsistent with the contract – Held: Doctrine of approbate and reprobate applies – A party cannot accept benefits under a contract and later challenge its terms [Paras 13, 23–24].

Writ Jurisdiction – Contractual Matters – The High Court erred in invoking writ jurisdiction under Article 226 to rewrite terms of a voluntarily concluded contract – Held: Power under Article 226 is discretionary and cannot be used to override settled contractual terms [Para 24].

Precedents – Finality of Consent Awards – Relying on previous decisions, including Ranveer Singh, NOIDA v. Ravindra Kumar, and others – Supreme Court held that a consent award or agreement extinguishes rights under the Act unless expressly reserved – Acceptance without protest bars further claims for interest or enhanced compensation [Paras 24–25].

Decision: Appeal allowed – High Court’s judgment to the extent of awarding interest under Section 12 is set aside – Held that no interest is payable where compensation was fixed by consent – No order as to costs.

Environmental Law – National Green Tribunal Act, 2010 – Section 16(h) – Limitation – Communication of Environmental Clearance (EC) – Multiple Duty Bearers – Held: The date on which EC is “communicated” is the starting point for limitation – Since the obligation to communicate lies with multiple duty bearers (MoEF&CC, Project Proponent, Pollution Control Boards), limitation commences from the earliest date on which communication is carried out by *any* of the duty bearers – The “principle of first accrual” applies; an aggrieved person cannot pick a later communication date to save limitation – Where MoEF&CC uploaded the EC on its website on 05.01.2017, the limitation period triggered on that date, rendering an appeal filed on 19.04.2017 time-barred [Paras 1, 6, 9-11, 14].

Interpretation of Statutes – “Any Person Aggrieved” – Communication in Rem – Interpretation of Section 16(h) of the NGT Act – The expression “communicated” must be interpreted liberally as environmental issues are public law concerns (in rem) rather than adversarial (in personam) – Communication is complete when the order is properly declared and easily accessible by any of the stakeholders required to publish it under the EIA Notification, 2006 – A clear and complete communication by one authority precludes reliance on subsequent communications by others for limitation purposes [Paras 6, 11, 13].

EIA Notification 2006 – Clause 10 – Publication in Newspapers – Sufficiency of Communication – Appellant argued that the Project Proponent failed to communicate effectively because the entire EC text was not published in newspapers – Held: Interpreting Clause 10 to require publication of the entirety of the EC in newspapers would be pedantic – It is sufficient compliance if the Project Proponent publishes the factum of the grant of EC and indicates the substance of conditions and safeguards, along with details on where the full text is available (e.g., website) – Absence of the full EC text in the advertisement does not invalidate the communication [Paras 19-20].

Facts – Appellant (Gram Panchayat) challenged EC granted to Respondent for limestone mining – EC granted and uploaded on MoEF&CC website on 05.01.2017 – Project Proponent advertised in newspapers on 11.01.2017 – Appellant filed appeal in NGT on 19.04.2017, claiming knowledge via RTI on 14.02.2017 – NGT dismissed the appeal as barred by limitation (beyond 30 days + 60 days condonable) – Supreme Court affirmed NGT’s decision, holding that the uploading of EC on 05.01.2017 constituted valid communication triggering the limitation period [Paras 2, 15-18, 21-22].

Decision: Appeal dismissed – Judgment of the National Green Tribunal affirmed.