"Balancing environmental protection with economic growth is a perennial challenge for policymakers worldwide, and India is no exception. This conundrum often places the judiciary at the epicentre of intense debates, as courts are called upon to interpret laws that have far-reaching consequences on both the environment and economic progress. This article delves into the intricate legal landscape of environmental protection versus economic growth in India, analysing key Supreme Court of India (SCC) case laws that have shaped this dynamic equilibrium.

The Constitutional Mandate
India's Constitution, in its Part IVA and Part IV, imposes a dual duty on its citizens and the state to protect and improve the environment (Article 51A(g)) and directs the state to endeavour to protect and improve the environment and to safeguard the forests and wildlife of the country (Article 48A). These provisions underscore the foundational recognition that environmental preservation is essential for sustainable development.

Judicial Interpretation and Environmental Jurisprudence
The Supreme Court of India has played a pivotal role in interpreting and enforcing environmental laws. One of the landmark cases in this context is M.C. Mehta v. Union of India (1987) 1 SCC 395. This case, commonly known as the Oleum Gas Leak case, established the principle of absolute liability for industries engaged in hazardous activities. The Court held that such industries must ensure that no harm befalls the community, emphasizing that economic activities should not come at the expense of environmental and public health.

In Vellore Citizens Welfare Forum v. Union of India (1996) 5 SCC 647, the Supreme Court introduced the concept of sustainable development and the precautionary principle into Indian jurisprudence. This case involved the pollution caused by tanneries in Tamil Nadu, which had adversely affected the agricultural lands and drinking water sources. The Court directed the closure of polluting tanneries and ordered the setting up of an environment protection fund. This decision highlighted that economic activities should not be pursued in a manner that endangers environmental sustainability.

Balancing Development and Environmental Protection
A more nuanced approach was evident in Narmada Bachao Andolan v. Union of India (2000) 10 SCC 664, where the Supreme Court addressed the issue of large-scale displacement due to the construction of the Sardar Sarovar Dam. The Court acknowledged the necessity of developmental projects for economic growth but emphasized that such projects must comply with environmental regulations and provide adequate rehabilitation for displaced populations. The judgment underscored the need for a balanced approach, ensuring that development projects are sustainable and inclusive.

Similarly, in Goa Foundation v. Union of India (2014) 6 SCC 590, the Court dealt with the issue of illegal mining in the state of Goa. The Court imposed a ban on mining activities, citing severe environmental degradation and the need for sustainable use of natural resources. However, it also laid down a framework for regulated mining activities, demonstrating a balanced approach towards economic development and environmental protection.

Recent Developments
The recent case of T.N. Godavarman Thirumulpad v. Union of India (2019) 16 SCC 1 reflects the ongoing judicial commitment to environmental protection. This case dealt with the expansion of industrial activities in forest areas. The Supreme Court reiterated that economic growth must not compromise environmental integrity and mandated stringent compliance with environmental regulations for industrial projects.

Conclusion
The jurisprudence emanating from the Supreme Court of India underscores the intricate balancing act between environmental protection and economic growth. While recognizing the imperatives of economic development, the Court has consistently emphasized the necessity of adhering to environmental laws and principles of sustainable development. The legal framework, fortified by landmark judgments, provides a robust mechanism to ensure that India's developmental trajectory does not undermine its environmental commitments.

End Notes:

• M.C. Mehta v. Union of India, (1987) 1 SCC 395.
• Vellore Citizens Welfare Forum v. Union of India, (1996) 5 SCC 647.
• Narmada Bachao Andolan v. Union of India, (2000) 10 SCC 664.
• Goa Foundation v. Union of India, (2014) 6 SCC 590.
• T.N. Godavarman Thirumulpad v. Union of India, (2019) 16 SCC 1.