This legal analysis delves into the landmark case of Rural Litigation and Entitlement Kendra, Dehradun v. State of Uttar Pradesh [AIR 1987 SC 2187], wherein the Supreme Court of India introduced the pivotal concept of "Sustainable Development." This case, initiated by an NGO against limestone quarrying in the Doon Valley, underscored the necessity of preserving the environment for future generations. This analysis meticulously examines the legal principles established, the court’s rationale, and the broader implications for environmental jurisprudence.

Introduction
The case of Rural Litigation and Entitlement Kendra, Dehradun v. State of Uttar Pradesh emerged as a beacon for environmental jurisprudence in India. The Supreme Court’s judgment in this case underscored the pressing need to balance developmental activities with environmental preservation, laying the groundwork for the doctrine of Sustainable Development. This principle mandates the judicious use of natural resources, ensuring that the environment remains viable for future generations. This legal analysis provides an in-depth examination of the court’s decision, its rationale, and its long-term implications.

Factual Matrix
Rural Litigation and Entitlement Kendra (RLEK), a Dehradun-based NGO, filed a public interest litigation in 1983 against the rampant limestone quarrying in the Doon Valley. The petitioners argued that the unregulated quarrying activities were causing severe environmental degradation, leading to deforestation, soil erosion, and water scarcity. They contended that these activities violated the right to a healthy environment, which is an integral part of the right to life under Article 21 of the Constitution of India.

Legal Issues:

• Whether the limestone quarrying activities in the Doon Valley were causing environmental degradation.
• Whether the right to a healthy environment is a fundamental right under Article 21 of the Constitution.
• The extent to which the doctrine of Sustainable Development applies in balancing environmental protection with developmental activities.

Court’s Analysis
Environmental Degradation and Fundamental Rights
The Supreme Court, after appointing an expert committee to investigate the environmental impact of quarrying, concluded that the activities were indeed causing substantial ecological damage. The court held that the right to a clean and healthy environment is a fundamental right under Article 21, encompassing the right to life.

The judgment stated:
"The permanent assets of mankind are not to be exhausted in one generation. The natural resources should be used with requisite attention and care so that ecology and the environment may not be affected in any serious way" [AIR 1987 SC 2187].

Doctrine of Sustainable Development
The court introduced the concept of Sustainable Development, which mandates that development should not compromise the ability of future generations to meet their own needs. This principle was rooted in the recognition that natural resources are finite and must be managed judiciously. The court emphasized that economic development and environmental protection are not mutually exclusive but should be pursued in tandem.

Precedential Influence
The court’s decision in this case set a significant precedent for future environmental litigation. It reinforced the notion that environmental protection is an integral part of human rights and development policies must consider ecological sustainability. Subsequent cases, such as Vellore Citizens’ Welfare Forum v. Union of India [1996 (5) SCC 647], have drawn on this principle, further solidifying the jurisprudential foundation laid in this landmark case.

Conclusion
The case of Rural Litigation and Entitlement Kendra, Dehradun v. State of Uttar Pradesh stands as a watershed moment in the annals of environmental law in India. The Supreme Court’s judgment, by embedding the doctrine of Sustainable Development within the ambit of constitutional rights, has profoundly influenced environmental jurisprudence. This case underscores the necessity of a balanced approach to development, one that safeguards the environment while promoting economic growth. The principles established herein continue to guide environmental policy and judicial decisions, ensuring that the legacy of preserving nature’s bounty for future generations endures.

References:

• Rural Litigation and Entitlement Kendra, Dehradun v. State of Uttar Pradesh [AIR 1987 SC 2187]
• Vellore Citizens’ Welfare Forum v. Union of India [1996 (5) SCC 647]
• Article 21, Constitution of India