Statutory Single-Window Governance for the Delhi Ridge (including the Morphological Ridge) under the Environment (Protection) Act, 1986

Introduction

In 2025 INSC 1306, the Supreme Court of India (B.R. Gavai, CJI; K. Vinod Chandran, J.) issued a transformative ruling in the long-running environmental litigation series arising from T.N. Godavarman Thirumulpad v. Union of India. Framed “In Re: Delhi Ridge,” this judgment addresses the chronic governance failures and institutional fragmentation that have imperiled the Delhi Ridge—the tail-end of the Aravalli range and the “green lungs” of the National Capital Territory (NCT).

The immediate triggers included: (a) the persistent non-issuance of a final notification under Section 20 of the Indian Forest Act, 1927 (IFA) despite a preliminary Section 4 notification in 1994 for 7,777 hectares (later tallied as 7,784 hectares); (b) rampant encroachments and unauthorized diversions; (c) confusion over the legal status and protection of the “Morphological Ridge” (ridge-like geomorphological features outside the notified ridge footprint); and (d) a proliferation of overlapping committees created by various courts and tribunals (Supreme Court, Delhi High Court, NGT), often producing duplicative or conflicting oversight.

The Court distilled the controversy into three core issues:

Issuance of a final notification under Section 20 of the IFA for the Delhi Ridge;
Removal of encroachments from the Delhi Ridge and the Morphological Ridge (at least since 9 May 1996);
Identification and legal treatment of the Morphological Ridge.

The principal relief ultimately granted is institutional: the Court directs the Ministry of Environment, Forest and Climate Change (MoEFCC) to constitute, under Section 3(3) of the Environment (Protection) Act, 1986 (EP Act), a statutorily-empowered Delhi Ridge Management Board (DRMB) as a single-window authority for all matters concerning the Delhi Ridge and the Morphological Ridge. The Court also embeds transparency, accountability, expert-driven functioning, and systematic reporting into the DRMB’s mandate, while integrating the Central Empowered Committee (CEC) into the DRMB’s structure and day-to-day operations via a Standing Committee chaired by a CEC member.

Summary of the Judgment

The Supreme Court’s dispositive directions restructure Delhi Ridge governance around a permanent, statutory, and transparent institutional framework:

Statutory constitution of DRMB under EP Act Section 3(3): MoEFCC must notify the DRMB as a statutory authority, thereby ending the DRMB’s ad hoc status (since 1995) and aligning it with the environmental rule of law.
Single-window authority for Ridge and Morphological Ridge: The DRMB becomes the sole nodal body for permissions, monitoring, management, and conservation decisions regarding both the notified Ridge and ridge-like geomorphological areas.
Composition with high-level inter-governmental membership and civil society representation: Chaired by the Chief Secretary, GNCTD, the DRMB includes senior representatives from DDA, MoEFCC, MoHUA, MCD, NDMC, CPWD, Delhi Police, key GNCTD departments, two NGOs/civil society representatives, the PCCF (Member-Secretary), and a representative of the CEC.
Standing Committee chaired by CEC representative: For daily functioning, the DRMB must constitute a Standing Committee chaired by a CEC member, with PCCF (GNCTD), the two NGO members, and expert nominees of the Chief Secretary and DDA.
Core functions:
- Preserve the Ridge and Morphological Ridge “in its pristine glory.”
- Remove all encroachments in both domains.
- Ensure completion of the Morphological Ridge identification exercise (as per the 8 February 2023 order) and report to the Court with comments.
- Undertake protection, scientific management, ecological restoration, afforestation, and habitat conservation.
- Submit six-monthly status reports to the Supreme Court; the CEC representative must submit tri-monthly reports on DRMB and Standing Committee functioning.
- Operate with fairness and transparency, including a public-facing website, public notices of hearings, public consultation, and prompt publication of reports.
- All NCT authorities must act in aid of the DRMB.
Legal architecture and oversight: By placing the DRMB under EP Act Section 3(3), its decisions become amenable to the National Green Tribunal’s original jurisdiction (NGT Act Section 14), appealable to the Supreme Court (NGT Act Section 22), and subject to High Court judicial review under Articles 226/227—an intentional design to embed accountability.

Although the Court laments the non-issuance of the IFA Section 20 notification despite clear NGT (2021) and Delhi High Court (2024) directions, it stops short of imposing an immediate deadline in this judgment. The emphasis is on institutionalization, consolidation of authority, and execution: encroachment removal, morphological identification, and rule-bound, transparent decision-making.

Analysis

Precedents and Materials Cited, and Their Influence

M.C. Mehta v. Union of India (orders dated 1 Sep 1995; 29 Sep 1995; 9 May 1996):
These foundational orders led to the creation of the DRMB in 1995 as the principal body for Ridge protection and articulated the imperative to maintain the Ridge’s “pristine glory.” The present judgment respects the original intent but cures the structural deficit—lack of statutory backing—by routing the DRMB through EP Act Section 3(3).
Master Plan for Delhi, 2001 (notified 1 Aug 1990):
Identified 7,777 hectares as Ridge (later 7,784 ha across Northern, Central, South Central (Mehrauli), Southern, and Nanakpura). Despite Section 4 IFA notification in 1994 and partial actions in 1996, only 103.48 ha stand finally notified under Section 20—a gap the Court regards as unacceptable and symptomatic of governance deficits.
Ashok Kumar Tanwar v. Union of India (Delhi HC, 30 Nov 2011):
Pivotal for recognizing protection for “Geological/Morphological Ridge” outside the notified footprint and requiring DRMB/SC clearance for constructions thereon. This concept—the Morphological Ridge—anchors the present Court’s insistence on integrating morphological areas into DRMB’s remit and completing formal identification.
Delhi Development Authority v. Kenneth Builders & Developers (P) Ltd. (2016) 13 SCC 561:
The Supreme Court endorsed Delhi HC’s approach, requiring DRMB and Supreme Court permission for projects on land with morphological ridge features even if outside the notified ridge. The current judgment consolidates that jurisprudence into a single-window model within a statutory authority.
T.N. Godavarman Thirumulpad v. Union of India, order dated 8 Feb 2023 (2023 SCC OnLine SC 1951):
Reaffirmed parity of protection for morphological ridge and set up a committee to identify it. The present judgment calls out the delay and compels the DRMB to ensure completion and report compliance.
Sonya Ghosh v. GNCTD (NGT, 15 Jan 2021):
Directed issuance of IFA Section 20 notifications for undisputed areas and created an Oversight Committee for encroachment removal and protection. The Supreme Court acknowledges multiple parallel bodies—NGT oversight, High Court directions, SC committees—and cures overlap by centralizing authority in the DRMB.
Devinder v. Lt. Governor (Del HC, 8 Nov 2023 and 8 Jan 2024):
The High Court signaled contempt for non-compliance with NGT’s Section 20 directions and recorded GNCTD’s promise to notify within four weeks. Continued non-compliance by mid-2024 reinforced the need for the Supreme Court’s institutional reforms.
T.N. Godavarman Thirumulpad v. Union of India (2024 SCC OnLine SC 86; 31 Jan 2024):
Institutionalized the CEC under EP Act Section 3(3), setting a template for converting ad hoc environmental bodies into statutory authorities. The Court quotes and relies on its own articulation of environmental rule of law—composition, funding, mandate clarity, coordination, transparency, and accountability—to justify DRMB’s statutory conversion.
Madhya Pradesh High Court Advocates Bar Association v. Union Of India (2022 SCC OnLine SC 639):
Clarifies that NGT jurisdiction does not oust High Courts’ constitutional powers, and that NGT’s appeal structure is constitutionally valid. This underpins the Court’s design for DRMB decisions to be reviewable by NGT, appealable to the Supreme Court, and subject to High Court judicial review.
T.N. Godavarman Thirumulpad v. Union of India (In Re: Gaurav Kumar Bansal) (2025) 2 SCC 641 (judgment dated 6 Mar 2024):
Emphasizes ecological restoration as a legal imperative, beyond mere penal action or compensatory afforestation. The present judgment weaves restoration, afforestation, and habitat conservation into the DRMB’s core functions, aligning Ridge governance with the restoration-focused jurisprudence.

Legal Reasoning and Principles Applied

From ad hoc to statutory: environmental rule of law as governance architecture
The Court’s central insight is that durable environmental protection requires permanent institutions with jurisdictional clarity, defined mandates, transparent procedures, and judicial accountability. By situating the DRMB under EP Act Section 3(3), the Court ensures:
- Applicability of administrative law norms (composition, tenure, transparency, RTI obligations, publication of rules/guidelines, public consultations).
- NGT’s original jurisdiction (Section 14) and appellate pathway to the Supreme Court (Section 22), plus High Court judicial review—ensuring oversight by specialized and constitutional courts.
- Funding, continuity, and expertise consistent with the institutional requirements spelled out in the 31 January 2024 CEC judgment.
Single-window authority to cure multiplicity and conflict
The proliferation of committees—NGT’s Oversight Committee, High-Powered Committees, and committees under prior Supreme Court orders—bred duplication and conflicting directions. The Court’s single-window mandate for DRMB reduces transactional friction for project proponents while heightening environmental rigor through expert-led review in a single, accountable forum.
Parity of protection for Morphological Ridge
Building on Delhi HC and Supreme Court precedent, the judgment treats morphology, not just prior notifications, as the conservation trigger. It recognizes that ridge-like geology/geomorphology serves the same ecological functions and thus merits equivalent protection. The Board is tasked with ensuring timely identification and protection of morphological tracts.
Encroachment removal and ecological restoration as affirmative duties
The Court recasts DRMB’s mission as both defensive (preventing fragmentation, removing encroachments) and restorative (scientific management, afforestation, habitat conservation), aligning ridge governance with the restoration-centric doctrine highlighted in the 6 March 2024 Godavarman ruling.
Transparency and participation
In a notable shift from the historically closed, court-driven permission model, the Court mandates proactive transparency: public notices, hearings, a functional website, immediate publication of reports, and periodic filings. This democratizes environmental governance and reduces information asymmetries.
Continuing Supreme Court oversight with operational devolution
The Court maintains supervisory jurisdiction (six-monthly reports; tri-monthly CEC reports on DRMB functioning) to stabilize the transition, while pushing operative decision-making to a statutory authority amenable to NGT/High Court review.

Impact and Implications

Governance of the Ridge fundamentally restructured:
All ridge-related approvals, permissions, conservation decisions, and enforcement actions will route through the DRMB. Fragmented oversight ends. Agencies such as DDA, MCD, NDMC, Delhi Police, and CPWD are bound to “act in aid” of the DRMB’s mandate.
Morphological Ridge elevated to operational parity:
Although already judicially recognized, this judgment operationalizes protection by integrating morphological areas into DRMB’s jurisdiction and making identification/reporting mandatory. Expect more rigor in scrutinizing projects in ridge-like tracts even if they fall outside legacy Master Plan delineations.
Shift from case-by-case Supreme Court clearances to rule-bound institutional decisions:
Historically, many Ridge diversions required DRMB recommendation plus Supreme Court leave. The “single-window” direction, coupled with statutory status and NGT oversight, signals a calibrated move toward institutional decision-making under judicial review, rather than pre-approval by the Supreme Court. However, given the Court’s continuing reporting requirements, a transitional period of close oversight will persist.
Section 20 notifications remain a priority—now institutionally driven:
The Court sharply criticizes the three-decade failure to issue IFA Section 20 notifications, despite NGT and Delhi HC orders. While this judgment does not set a fresh hard deadline, the DRMB will be expected to shepherd the process, integrate morphological mapping, and eliminate legal ambiguity about status on the ground.
Enforcement reality: encroachment removal with due process and coordination:
With the Board’s explicit mandate to remove encroachments in both notified and morphological areas, expect coordinated operations involving revenue, police, and municipal bodies. Practically, this will require inventories, boundary reinforcement, fencing, and (where applicable) rehabilitation policies consistent with law. The judgment’s “all authorities to act in aid” instruction will help overcome inter-agency friction.
Precedential value beyond Delhi:
The approach—statutory institutionalization under EP Act Section 3(3), single-window environmental authorities, integration of geomorphological criteria, and transparency mandates—offers a template for managing other urban ecological assets (city forests, wetlands, hill systems) where legacy notifications fall short of ecological realities.
Funding and offsets:
Earlier orders sometimes required “5% of project cost” deposits to DRMB funds. The present judgment does not reiterate a percentage levy, leaving space for the DRMB to develop rule-based, legally grounded funding frameworks (consistent with EP Act, IFA, FCA, CAMPA, and NPV jurisprudence) to finance restoration and management.

Key Institutional Features Ordered

DRMB Membership (as notified under EP Act Section 3(3))

Chief Secretary, GNCTD (Chairman)
Vice-Chairman, Delhi Development Authority
Representative of the Director General of Forests & Special Secretary, MoEFCC (not below the rank of Inspector General of Forests)
Representative, Ministry of Housing and Urban Affairs, Government of India (not below the rank of Joint Secretary)
Commissioner, Municipal Corporation of Delhi
Chairman, New Delhi Municipal Council
Director General, Central Public Works Department (Government of India)
Representative of the Commissioner of Police, Delhi (not below the rank of Joint Commissioner)
Principal Secretary/Secretary (Environment & Forests), GNCTD
Principal Secretary/Secretary (Land Revenue), GNCTD
Two representatives from NGOs/Civil Society (to be nominated by GNCTD)
Principal Chief Conservator of Forests, GNCTD (Member-Secretary)
Representative of the Central Empowered Committee (CEC)

Standing Committee for Day-to-Day Functioning

Member of the CEC (Chairperson)
Principal Chief Conservator of Forests, GNCTD
The two NGO/Civil Society representatives who are members of DRMB
Nominee of the Chief Secretary, GNCTD (must be a conservation expert)
Nominee of the DDA (must be a conservation expert)

DRMB’s Core Functions and Operating Protocols

Act as single-window authority for all issues concerning the Delhi Ridge and Morphological Ridge.
Preserve and restore ridge ecosystems; prevent fragmentation; remove encroachments.
Ensure completion of Morphological Ridge identification (per 8 Feb 2023 order) and report compliance and comments to the Supreme Court.
Undertake protection, scientific management, afforestation, and habitat conservation.
File six-monthly reports to the Supreme Court; CEC representative to file tri-monthly reports on the functioning of DRMB and its Standing Committee.
Operate with fairness and transparency: public website, advance public notices of hearings, public consultation, and prompt publication of reports.
All authorities in NCT Delhi must act in aid of the DRMB’s duties.

Complex Concepts Simplified

Reserved Forest under the Indian Forest Act (IFA):
A legal status conferring robust protection. Section 4 is a preliminary step (proposing an area as reserved forest and appointing a Forest Settlement Officer); Section 6 involves proclamations and settlement of rights; Section 20 is the final notification that formally declares the area as “Reserved Forest.” Delhi issued Section 4 in 1994 for 7,777 ha, but only 103.48 ha are finally notified under Section 20—leaving most of the Ridge without full IFA protection.
Morphological Ridge:
Areas that have ridge-like geological/geomorphological features (e.g., residual hills/ridges mapped by GSI) but fall outside the historically notified ridge footprint. Courts have held that such areas must receive equivalent protection given their ecological function in the Aravalli system and Delhi’s air-shed. The pending identification exercise is now placed under DRMB’s watch.
EP Act Section 3(3) Authority:
The Central Government can constitute statutory authorities by notification to exercise powers and perform functions under the EP Act. Such authorities (like the CEC, and now the DRMB) have legal personality, must adhere to rule-bound processes, and are accountable to judicial scrutiny.
NGT’s Jurisdiction (Sections 14 and 22 of the NGT Act):
Section 14 gives the NGT original jurisdiction over substantial environmental questions; Section 22 provides an appeal to the Supreme Court against NGT orders. The Supreme Court confirms that High Court writ jurisdiction under Articles 226/227 remains intact. By statutorily constituting DRMB, the Court ensures its decisions fall squarely within this judicial architecture.
Single-Window Authority:
One institution empowered to consider and decide all permissions, mitigations, and management actions for a subject-matter, eliminating the need to approach multiple committees and reducing inconsistent outcomes. Here, the DRMB becomes the single-window for the Ridge and Morphological Ridge.
Environmental Rule of Law:
Governance grounded in legal certainty, transparency, participation, accountability, and expertise. The Court requires that environmental authorities have clear compositions, mandates, rules, procedures, public-facing information, timelines, and audit/accountability mechanisms.

Practical Notes and Implementation Pathways

For Government agencies (GNCTD, DDA, MCD/NDMC, CPWD, Delhi Police):
- Align all ridge-related processes to route through DRMB; cease parallel committee permissions.
- Prioritize completion of IFA Section 20 notifications for undisputed areas; DRMB should publish a time-bound roadmap and status dashboards.
- Inventory encroachments with geo-tagging; implement boundary demarcation, fencing, and surveillance; ensure due process in removals with inter-agency coordination.
- Accelerate GSI-backed Morphological Ridge identification; publicize draft maps and invite comments.
For project proponents (public infrastructure/utilities):
- Expect unified scrutiny by DRMB; prepare comprehensive environmental documentation (geomorphology, biodiversity, fragmentation risk, mitigation/restoration plans).
- Anticipate public hearing processes and transparent publication of submissions and decisions.
- Plan for restoration obligations and offsets aligned with DRMB guidelines and applicable law (EP Act/IFA/FCA/CAMPA/NPV).
For civil society and residents:
- Engage via DRMB’s mandated public consultations; track six-monthly and tri-monthly reports published online.
- Use NGT and High Court remedies if DRMB’s decisions raise substantial environmental questions or deviate from rule-bound procedures.

Observations on Outstanding Issues

Section 20 notification deadline:
While the Court censures delay, it does not set a new deadline in this judgment. Momentum is now expected to come through DRMB’s statutory coordination; litigants may leverage NGT/HC jurisdiction to ensure time-bound action.
Funding model:
The prior “5% of project cost” deposit practice is noted historically but not mandated afresh. DRMB should frame legally robust funding guidelines for restoration and management, harmonized with existing statutory frameworks.
Transitional oversight:
The Supreme Court retains supervisory control through periodic reporting. In practice, this maintains continuity while DRMB procedures and guidelines stabilize.

Conclusion

This judgment marks a decisive turn from fragmented, ad hoc judicial management of the Delhi Ridge toward a permanent, statutory, and transparent governance regime. By constituting the DRMB under EP Act Section 3(3) as a single-window authority—and extending its remit to the Morphological Ridge—the Supreme Court aligns urban ecological governance with contemporary environmental rule-of-law principles.

The Court’s design embeds:

Institutional legitimacy (statutory status);
Jurisdictional clarity (single-window authority);
Expertise and inter-agency coordination (high-level membership and a CEC-chaired Standing Committee);
Judicial accountability (NGT/HC review, periodic reporting to the Supreme Court);
Public participation and transparency (mandatory website, public notices, consultations, and publication of reports);
A restoration-focused conservation mandate (afforestation, habitat conservation, and prevention of fragmentation).

The immediate legal significance lies in operational parity for morphologically identified ridge areas and the consolidation of all ridge-related permissions, management, and enforcement under a single statutory authority. The broader legacy is an institutional template that other jurisdictions can emulate to protect critical urban ecological systems where formal notifications lag behind ecological realities.

Key takeaway: Environmental governance is most effective when courts catalyze durable institutions that are transparent, expert-led, and accountable. The statutory DRMB is the Supreme Court’s instrument for rescuing the Delhi Ridge—and with it, Delhi’s green lungs—from decades of administrative drift.