Supreme Court Mandates Full & Frank Disclosure in Multi-Forum Environmental Litigation
A Comprehensive Commentary on
Arun Kumar Sharma & Ors. v. State of Madhya Pradesh & Ors. (2025 INSC 826)

1. Introduction

The decision of the Supreme Court of India in Arun Kumar Sharma v. State of Madhya Pradesh (Civil Appeal Nos. 3263-3264 of 2025, decided on 14 July 2025) deals with an environmental dispute that began before the National Green Tribunal (NGT) and later spawned a parallel writ petition before the Madhya Pradesh High Court. The appellants questioned several permissions—particularly a No-Objection Certificate (NOC) dated 07-02-2024 granted by the District Collector—for the establishment of a Reliance BP Mobility petrol pump in Bhopal District. They alleged non-compliance with:

• CPCB Guidelines (07-01-2020) prescribing a 50-metre buffer around petrol pumps,
• Rule 144 of the Petroleum Rules, 2002,
• Various local town-planning statutes, notably the M.P. Nagar Tatha Gram Nivesh Adhiniyam, 1973.

The NGT dismissed the Original Application and a subsequent review petition. The appellants then approached the Supreme Court while, during pendency of the appeals, one of them (Appellant No. 3) independently filed a writ petition before the High Court challenging the same NOC on allegedly different grounds. The Supreme Court seized upon this non-disclosure of “parallel proceedings,” ultimately dismissing the civil appeals with costs of ₹50,000 and laying down an emphatic rule on duty of candour in environmental and public-interest litigation.

2. Summary of the Judgment

1. The Court confirmed the NGT’s dismissal of the appellants’ challenge to the petrol-pump project, holding that no violation of the CPCB siting guidelines or other statutory requirements had been established.
2. More importantly, it held that the appellants had abused the process by running “identical and parallel proceedings” in two forums without candour and without seeking leave of the Supreme Court.
3. Observing that such conduct undermines “access to justice” and “integrity of the process,” the Court dismissed the civil appeals with exemplary costs.
4. It, however, clarified that the pending High Court writ on town-planning issues may proceed uninfluenced by its present observations.

3. Analysis

3.1 Precedents Cited & Their Influence

The judgment itself does not expressly list case citations, but the Court’s reasoning resonates with established authorities on suppression of facts and abuse of the judicial process. Comparable precedents include:

• K.D. Sharma v. Steel Authority of India Ltd. (2008) 12 SCC 481 – Reiterated that litigants approaching constitutional courts must come with clean hands and make full disclosure.
• Dalip Singh v. State of U.P. (2010) 2 SCC 114 – Emphasised that dishonesty and lack of candour will lead to dismissal with costs.
• Haryana Financial Corpn. v. Jagadamba Oil Mills (2002) 3 SCC 496 – Clarified that multiplicity of proceedings on the same cause is an abuse of process.
• Madiqur Rehman v. NGT (2019) & S.N. Chandrashekar v. State of Karnataka (2022) – Dealt with NGT’s jurisdictional limits vis-à-vis town-planning laws.

By echoing these precedents, the Supreme Court reaffirmed that environmental litigants are subject to the same standards of fairness and candour as any other litigant, perhaps more so because of the typical public-interest flavour of such cases.

3.2 Legal Reasoning

The Court’s reasoning can be broken into three logical steps:

1. Scope Overlap Analysis: It examined the prayers and grounds in the NGT application, the civil appeals, and the High Court writ. Finding that all three attacked the same NOC under overlapping heads (Petroleum Rules, town-planning norms, CPCB siting criteria), the Court concluded that the writ was “identical and parallel.”
2. Duty of Candour: Relying on general principles of uberrima fides (highest good faith) in public-interest litigation, it held that the appellants were duty-bound to disclose the High Court proceedings once they were initiated. Even if the High Court writ allegedly raised “distinct” grounds, the appellants should have (a) sought leave and (b) placed the fact before the Supreme Court—especially after the respondents had raised objections.
3. Consequential Relief & Costs: Because the omission was deliberate, the Court dismissed the appeals in limine with costs of ₹50,000 payable to SCAORA, thereby sending a deterrent signal. It nevertheless preserved the High Court’s jurisdiction to consider pure town-planning issues, embodying judicial comity.

3.3 Likely Impact on Future Litigation

• Elevated Candour Standard: Parties litigating environmental or regulatory matters across multiple forums must make proactive, full disclosures. Non-disclosure can now invite exemplary costs and dismissal.
• Streamlined Forum Shopping Doctrine: The judgment adds doctrinal clarity on what constitutes “parallel proceedings,” likely guiding tribunals and High Courts to weed out duplicative litigation early.
• NGT’s Jurisdictional Boundaries: By affirming that issues purely under the Petroleum Rules or town-planning enactments may fall outside the NGT’s domain, the Court indirectly delineates the tribunal’s reach.
• Deterrence Against Business-Driven PILs: The Court’s suspicion that the litigation was intended to “subserve business interest” of a competitor may dissuade disguised commercial battles in the garb of environmental concerns.

4. Complex Concepts Simplified

• Duty of Candour: A legal obligation on any person approaching the court to voluntarily place all material facts, favourable or otherwise. Failure = dismissal & costs.
• Parallel Proceedings: Multiple cases in separate forums concerning the same cause of action or relief. Courts frown upon this because it wastes judicial time and risks conflicting decisions.
• CPCB Siting Criteria (2020): Central Pollution Control Board guidelines prescribing a 50-metre buffer (relaxable to 30 m with extra safety measures) between petrol pumps and sensitive receptors like schools, hospitals, and designated residential areas.
• Rule 144, Petroleum Rules 2002: Empowers the District Authority to issue licences/NOCs for petroleum storage after ensuring public safety.
• Consent to Establish (CTE): Certificate from the State Pollution Control Board allowing industry to commence construction; followed by Consent to Operate (CTO) once operational readiness is achieved.
• M.P. Nagar Tatha Gram Nivesh Adhiniyam, 1973: State town-planning statute requiring development permission for land-use changes; often invoked in urban-development disputes.

5. Conclusion

Arun Kumar Sharma (2025) is less about siting of petrol pumps and more about the integrity of judicial proceedings. The Supreme Court has crystallised a principle: “Environmental litigation, while aimed at public welfare, cannot be a cloak for private economic warfare, nor can it proceed on selective disclosure.” The ruling strengthens procedural discipline by:

• Compelling litigants to disclose any concurrent or subsequent proceedings relating to the same dispute,
• Empowering courts and tribunals to impose real, deterrent costs for abuse of process,
• Clarifying the jurisdictional limits between the NGT, High Courts, and other statutory authorities.

Going forward, lawyers and parties embroiled in multi-forum environmental or regulatory battles must carefully chart litigation strategy, obtain appropriate permissions, and maintain absolute candour at every stage—or risk swift judicial rebuke.