Unified Definition of the Aravalli Hills and a Moratorium on New Mining Leases Pending a Landscape-Level Management Plan

1. Introduction

This judgment of the Supreme Court of India, reported as 2025 INSC 1338, arises in the long-running public interest litigation In Re: T.N. Godavarman Thirumulpad v. Union of India, Writ Petition (Civil) No. 202 of 1995. It addresses a specific but hugely consequential issue:

• What is the legally operative definition of the Aravalli Hills and Ranges for the purposes of regulating mining, and
• On what terms, if at all, can mining continue or commence within this ecologically critical landscape spanning Delhi, Haryana, Rajasthan and Gujarat?

The Court sits in its inherent/original jurisdiction in the continuing mandamus under the Godavarman forest case and in coordination with the parallel PIL M.C. Mehta v. Union of India concerning mining in the Aravallis of Haryana. The Bench comprised:

• B.R. Gavai, CJI (authoring the judgment)
• K. Vinod Chandran, J.
• N.V. Anjaria, J.

Triggered by concerns over illegal mining, fragmented definitions of “Aravalli Hills/Ranges” across States, and the ecological degradation of one of the oldest mountain systems in the world, the Court was called upon to harmonise scientific definitions, environmental law principles, and socio-economic realities.

The case is also anchored in India’s international obligations under the United Nations Convention to Combat Desertification (UNCCD), the 2023 National Action Plan to Combat Desertification and Land Degradation through Forestry Interventions, and the Union Government’s flagship Aravali Green Wall Project.

The judgment culminates in a new legal architecture for the Aravalli region: a uniform, Court-approved scientific definition, a moratorium on all new mining leases pending a comprehensive Management Plan for Sustainable Mining (MPSM) prepared by expert institutions, and strict no-go “core/inviolate” areas where mining is prohibited, with very narrow exceptions.

2. Summary of the Judgment

2.1 Core Holdings

The Supreme Court lays down the following key directions and principles:

1. Unified Definition of “Aravali Hills” and “Aravali Range” for Mining:
   The Court accepts the operational definition recommended by a Committee constituted by its order dated 9 May 2024:
   • Aravali Hills: Any landform in identified Aravalli districts with an elevation of 100 metres or more above the local relief (measured from the lowest contour line encircling the landform). The entire landform within that lowest contour — including the hill, its supporting slopes and associated landforms — constitutes “Aravali Hills”.
   • Aravali Range: Where two or more Aravali Hills are located within 500 metres of each other (measured between the boundaries of their lowest contour lines), the entire intervening area, along with associated slopes, hillocks etc., is classified as “Aravali Range”.
2. Moratorium on New Mining Leases:
   The Court directs that no new mining leases may be granted in the Aravalli Hills and Ranges until a Management Plan for Sustainable Mining (MPSM) is finalised by the Ministry of Environment, Forest and Climate Change (MoEF&CC) through the Indian Council of Forestry Research and Education (ICFRE).
3. Post-MPSM Restriction:
   After the MPSM is prepared:
   • Mining will be permissible only in those areas which the MPSM identifies as suitable for “sustainable mining”.
   • Other ecologically sensitive, conservation-critical and restoration-priority areas will be no-go or highly restricted zones for mining.
4. Mandatory Content of the MPSM:
   The MPSM, to be prepared for the entire continuous Aravalli ridge from Gujarat to Delhi, must:
   • Map and classify areas into:
     • Permissible for sustainable mining, and
     • Ecologically sensitive, conservation-critical, and restoration-priority areas where mining is strictly prohibited or allowed only in exceptional, scientifically justified cases.
   • Undertake a cumulative environmental impact assessment and evaluate the ecological carrying capacity of the entire Aravalli landscape.
   • Specify detailed post-mining restoration and rehabilitation measures.
5. Protection of Core/Inviolate Areas:
   The Court adopts the Committee’s recommendations designating core/inviolate areas where mining is prohibited, including:
   • Protected Areas (PAs), including Tiger Reserves, and identified tiger corridors.
   • Eco-Sensitive Zones (ESZs)/Eco-Sensitive Areas (ESAs) under the Environment (Protection) Act, 1986.
   • A minimum 1 km buffer around all Protected Areas, even if the notified ESZ is narrower.
   • Areas where plantations have been carried out with CAMPA or other government/international funds.
   • A 500 m buffer around Ramsar wetlands and wetlands under the Wetlands (Conservation & Management) Rules, 2017.

   Narrow Exception: No new leases in the Aravallis as a whole, but even the Committee’s limited allowance for new leases in Aravalli Hills/Ranges is now further confined by the Court’s moratorium pending the MPSM. In principle, the Committee allowed new leases only for critical, strategic and atomic minerals and minerals in the Seventh Schedule of the MMDR Act, but the Court’s moratorium temporarily supersedes this for all new leases.

6. Existing Legal Mining Operations to Continue with Stricter Oversight:
   The Court explicitly declines to impose a complete ban on ongoing legal mining in the Aravallis. Existing mines may continue, but:
   • They must strictly comply with the Committee’s recommendations in paragraph 8 of its report (additional environmental safeguards, expert inspections, compliance with EC and Consent to Operate conditions, etc.).
   • They remain subject to all statutory clearances and environmental regulations.
7. Rejection of a Blanket, Indefinite Mining Ban:
   Referring to its earlier experience and the judgment in State Of Bihar v. Pawan Kumar (2022) 2 SCC 348 and another judgment dated 10 November 2021 in Civil Appeal Nos. 3661–3662 of 2020, the Court reiterates that total bans on mining often fuel illegal mining and criminalisation. Therefore, instead of a blanket prohibition, the Court adopts a calibrated moratorium on new leases coupled with continued but regulated operation of existing leases.

2.2 Relationship to Earlier Orders

The judgment builds on, and partially modifies, the Court’s interim order dated 9 May 2024, where:

• A Committee including MoEF&CC, State Forest Secretaries, FSI, CEC and GSI was directed to recommend a uniform definition of “Aravalli Hills/Ranges”.
• States were allowed to process applications for new/renewed mining leases in Aravallis but barred from granting final permissions without leave of the Court.

The present judgment:

• Formally adopts the Committee’s operational definition; and
• Imposes a stronger moratorium by mandating that no new mining leases in the Aravallis can be granted at all until the MPSM is completed.

---

3. Detailed Analysis

3.1 Ecological and Legal Context: Why the Aravallis Matter

The Court begins by highlighting the immense ecological significance of the Aravalli mountain system:

• It is one of the oldest fold mountain ranges globally and the oldest in India.
• It spans Gujarat, Rajasthan, Haryana and Delhi, influencing climate, biodiversity, and hydrology across northern India.
• Scientifically, the Aravallis serve as a “green barrier” or “shield” that prevents the eastward spread of the Thar Desert into the Indo-Gangetic plains, Haryana and western Uttar Pradesh.
• The range harbours:
  • 22 Wildlife Sanctuaries,
  • 4 Tiger Reserves,
  • Keoladeo National Park (a World Heritage Site), and
  • Important wetlands like Sultanpur, Sambhar, Siliserh, Asola Bhatti, and aquifers recharging rivers such as Chambal, Sabarmati, Luni, Mahi, Banas.

Simultaneously, the Court notes that the Aravalli landscape faces “escalating degradation pressures”:

• Deforestation and unsustainable grazing,
• Illegal and excessive mining,
• Urban encroachment,
• Declining forest cover, advancing desert sands, and damaged aquifers.

These facts underpin the Court’s invocation of the precautionary principle and its reliance on international and domestic policy commitments to combat desertification and land degradation.

3.1.1 International Law: UNCCD

The Court recalls that India ratified the United Nations Convention to Combat Desertification (UNCCD) on 17 December 1996 and highlights key obligations:

• Article 4: Adopt an integrated approach addressing physical, biological and socio-economic aspects of desertification, and promote conservation of land and water resources.
• Article 5: Strengthen existing laws, enact new laws, and adopt long-term policy measures and action programmes to combat desertification.
• Article 10(2)(c) & 10(4): Develop National Action Programmes focusing particularly on preventive measures for lands not yet degraded or only slightly degraded.

In response, MoEF&CC has:

• Issued the National Action Plan to Combat Desertification and Land Degradation through Forestry Interventions (2023).
• Launched the Aravali Green Wall Project aimed at restoring degraded lands, preventing desertification, enhancing green cover, and improving ecological health across the Aravali landscape.

The Court reads these international and national commitments as reinforcing the need for a uniform, science-based and precautionary framework for protecting the Aravallis, particularly from mining.

3.2 Procedural History and Expert Inputs

3.2.1 Dual Proceedings: Godavarman and M.C. Mehta

The Aravalli issues were simultaneously before:

• M.C. Mehta v. Union of India – focusing on mining in Haryana’s Aravallis, and
• In re: T.N. Godavarman Thirumulpad – dealing, inter alia, with mining in Rajasthan’s Aravallis.

To avoid conflicting orders, the Chief Justice constituted a Special Bench comprising (then) Justices B.R. Gavai and Abhay S. Oka and directed that all Aravalli-related mining issues be heard together.

3.2.2 The CEC’s 2024 Report (CEC Report No. 3 of 2024)

In January 2024, the Court requested the Central Empowered Committee (CEC) to examine:

• Whether the existing distinction between “Aravalli Hills” and “Aravalli Ranges” for mining purposes should be continued, and
• Whether mining in these areas was in the larger public interest.

The CEC’s Report, submitted on 7 March 2024, made extensive recommendations, including:

• Comprehensive mapping of the entire Aravalli Range by the Forest Survey of India (FSI), funded by National CAMPA.
• A macro-level Environmental Impact Assessment (EIA) for mining-affected districts in Rajasthan, similar to the Karnataka iron ore cases (referring to earlier Supreme Court directions in WP(C) 562/2009).
• A series of no-mining zones:
  • Protected Areas, Tiger Reserves, ESZs, tiger corridors,
  • Buffers around wetlands, groundwater recharge zones, NCR areas, Dark Zones for groundwater, etc.
• Immediate suspension of mining in forest areas within Aravalli Ranges until mapping and EIA are completed, subject to Supreme Court’s future permission.
• Strict compliance and enforcement measures:
  • Closure and termination of non-compliant or illegal leases,
  • Rehabilitation of abandoned mines,
  • Closure of mines hitting groundwater tables,
  • Online Integrated Lease Management System,
  • Control of stone crushers and prevention of illegal mining,
  • District Task Forces under multi-departmental composition.

Though the final judgment does not adopt every CEC recommendation verbatim, the spirit of comprehensive mapping, zoning and strict regulation clearly carries into the Court’s directions via the Committee’s work and the MPSM mandate.

3.2.3 The 2010 FSI Definition of “Aravalli”

As early as 2010, FSI had provided a technical definition of Aravalli hills (for Rajasthan) in response to Court orders:

“(i) slope > 3°, (ii) foothill buffer = 100m, (iii) inter-hill distance or valley width = 500m and (iv) the area enclosed by above defined hills from all sides.”

The Amicus Curiae, Mr. K. Parameshwar, argued that this expert-derived definition should be adopted wholesale and questioned the need for a new Committee definition, especially where the latter introduced a 100 m elevation threshold that could, at least prima facie, exclude smaller hillocks.

3.2.4 The May 2024 Committee and Its Report

By order dated 9 May 2024, the Court constituted a multi-institutional Committee to recommend a uniform definition for “Aravalli Hills/Ranges”:

• Secretary, MoEF&CC (Chair)
• Forest Secretaries of NCT of Delhi, Haryana, Rajasthan, Gujarat
• Representative of FSI
• Representative of CEC
• Representative of Geological Survey of India (GSI)
• Joint Secretary, MoEF&CC (Convenor)

The Committee submitted its report (forwarded by MoEF&CC on 3 October 2025), proposing:

• The operational definition of Aravali Hills and Ranges (as quoted in paragraph 7.1.1 of its report and adopted by the Court).
• A regulatory framework that:
  • Prohibits new mining leases in Aravalli Hills/Ranges except for critical, strategic and atomic minerals and Seventh Schedule minerals under the MMDR Act (Section 7.3.1).
  • Requires expert team visits and environmental safeguards for ongoing and renewing leases (Section 7.3.2).
  • Designates core/inviolate areas where mining is prohibited (Section 7.4), largely overlapping with CEC’s no-go recommendations.

The Court largely endorses this Committee framework but overlays it with a crucial additional requirement: a landscape-scale Management Plan for Sustainable Mining (MPSM) prepared by ICFRE for the entire Aravalli range, and an accompanying moratorium on new leases until this plan is in place.

3.2.5 The Saranda MPSM Precedent

A key step in the Court’s reasoning is its reference to its own recent order (13 November 2025) in the Saranda Wildlife Sanctuary matter, decided within the same Godavarman PIL stream:

• In Saranda (Jharkhand), the MoEF&CC had engaged ICFRE to prepare a Management Plan for Sustainable Mining (MPSM).
• The MPSM used geo-referenced ecological assessment to:
  • Identify zones suitable for mining,
  • Mark conservation/no-mining areas (critical wildlife habitats, rich forests, corridors) as inviolate, and
  • Prescribe restoration measures.
• The Court accepted the MPSM, directing that:
  • “Conservation/no-mining” compartments be declared a Wildlife Sanctuary or other protected status, and
  • “Sustainable mining” compartments remain available for regulated mining.

The Court now treats Saranda’s MPSM as a model for the Aravallis, observing that:

• The Aravallis share ecological fragility and biodiversity values comparable to Saranda.
• A similar landscape-level, science-based zoning exercise is necessary to reconcile conservation and mining.

3.3 Precedents and Prior Judicial Orders Considered

3.3.1 Earlier Aravalli Orders (Godavarman and M.C. Mehta)

Over the years, in both Godavarman and M.C. Mehta, the Court has:

• Imposed and modified bans and restrictions on mining in the Aravallis (especially in Haryana),
• Directed mapping and identification of Aravalli hills (leading inter alia to the FSI’s 2010 report),
• Sought CEC inputs on illegal mining and environmental damage, and
• Required States to respond to CAG/CEC findings and implement corrective measures.

The 9 May 2024 order, quoted extensively in the judgment, is particularly significant as it:

• Identified the lack of a uniform definition of “Aravalli Hills/Ranges” as a major cause of illegal mining and regulatory confusion.
• Set up the Committee whose recommendations on definition and regulatory framework are now adopted and strengthened.
• Imposed an interim bar on granting final mining permissions without Court approval.

3.3.2 10 November 2021 Judgment in C.A. Nos. 3661–3662 of 2020

While the parties and facts in those appeals are not set out in this judgment, the Court relies on a central principle extracted from that decision:

A total ban on mining is not conducive even to environmental interests, as it often leads to illegal mining.

This logic is re-affirmed here to justify:

• Allowing existing legal mining operations to continue (under strict regulatory conditions), rather than imposing a sudden blanket ban in the Aravallis; and
• Preferring a moratorium on new leases and a science-based MPSM over an outright prohibition of all mining activity.

3.3.3 State Of Bihar v. Pawan Kumar (2022) 2 SCC 348

In Pawan Kumar, dealing primarily with sand mining, the Court had noted the perverse consequences of blanket mining bans:

• Bans that do not reflect ground realities and demand-supply dynamics often create space for illegal mining and mafias.
• Criminalisation of the mining sector can thereby be aggravated, undermining both environmental protection and the rule of law.

Invoking this precedent, the present Bench reasons that:

• A total stop to all mining in the Aravallis, including lawful projects with clearances, would be counterproductive.
• The better course is to:
  • Allow existing legal mines to operate under tightened environmental conditions, and
  • Impose a forward-looking moratorium on new leases pending the MPSM.

3.3.4 The Saranda (Jharkhand) MPSM Order

As discussed, the Court’s Saranda decision:

• Recognised the MPSM prepared by ICFRE as a scientifically robust model for:
  • Identifying conservation/no-mining areas,
  • Designating acceptable mining areas, and
  • Balancing mineral exploitation with forest and wildlife protection.

The present judgment explicitly extrapolates this approach to the Aravallis, which signals an emerging jurisprudential template: landscape-level, expert-driven management plans as prerequisites for determining where and how mining may occur in ecologically sensitive regions.

3.4 Court’s Legal Reasoning

3.4.1 Need for a Uniform, Scientific Definition

The Court accepts that a major driver of illegal or unsustainable mining in the Aravallis has been the absence of a consistent definition across the four States:

• Some States adopted narrow or inconsistent criteria for what constitutes “Aravalli Hills” or “Aravalli Range”.
• Haryana, notably, had no statutory definition at all.

This allowed:

• Regulatory evasion (classifying mining sites as “outside Aravallis”), and
• Incoherent application of Court orders and environmental clearances.

By judicially endorsing a uniform, scientific definition proposed by a high-level Committee including FSI, GSI and MoEF&CC, the Court:

• Creates a binding reference framework for all four States, at least for mining regulation.
• Reduces ambiguity and scope for manipulation in determining what areas fall within the protected Aravalli regime.

The Amicus Curiae’s concern — that a 100 m elevation threshold might exclude smaller but ecologically important hillocks — is addressed not through rejecting the Committee’s definition but by:

• Emphasising the comprehensive, landscape-level MPSM, which can still identify such areas as ecologically sensitive, conservation-critical, or restoration-priority, irrespective of whether they meet the technical definition of “Aravali Hills”.
• Stressing the need to maintain the “continuity and integrity” of the Aravalli range while preparing district-level MPSMs.

3.4.2 Application of Precautionary Principle and Sustainable Development

The Court frames its directions around two core environmental law principles:

• Precautionary Principle: In the face of scientific evidence of ecological fragility, desertification risk, and hydrological dependence on the Aravallis, the Court prefers to err on the side of caution:
  • By mandating an expert-driven MPSM before permitting new mining, and
  • By carving out core/inviolate areas where mining is per se prohibited.
• Sustainable Development: Rather than prohibiting all mining — which could disrupt livelihoods and incentivise illegal operations — the Court seeks a calibrated balance:
  • Protect ecologically critical and sensitive zones absolutely.
  • Allow controlled, scientifically managed mining in specific zones identified through the MPSM.
  • Enforce post-mining restoration and rehabilitation as an integral component of mining approvals.

The Court’s reasoning shows a preference for planning and zoning over ad hoc, lease-by-lease approvals or blanket prohibitions.

3.4.3 Reliance on Expert Bodies and Scientific Assessments

The judgment reflects a sustained pattern of judicial deference to expert bodies, while still setting the normative guardrails:

• FSI is relied on for earlier mapping and technical characterization of the Aravallis.
• CEC is credited with detailed factual and regulatory analyses, particularly illegal mining documentation.
• MoEF&CC’s Committee is entrusted with defining the Aravallis and proposing regulatory frameworks.
• ICFRE is designated as the primary technical body to prepare the MPSM, just as it did in Saranda.

The Court does not micro-manage the scientific methodologies but:

• Specifies objectives and minimum content for the MPSM (zoning, carrying capacity, cumulative impacts, restoration details).
• Insists on landscape continuity (the entire ridge from Gujarat to Delhi) even if the MoEF&CC chooses to prepare district-wise plans.

3.4.4 Calibrated Approach to Mining Bans

The Court is clearly attentive to the competing submissions:

• The Amicus Curiae had urged a more stringent stance, including a de facto halt on new mining until proper conservation frameworks were in place.
• The Solicitor General and other State counsel stressed that millions of labourers depend on mining, and a sweeping ban could cause economic distress and fuel illegal operations.

The Court resolves this tension by:

• Rejecting a blanket ban on all mining (in light of Pawan Kumar and prior experience).
• Freezing the frontiers of mining expansion via:
  • A moratorium on new leases in the Aravallis until the MPSM is finalised; and
  • Permitting only ongoing legal operations to continue under tightened environmental compliance.
• Linking future mining authorisations to a rigorous, science-based plan (MPSM), thereby converting what was previously a more policy-level aspiration into a judicially enforceable precondition.

3.5 The New Definition of Aravali Hills and Range: Practical Implications

The operational definition the Court approves has several practical and legal implications:

3.5.1 Aravali Hills

• Threshold Elevation: Only landforms rising 100 metres or more above local relief (i.e., above the lowest contour line that encircles the landform) are classified as “Aravali Hills”.
• Local Relief Concept: The “local relief” is defined with reference to topographical contour lines; this is a standard geomorphological measure and avoids defining elevation relative to sea level, which would be less meaningful in hilly terrain.
• Inclusion of Slopes and Associated Landforms: The entire area within the lowest contour, including supporting slopes and adjacent landforms, is treated as part of the Hill. This:
  • Prevents the artificial exclusion of slopes and foothills from protection,
  • Recognises their ecological and hydrological importance (e.g., in groundwater recharge, soil stability).

3.5.2 Aravali Range

• 500 m Proximity Rule: If two or more Aravali Hills are within 500 metres of each other (distance measured between the outer boundaries of their lowest contour lines), they are collectively treated as part of a continuous “Aravali Range”.
• Intervening Area Included: Using buffers and intersection lines, the entire area between these hills — with its associated landforms and slopes — is incorporated into the “Range”.
• Effect:
  • Prevents fragmentation of the Aravalli belt into artificially isolated “islands” of protection.
  • Recognises ecological continuity (wildlife movement, hydrological flows, vegetation corridors) between hills.

When combined, these criteria provide a geo-morphologically robust and mappable framework to delineate the Aravalli Hills and Range across the four States for purposes of mining regulation.

3.6 Regulatory Architecture for Mining in the Aravallis

3.6.1 Core/Inviolate Areas: Absolute No-Go Zones

The Court accepts the Committee’s list of core/inviolate areas where mining is prohibited, which include:

• Protected Areas and Tiger Reserves: Under the Wildlife (Protection) Act, 1972, including all notified tiger corridors.
• Eco-Sensitive Zones (ESZs)/Eco-Sensitive Areas (ESAs): Notified (or to be notified) under Section 3(2)(v) of the Environment (Protection) Act, 1986 and Rule 5(1) of the Environment (Protection) Rules, 1986.
• Default ESZ Regime: For Protected Areas where ESZs are not yet notified or proposals are pending, the Court’s own earlier orders in the Godavarman matter (which prescribed a default ESZ) will govern.
• Minimum 1 km Buffer around Protected Areas: Even if a notified ESZ is narrower than 1 km, no mining is allowed within 1 km of the PA boundary.
• Plantation Areas: Sites where plantations have been established with funds from:
  • CAMPA (Compensatory Afforestation funds),
  • Other Government schemes, or
  • International cooperation programmes.
• Wetland Buffers: A 500 m buffer around:
  • Ramsar-listed wetlands, and
  • Wetlands notified under the Wetlands (Conservation & Management) Rules, 2017.

These zones reflect both statutory protections and the Court’s own recognition of crucial ecological functions (wildlife habitat, water security, landscape connectivity).

3.6.2 Moratorium on New Mining Leases

The Court’s most consequential new rule is:

“Till the MPSM is finalised by the MoEF&CC through ICFRE, no new mining leases should be granted.”

Coupled with the requirement that post-MPSM mining may only occur in areas identified as suitable for sustainable mining, this creates a two-stage filter:

1. Stage 1 (Pre-MPSM):
   • Absolute moratorium on all new mining leases in the Aravallis.
   • Ongoing legal mining may continue under stricter oversight.
2. Stage 2 (Post-MPSM):
   • New and renewed mining leases are possible only in areas designated by the MPSM as suitable for sustainable mining.
   • Core/inviolate and other conservation-critical or eco-sensitive zones remain off-limits.

This is a significant judicially created moratorium, grounded not in a statute but in the Court’s environmental jurisdiction and its duty to protect the right to life and environment under Article 21, and to give effect to statutory and treaty obligations.

3.6.3 Treatment of Existing Mines

Existing mines in Aravalli Hills and Ranges:

• Are not immediately shut down, to avoid the adverse consequences of a blanket ban (economic disruption, illegal mining, criminalisation).
• Must, however, comply strictly with the recommendations in paragraph 8 of the Committee’s report, which include:
  • Expert inspection teams (from Forest, Mining, Local Administration, SPCB, etc.) to assess compliance with Environmental Clearances (EC) and Consent to Operate (CTO) conditions.
  • Imposition of additional environmental safeguards as part of CTO conditions.
  • Monitoring and enforcement by State Pollution Control Boards.

In substance, the Court thus transforms what might previously have been considered primarily administrative or regulatory guidelines into judicially-backed mandatory conditions for continued operation.

3.7 Impact and Future Implications

3.7.1 For Environmental Jurisprudence

This judgment advances Indian environmental law in several ways:

• Landscape-Level Planning: It entrenches the idea that ecologically critical regions (like Saranda and now the Aravallis) must be managed at a landscape scale, not on a parcel-by-parcel basis.
• Science-Based Zoning as a Legal Precondition: The requirement of an MPSM before granting new leases effectively turns scientific zoning into a legal prerequisite for mining in sensitive landscapes.
• Integration of International Obligations: The Court explicitly references the UNCCD and India’s National Action Plan, reinforcing the trend of using international environmental commitments as interpretive tools in domestic environmental governance.
• Precautionary Principle Operationalised: The moratorium and MPSM requirements operationalise the precautionary principle in a concrete, site-specific way.

3.7.2 For Mining Law and Industry Practice

The judgment will have substantial ramifications for the mining sector in Delhi, Haryana, Rajasthan and Gujarat:

• Immediate Freeze on New Leases in Aravallis: Mining companies cannot obtain fresh leases in the Court-defined Aravalli Hills and Ranges until the MPSM is complete, which, given the scale of the terrain, may take considerable time.
• Increased Reliance on Expert Assessments: Future projects will be judged not merely against standard EIA/EC requirements but also against the zoning and prescriptions of the MPSM.
• Greater Compliance Burden on Existing Mines: Ongoing operators face:
  • More intensive inspection and monitoring,
  • Potentially stricter conditions, and
  • Legal risk if found non-compliant (closure/termination of leases).
• Trajectory Towards Sustainable Mining: In the longer term, companies may need to:
  • Invest significantly in restoration and rehabilitation,
  • Adapt to cluster-based operations and tighter spatial constraints, and
  • Re-orient business models to align with carrying-capacity limits and no-go zones.

3.7.3 For States and Regulatory Institutions

The four Aravali States and central agencies will need to:

• Coordinate closely with MoEF&CC and ICFRE for the MPSM preparation, supplying data, mapping support, and legal inputs.
• Amend or harmonise their mining policies and rules to reflect:
  • The Court-approved definition of Aravalli Hills/Ranges,
  • The no-go core/inviolate areas, and
  • The eventual MPSM zoning.
• Strengthen enforcement:
  • Set up or empower District Task Forces and integrated lease management systems, as suggested by CEC and Committee.
  • Ensure strict enforcement of EC and CTO conditions, and take prompt action against illegal mining and non-compliant leases.

In effect, the Court’s directions push States towards a more transparent, data-driven and inter-state-consistent mining regulatory regime in the Aravalli belt.

3.7.4 For Local Communities and Livelihoods

The judgment implicitly acknowledges the livelihood dependence of millions on mining, especially in Rajasthan and Haryana. Its calibrated approach:

• Avoids immediate closures of ongoing legal operations, thereby mitigating shock to workers.
• Nevertheless, by freezing new leases and tightening environmental safeguards, it may:
  • Limit expansion of mining-related employment in the short-to-medium term in Aravalli areas,
  • Encourage greater investment in ecosystem restoration, afforestation and sustainable livelihoods as part of the Aravali Green Wall and other programmes.

3.7.5 Template for Other Ecologically Sensitive Regions

By extending the Saranda MPSM model to the Aravallis, the Court effectively signals that:

• Other sensitive landscapes (e.g., parts of the Western Ghats, Eastern Ghats, Shivaliks) may, in future PILs, be subjected to similar landscape-level MPSMs as conditions precedent for major mining or infrastructure expansion.
• This could mark a broader shift in Indian environmental governance from project-level EIAs to region-level ecological zoning.

---

4. Complex Legal and Technical Concepts Simplified

4.1 Aravali Hills and Ranges

• Aravali Hills: A “hill” in this context is a landform that rises at least 100 metres above the surrounding terrain (local relief). The entire area within the contour that encircles the base of this rise — including slopes and adjacent features — is part of the hill.
• Aravali Range: When two or more such hills are close together (within 500 m), the land between them, along with associated features, is treated as a continuous “range”. This captures the broader mountainous landscape, not just isolated peaks.

4.2 UNCCD and National Action Plan

• UNCCD (United Nations Convention to Combat Desertification): An international treaty obliging countries like India to prevent and reverse land degradation and desertification.
• National Action Plan to Combat Desertification (2023): India’s national strategy document for implementing UNCCD commitments, emphasising forestry interventions, restoration and integrated land management.

4.3 CAMPA

CAMPA (Compensatory Afforestation Fund Management and Planning Authority) oversees funds collected from project developers (e.g., for forest diversion) to finance compensatory afforestation and related activities. Plantations funded by CAMPA are treated as valuable environmental assets and are part of core/inviolate no-mining areas.

4.4 Eco-Sensitive Zones (ESZs)/Eco-Sensitive Areas (ESAs)

Under the Environment (Protection) Act, 1986, ESZs/ESAs are buffer areas around Protected Areas (or other ecologically sensitive sites) where certain activities (including mining) are restricted or prohibited to protect the ecological integrity of the core area. The Court here reinforces and, in some respects, supplements these protections (e.g., by imposing a minimum 1 km no-mining buffer around PAs regardless of ESZ boundary).

4.5 Ramsar Wetlands and Wetlands Rules, 2017

• Ramsar Sites: Wetlands of international importance designated under the Ramsar Convention.
• Wetlands (Conservation & Management) Rules, 2017: Domestic rules governing the identification and protection of wetlands in India.

The Court directs that a 500 m buffer around such wetlands in the Aravallis be treated as a no-mining zone.

4.6 MPSM (Management Plan for Sustainable Mining)

An MPSM is a comprehensive, landscape-level plan, here to be prepared by ICFRE, which:

• Identifies:
  • Areas where mining can be allowed sustainably, and
  • Areas that must be conserved or restored and kept free from mining.
• Assesses:
  • Cumulative environmental impacts (aggregate effect of all mines and related activities), and
  • Ecological carrying capacity (how much disturbance the ecosystem can handle without collapse).
• Specifies:
  • Conditions and safeguards for permitted mining,
  • Post-mining restoration and rehabilitation obligations.

4.7 Core/Inviolate Areas

These are areas that are so ecologically significant or sensitive that they must be kept free from mining and other major disturbances. In this judgment, they include Protected Areas, tiger reserves and corridors, ESZs, plantation areas, and wetland buffers, among others. The term “inviolate” reflects the idea that such areas should not be disturbed at all, except perhaps in extraordinary situations (e.g., critical/strategic national interest) — and even then, subject to stringent scrutiny.

4.8 Critical, Strategic and Atomic Minerals; Seventh Schedule Minerals

• MMDR Act, 1957: The Mines and Minerals (Development and Regulation) Act regulates mining of major minerals.
• Part B of First Schedule: Lists atomic minerals (e.g., uranium, thorium) with special strategic importance.
• Part D of First Schedule: Lists critical and strategic minerals (e.g., some rare earths, certain metals crucial for national security and high-tech industries).
• Seventh Schedule minerals (referred to in Committee’s recommendation) are specific minerals that, due to their characteristics, may warrant distinct regulatory treatment.

The Committee had recommended that new mining leases in Aravallis, if at all, be restricted to such critical/strategic/atomic minerals and Seventh Schedule minerals. The Court, however, now places all new leases under moratorium until the MPSM is ready.

4.9 Carrying Capacity and Cumulative Impact

• Carrying Capacity: The maximum level of human activity (such as mining) that an ecosystem can sustain without undergoing irreversible damage.
• Cumulative Impact: The combined effect of multiple projects and activities over time on the environment, which may be much greater than the sum of individual impacts assessed in isolation.

The Court insists that the MPSM must incorporate both these concepts so that future mining decisions account for overall ecological limits, not just project-specific EIAs.

4.10 Precautionary Principle and Sustainable Development

• Precautionary Principle: When there is scientific uncertainty but credible evidence of potential serious harm, the State (and the Court) should take preventive action rather than wait for full proof of damage.
• Sustainable Development: Development that meets present needs without compromising the ability of future generations to meet their own, balancing ecological conservation with economic and social needs.

The Court’s moratorium, MPSM requirement, and protection of core/inviolate areas are concrete expressions of these principles in the Aravalli context.

---

5. Conclusion: Significance in the Broader Legal Landscape

This judgment is a significant milestone in India’s environmental and mining jurisprudence, particularly for the following reasons:

1. First Uniform, Judicially Backed Definition of the Aravallis for Mining:
   The Court, for the first time, endorses a scientific, uniform definition of “Aravali Hills” and “Aravali Range” applicable across Delhi, Haryana, Rajasthan and Gujarat for mining regulation. This reduces regulatory ambiguity and guards against deliberate under-classification of Aravalli areas to facilitate mining.
2. Institutionalisation of Landscape-Level Management Plans:
   Building on the Saranda precedent, the Court requires a comprehensive Management Plan for Sustainable Mining (MPSM) for the entire Aravalli ridge, to be prepared by ICFRE. This represents a shift from project-level EIAs to region-level ecological zoning as a precondition for mining in sensitive landscapes.
3. Moratorium on New Mining Leases:
   By ordering that no new mining leases may be granted in any part of the Aravalli Hills and Ranges until the MPSM is finalised, the Court creates a robust forward-looking safeguard. It protects the remaining Aravalli ecosystems from further fragmentation while the scientific and planning exercise is carried out.
4. Protection of Core/Inviolate Areas:
   The Court cements a strong framework of no-go zones—Protected Areas, tiger reserves and corridors, ESZs/ESAs, plantation areas, and wetland buffers—where mining is prohibited. This reinforces statutory protections and gives them additional judicial strength.
5. Balanced Approach to Livelihoods and Environmental Protection:
   The Court refuses a blanket ban on all mining, cognisant of the livelihood dependence of millions and the risk of illegal mining mafias. Instead, it:
   • Allows existing legal mines to continue under stricter regulatory conditions, and
   • Freezes new expansion until a scientifically informed plan is in place.
   This approach aligns with the principle of sustainable development rather than absolutist preservationism.
6. Integration of International and National Commitments:
   By referencing the UNCCD, the National Action Plan on desertification, and the Aravali Green Wall Project, the Court situates its orders within a broader policy and treaty context. It underscores that judicial directions are not isolated interventions but part of India’s systemic obligations to combat desertification and ecological degradation.
7. Template for Other Ecologically Sensitive Regions:
   The Aravalli judgment, alongside Saranda, points towards a potential judicial template for other critical ecosystems: scientifically prepared management plans, core/inviolate no-go areas, moratoria on new projects until planning is complete, and stricter conditions for ongoing operations.

In summary, In Re: Issue relating to definition of Aravali Hills and Ranges within the Godavarman PIL:

• Resolves longstanding definitional ambiguities about what constitutes the Aravallis for mining regulation,
• Imposes a significant but nuanced moratorium on new mining leases,
• Mandates a landscape-scale, expert-driven management plan as the gatekeeper of future mining, and
• Strengthens the legal protection of one of India’s most critical ecological barriers against desertification.

For environmental lawyers, policy-makers, regulators, and industry alike, this judgment is a crucial reference point in understanding how India’s highest court envisions the governance of mining in fragile ecosystems: not through piecemeal or purely administrative decision-making, but through integrated, scientifically informed, and justice-driven planning that takes seriously both ecological limits and human needs.