A Study on Significance of Wetlands for Maintaining Ecological Balance

Paper Details 

Paper Code: RP-VBCL-09-2025

Category: Research Paper

Date of Publication: April 20, 2025

Citation: Dr. Shubhalakshmi P., “A Study on Significance of Wetlands for Maintaining Ecological Balance", 2, AIJVBCL, 124, 124-138 (2025).

Author Details: Dr. Shubhalakshmi P., Assistant Professor of Law, SDM Law College, Mangaluru, Karnataka, India.

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ABSTRACT

Protection of environment is one of the prime concerns for the wellbeing of all living creatures. Degradation of natural environment has occurred from population explosion, over consumption, excess technological growth, deforestation etc., all of which have resulted in negative impact on the environment and it has put the life of humans, animals and other living beings at risk. The main objective of the paper is to learn about significance of wetlands and to know the legal framework to conserve them to maintain ecological balance. There is need to conserve wetland and the Constitution of India also provides provisions for protection of environment and its elements. Ramsar Convention on wetlands, National Environment Policy 2006, Wetlands (Conservation and Management) Rules 2017 and judicial pronouncements also highlighted on protection of wetlands in India. Legal provisions and judicial decisions related to wetland provides us a clarity about the substantial role played by the wetlands in maintaining ecological balance and in turn contributing for the protection of environment. Different courts, tribunals, including National Green Tribunal have emphasised on significance of wetlands and conservation of wetlands to maintain ecological balance. Because wetlands play a prominent role in ecological balance, it is the prime duty and responsibility of all of us to conserve them and preserve them for future generation.

Keywords:  Wetlands, Environment, Conservation, Ecological Balance.

INTRODUCTION

“Wetlands are very important for the existence of our earth, because many birds and animals depend on them. Along with enriching Biodiversity, they also ensure flood controland groundwater recharge.”[1] - Prime Minister Narendra Modi

The ecosystem on the earthcontains different biotic and abiotic components like organisms, vegetation, rivers, mountains, lakes, wetlands etc. Wetland plays a major role in balancing natural cycles and supports a wide range of biodiversity. They play a role in water conservation by recharging ground water system. Wetland also provides habitat for many living organisms. Wetland provides natural infrastructure which supports climate change mitigation, disaster and risk reduction, health and livelihood along with local development.

The term wetland is defined by the Ramsar Conventionas “areas of marsh, fen, peatland or water, whether natural or artificial, permanent or temporary, with water that is static or flowing, fresh, brackish or salt, including areas of marine water the depth of which, at low tides, does not exceed six meters”.[2]In the Convention it was also stated that “wetlands may include riparian and coastal zones adjacent to the wetlands and islands or bodies of marine water deeper than six meters at low tide lying within the wetlands.” On this earth. around six percent of the areas is considered as wetlands.[3]

CLASSIFICATION OF WETLANDS IN INDIA

The estimated Wetlands in India is about 58.2 million hectares, including areas under wet paddy cultivation. Major portion of the inland wetlands are dependent on the rivers in India. Wetlands in India are classified as follows: -

i.        Himalayan wetlands that includeLadakh and Zanskar, wetland of Kashmir valley, Central Himalayas, and Eastern Himalayas.

ii.      Indo-Gangetic wetlands that include wetlands of the Himalayan terai and the Indo-Gangetic plains.[4]

iii.    Coastal wetlands that includevast intertidal areas, mangroves and lagoons, Islands and Offshore coral reefs.

iv.    Deccan wetlands include innumerable small and large reservoirs and several water storage tanks.[5]

SIGNIFICANCE OF WETLAND

Wetlands ecosystems are prominent parts of hydrological cycle that are highly productive, support biodiversity and afford a wide range of ecosystem services like water storage, flood mitigation, water purification, controlling erosions, storm buffers, recharging ground water, regulation of climatic conditions, and aesthetic enhancement of landscapes and provides significant support for social,cultural,and recreational activities. The wetlands functions as reservoirs for ecological protection.[6]The Coastal wetlands are very useful and significant in shoreline stabilisation and storm protection and they contribute for hydrological balance.[7]

There are many people dependent upon wetlands for their food, water, and livelihood. Some wetlands also contribute in combatting the floods and extreme weather events occurs in the environment. Wetlands also work as top carbon stores of earth and the conservation of wetland can help in reduction of carbon emissions.Under the Ramsar Convention, it has been estimated that there are more than 80 wetlands in India with more than a million hectares surface area and they are recognised as wetlands of international significance.[8]

i.                    Protection from Storm Damage and Flood

The energy of storm surges and heavy rain overflows are controlled by the tidal wetlands and inland wetlands by absorbing the sudden influx of water. Wetlands help in protection of lowlandcommunities byreducing flooding, property damage, erosion etc, during major storms.[9]

ii.                  Climate Change

Wetlands have the capacity to store more carbons than the rain forests, that is around more than 50 times that the rain forests do, that helps inmaintaining weather condition during climate-change in the atmosphere. The high-carbon detritus, such as leaves, animal wastes, other debris etc are trapped below the water’s surface by the wetlands. 

iii.                Water Quality

Wetlands act as water purifier centres that are natural filters, protecting groundwater and downstream waters by treating and trapping pollutants in the water, they may be sediments or chemicals or any other pollutants. The wetlands referred to as watershed’s kidneys, because by a complex system of biological, physical and chemical processes, they clean the pollutants before it reaches the Bay.[10]

iv.                Groundwater Recharge and Baseflow Supply to Stream

Wetlands that are non-tidal, act as a sponge and absorbers of water after storm events. This water retention lets water slowly percolate and recharge groundwater deposits. During summer seasons, even though wetlands may run dry for some extent, they will never barren because of creation of ground water sources under it. This balance of water flow plays prominent role in the atmosphere for healthy watersheds.

v.                  Wildlife Habitat

Wetlands provide rich and productive habitat for widely diverse wildlife. The wetlands vegetation provides food, water and shelter along with spawning for fish, reptiles, mammals and birds. It also been ats as shelter for migrating waterfowls during certain seasons.[11]

vi.                Erosion Control

Extensive erosion and sediment can be prevented by binding the soil properly by the plants, grasses and bushes grown on the wetlands. The flow of water can also be slow down in wetlands because of the presence of grass and plants allowing fine sediment particles to settle, building soil elevation over time.

Wetlands not only having ecological significance, but also connected to Indian culture and tradition. For example, in Manipur, Loktak Lake is considered as mother or Ima by the local people of the area. Khecheopalri Lake is one of the Lakes of Sikkim called as “wish fulfilling lake. Lakes and wetlands are also significant as the place of tourism and amusement.[12]

THREATS TO WETLAND

There is lack of awareness among the people in the country on significance and necessity of the protection of wetlands. In India there were good number of wetlands present and as time passed India has lost nearly one-third of her natural wetlands to urbanisation, agricultural expansion and other activities creating pollution from the past forty years.  It is estimated that the rate of vanishing of wetlands is comparatively three times greater than the deforestation.

Even though wetlands are rich vegetation for various organisms and species of animals, birds and reptiles, they are threatened by reclamation and degradation resulted from drainage and landfill,discharge of domestic and industrial effluents, solid wastes disposal, hydrological alteration, over-exploitation of natural resources resulting in loss of biodiversity and ecosystem services provided by wetlands.[13] Whenever agriculture and industries are grown, wetlands must be maintained intact, still they are encroached and are in danger. Wetlands are converted into commercial lands or residential area and used for developmental activities by establishing industries and agricultural lands.[14]

In India, wetland has historical significance and Chanakya’sArthashastra makes a mention about wetlands with the name called Anupa or incomparable lands. Sangam Literature also mentions the word ‘Marutam’ fertile area of wetland for cultivation.[15]From 1982 to 2013, totally 26 Indian sites were added to the list of Ramsar sites and during 2014 to 2022, the country has added again 49 new wetlands to the list of Ramsar sites. Now India has taken a step ahead to protect the wetlands available at present in India and it has around 80 Ramsar sites. It covers around an area of 13,26,677 hectares in the country.[16]

The Wildlife Trust of India filed a petition in Allahabad High Court against World Bank project for draining of Etowah and Mainpuri wetlands in UP.[17]

There was a need of making of a national wetland policy, and India hadno specific wetland policy at national or state level. However, a National Committee on Wetlands, Mangroves and Forests,has been constituted by the Ministry of Environment and Forests, that includes with cross-sectoral representation and members drawn from Non-Governmental Organisations and academic institutions.[18] The Committee, meets twice in a year for the purpose ofreviewing wetland-related activity, and it has been divided into two committees, like the Wetlands/Lakes Committee and the Mangroves/Coral Reefs Committee, later wetland committees at State level have also beenestablished.[19]

LEGAL FRAMEWORK TO PROTECT WETLANDS IN INDIA

The Government of India has provided importance for the conservation of wetlands and seeks to bring out its full range of values at all levels of developmental planning and decision-making.[20]In international level Ramsar Convention held in 1971 and India also became a contracting party, signatory, and member on 1st February 1982. As per this convention,[21] parties to this agreement must formulate and implement their rules and plans to promote conservation of the wetlands that are included in the list of Ramsar convention as per the principles of ‘wise use’.[22] There is Montreux record to register about wetland sites listed under Ramsar convention wherein changes occurred and likely to occur in ecological characters of such sites are recorded. For example, Loktak Lake of Manipur and Keoladeo National Park of Rajasthan from India are in Montreux record.[23]

Efforts to conserve wetlands in India began in 1987 and the focus of governmental efforts was on biological methods of conservation rather than adopting engineering options. A national wetland-mapping project has also been initiated for an integrated approach on conservation.The Wetlands(Conservation and Management) Rules, 2010 brought a reformation in conservation of wetlands in India.[24]

In international level, India is party to the Convention on Wetlands, called the Ramsar Convention, an intergovernmental treaty that provides the framework for national action and international cooperation for the conservation and wise use of wetlands and their resources. There are certain rules, regulations and conventions in global level formulated for the purpose of conservation of wetlands around the globe. The Convention on Conservation of Migratory Species of Wild Animals 1979, UNESCO World Heritage Convention 1972, Convention on Biological Diversity 1992, United Nations Convention to Combat Desertification 1994, United Nations Framework Convention on Climate Change 1994 etc are prominent conventions addressing certain matters connected to earth, wetlands and environment.[25]

The National Legal framework of the conservation of the wetlands in India can be understood with different dimensions. Even though there are no specific mention about the protection of wetlands in India in the Constitution of India, certain provisions focus on environment protection. Article 48A under the Directive Principles of State Policy of the Constitution which states, “The State shall endeavour to protect and improve the environment and to safeguard the forests and wildlife of the country.”[26]Under Article 51A (g) there is obligation for the citizens to protect the environment as it is a fundamental duty laid down in the Constitution.[27]

There are no specific legislations enacted directly on wetlands conservation still as a part of environment protection, wetlands are protected by the Environmental (Protection) Act 1986. In order to recognises the ecosystem services provided by wetlands the National Environment Policy, 2006 emphasised the need to set up a regulatory mechanism for all wetlands to maintain their ecological characterand ultimately support their integrated management.Section 3(3) of the Environmental (Protection) Act, 1986, provides an authority to the Central Government to constitute Central Wetlands Regulatory Authority for the purpose to take measures to protect and improve environment.[28]It has also notified for the Wetlands (Conservation and Management) Rules 2017.[29]

The regulatory framework for wetlands is provided with the provisions of the Indian Forest Act, 1927, the Forest (Conservation) Act, 1980 and the Indian Wildlife (Protection) Act, 1972.[30]Such protection is extended to the areas located within forests and designated protected areas. Under the Wildlife Protection Act, it is mentioned that the wetlands within the protected areas of the National Parks and Wildlife Sanctuaries shall be regulated by the provisions of this Act.[31] To conserve, manage and maintain the ecological character of the wetlands without restricting the wise use, significant steps must be taken as per notification made by the Ministry of Environment, Forest, and Climate Change (MoEF&CC) under Wetlands (Conservation and Management) Rules, 2017. These rules provide legal framework for environmental concerns and strengthen the institutional framework through State and Union Territories Wetland Authorities and a National Wetland Committee. In 2006-2011, a National Wetland Inventory and Assessment (NWIA) was conducted in India by using Indian remote sensing satellites.[32]

The Government of India India’s has formulated National Wildlife Action Plan (2017-2031)that has brought to focus the alarming erosion of our natural heritage comprising of rivers, mountains, forests, wetlands, grasslands, marine and coastal habitats, arid lands,and deserts.[33]

The Ministry of Environment, Forest and Climate Change is currently implementing a Centrally Sponsored Scheme namely, National Plan for Conservation of Aquatic Eco-systems (NPCA) for conservation and management of identified wetlands in the country. The scheme covers various activities such as interception, treatment of wastewater, diversion, shoreline protection, storm water management, lake front development, bioremediation, catchment area treatment, education and awareness creation, survey and demarcation, bio-fencing, lake beautification, fisheries development, biodiversity conservation, weed control, community participationetc.[34] 

Under Environmental Protection Act,1986, wetlands are protected and coastal wetlands are protected even under the Coastal Regulation Zone (CRZ) Notification, 2018 and with its further Amendments and the Island Protection Zone (IPZ) Notification 2011.[35] The CRZ notification 2018 mainly aims at clearance of projects on environment, rural and urban area development, tourism infrastructure, Islands conservation, Ecologically Sensitive Areas Conservation, pollution abatement,defense, infrastructure etc. World Wetlands Day is celebrated on 2nd February every year.[36]

The wetlands rejuvenation programme has taken up by MoEF&CC in 2020with four major ideas to implement. They are mainly developing baseline information, providing wetland health cards, providing wetland mitra status to the stakeholders to make rapid assessment of wetlands’ condition and management planning.AmritDharohar Scheme also one of the important plans presented in Union Budget 2023-24. This scheme will be implemented for the next 3 years to encourage optimal use of wetlandsand enhance biodiversity, income generation for local communities, carbon stock and eco-tourism opportunities.[37]

The Guidelines for Conservation and Management of Wetlands in India were issued in 2009. The State Governments have not shown much interest resulted in non-utilization of the funds under the National Wetland (Conservation & Management) Programme (NWCMP). The NWCMP along with the National Lake Conservation Plan (NLCP) have been merged into the National Plan for Conservation of Aquatic Eco-systems 2013.[38]The important role of wetlands in the context of climate change was recognised by National Action Plan on Climate Change 2008.[39]The National Water Mission lists some actions for conservation of wetlands, which are more progressive than the provisions of the Wetlands Rules. For example, formulation and implementation of a regulatory regime to ensure wise use of wetlands at the national level, state levels and also at the district level.[40]It will provide an opportunity for community participation in the conservation and management of wetlands. At the state-level, the judiciary has also played a role in the formulation of the West Bengal Wetlands and Water Bodies Conservation Policy 2012.

JUDICIAL DECISIONS

Other than conventions, policies and rules, there are certain efforts made by the judiciary and the tribunals to preserve wetlands in India. While deciding a matter on public trust doctrine under M. C. Mehta v. Kamal Nath, in 1997, the Supreme Court of India reviewed number of the US courts decisions especially Mono Lake case, in which, it was held that there is judicial concern in protecting all ecologically important lands including fresh water wetlands or riparian forests.[41]

In People United for Better Living in Calcutta v State of West Bengal,[42]the petitioner organization approached the High Court for protection of a Ramsar site on the eastern side of Calcutta. While staying all developmental activities at the Ramsar site, the Court made following observation: “Wetland acts as a benefactor to the society and there cannot be any manner of doubt in regard thereto and as such encroachment thereof would be detrimental to the society which the law as to take note of the requirement of the society. What is required today may not be a relevant consideration in the immediate future, therefore, it cannot really be assessed to what amount of nature's bounty is required for the proper maintenance of environmental equilibrium”[43].

In 2008, Public Interest Litigation filed by Environment Support Group (ESG) of Karnataka, in a lake case, Karnataka High court had ruled on 11th April 2012 that every district would have a lake protection committee to entertain any complaint or proposal to protect and rehabilitate lakes and Raja Kaluve for posterity-as biodiversity and livelihood rich wetlands.  In case the district committees failed to resolve the concern, a quasi-judicial body at the state level headed by the Revenue Secretary along with Member Secretary of Karnataka State Legal Services Authority would attend to the grievance.[44]

In 1996, a proposal for industry and power plant establishment in Dahanu arose and environmentalists fought to preserve Dahanu natural heritage from violation of Dahanu notification. On 24th September 1996, the Supreme Court of India directed the National Environmental Engineering Research Institute (NEERI) Nagpur, to study the plan and report about its confirmation to the Dahanu notification and Coastal Regulation Zone (CRZ) notification 1991.[45]  The report stated that, the plan has violated Dahanu notification and as per Section 3(3) of the Environmental (Protection) Act, 1986, authority must be formulated and the Supreme Court has transferred the matter to Bombay High Court to constitute a Green Bench to deal with environmental issues. The Supreme Court observed that there is decrease in wetlands because of power plants emergence and it has led for disappearance of crisis crossing creeks and natural drains functions as breeding ground for aquatic fauna and erosion control.[46]

In People United for Better Living in Calcutta v East Kolkata Wetlands Management Authority (2008), the High Court permitted the construction of a water treatment plant in the East Kolkata Wetland Area, which is a Ramsar site under the East Kolkata Wetlands (Conservation and Management) Act, 2006. However, the court has imposed a condition that the construction should be in the most eco-friendly manner and remedial measures must be adopted in the vicinity of the area. It has also appointed a monitoring committee to ensure compliance with its directions.[47]The High Court of Kolkata also passed an order by saying that State Governments should not reclaim the wetlands for any commercial or residential purpose.[48]

The National Green Tribunal (NGT) also hears several cases relating to the threat to wetlands.  In Akash Vashishta and Another v. Union of India and Others, the applicants have alleged that the Dadri wetlands/BeelAkbarpur wildlife habitat of protected black buck species, Nilgai and other migratory and resident birds, are being extinct due to activity of builders and others. The NGT has restrained construction in and around the wetlands.[49]

Dheerpur located in the north of Delhi, is a wetland that was under threat of dumping of solid waste and storing of sewage water, harming the soil and the aquatic life. Because of the emergence of residential projects and other infrastructure, the land-use has caused a loss of these wetlands. Later, the Delhi Pollution Control Committee(DPCC) decided to restore these wetlands.[50]In a plea by advocate Gaurav Kumar Bansal that Delhi Metro Rail Corporation (DMRC) workers were dumping solid waste in Dheerpur, leading to deposition of extra soil that was threatening the existence of the water body and that it needs to be protected. The tribunal issued notice to the environment and forests ministry, Delhi government, Delhi Park and Garden Society, DMRC, Delhi Jal Board and Delhi Pollution Control Committee and asked them to file replies within three weeks on a plea seeking formulation of a management plan for the protection of wetlands in the capital. Soan active step has taken by the tribunal for the protection of wetlands in national capital.[51]

Jal Mahal Resort v. K.P. Sharma, litigation petitions filed by the petitioners K.P. Sharma, DharoharBachaoSamiti, Rajasthan and Heritage Preservation Society respectively  against  the  Stateof Rajasthan and the beneficiary of the project, to cancel an Environment andMonument Improvement/Preservation and Tourism Development Project at Jaipur  by declaring it as illegal which was awarded to  the  petitioner/appellant  Jal  Mahal  Resorts  Private Limited via global tender floated in 2003 and  finally granted in 2005.[52]The High Court has directed immediate dismantling and removal of the entire project and diversion of the two drains which was done topurify waters of  a man made artificial water body and detritus.[53]

On 5th January 2021, the Madras High Court said that the government officials must have zero tolerance towards encroachment of waterbodies and ensure that every inch of such encroachment gets removed at the earliest by following the due process of law.[54] This decision has been taken while hearing a public interest litigation petition which sought for removal of encroachments from a 2 acres swamp at Arehalla in Ithalar, a village in Nilgiri Hills.[55]

In case of Swacch Association, Nagpur v. The State of Maharashtra and others, the Supreme Court on 25th January, 2024 decided that not to promote tourism and commercial activities, in Nagpur’s heritage wetland of Futala lake, and stopped all construction activities around the lake. The Maharashtra Government and its Metro Rail Corporations should stop construction activities around wetland. An NGO Swacch Association of Nagpur, argued before the Bench headed by Chief Justice Chandrchud, that the lake is 225-year-old heritage lake and considered as wetland, but in 2023, the Nagpur Bench of Bombay High Court permitted only temporary construction activities after the State took the stand that it was a man-made lake and not a wetland.But the Supreme Court of India upheld the environmental concern and PIL filed to protect the wetland was upheld.[56]

Even though there is central wetland rules, notification of wetlands is with the State Governments still delay in notifying wetlands takes place. The issue of delay in notification of wetlands addressed many a times before the Supreme Court of India and even before the High Courts and also before the National Green Tribunal. In case of Anand Arya & Others v. Union of India, in Uttar Pradesh, the Court specifically interfered by passing an order against the delay in notifying the wetlands by the State.[57]In case of A. Swaminathan, President Narayanapuram Residents Association v. State of Tamil Nadu, it was held that there is responsibility on the part of the State Wetland Authority to take up appropriate actions in regards to preservation of the wetlands. It has been observed that authorities fail to take any action and National Green Tribunal has to intervene in the matters of construction of residential area buildings on wetland, prevention of releasing of waste to the area of wetlands etc. In case of Kerala State Coastal Zone Management Authority v. Maradu Municipality &Ors.[58]the Supreme Court of India issued an order for removal and demolition of a residential complex near a coastal wetland in Kerala.[59]

SUGGESTIONS

Assessment of wetland ecosystem should be made a part of district level disaster planning processes. Wetlands conservation and restoration should be made as prime important matter of the governments. States should constitute Wetland Authorities as nodal agencies for integrated policy, planning and regulation of wetlands. The government must build awareness among the people from the local level to understand the significance of conservation of wetlands and the possible risks if they are not preserved properly. Encroaching wetlands for mega projects or any other industrial activities must be prevented and such wetlands always maintain humidity and they are acting as one of the prominent water bases even during summer. Moreover, it is the duty of every citizen to preserve and conserve the natural environment and rich heritage of our country.

CONCLUSION

                Wetlands are the part of our mother earth and conservation of them is the prime importance of all of us because wetland is abode of many living creatures and keeps environment away from global warming. By studying all about wetlands, it is understood that wetlands play a major role in maintaining healthy ecosystem and to prevent disasters on earth. The judicial decisions also focused on preservation and protection of wetlands in and around us. Conservation of wetlands in not mere the concern of a particular country, it is a global concern as a part of environmental protection. 

* Assistant Professor of Law, SDM Law College, Mangaluru, Karnataka, India.

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[13]MalabikaBiswas Roy, Swetasree Nag, Sudipa Halder & Pankaj Kumar Roy, “Assessment of wetland potential and bibliometric review: a critical analysis of the Ramsar sites of India”, (2022), Bulletin of the National Research Centre, 4, vol. 46, Springer publications.

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[16]Supra note 12.

[17]Supra note 6 at p. 102.

[18] Devaki Panini, “The Ramsar Convention and National Laws and Policies for Wetlands in India”-case study, (1998),Technical Consultation on Designing Methodologies to Review Laws and Institutions Relevant to Wetlands,6, Switzerland.

[19]Supra note 7 at p. 72.

[20]Supra note 12.

[21]Prof. S. C. Shastri, Environmental Law,(6thed, Eastern Book Company, Lucknow, 2020) 315.

[22]Supra note 3.

[23]Dr. Anurag Linda, Environmental Science-Ecology, Biodiversity and Climate Change, (Excellent Book Publications, New Delhi 2012) 101.

[24] M. Z.M. Nomani , “Legal Policy for Wetland Conservation in India: A Review “, (2012), Pragyaan: Journal of Law" 86, vol. 2, Issue 2.

[25] An Introduction to the Ramsar Convention on Wetlands- Ramsar Handbook, Ramsar Convention Secretariat ( 5thed, Switzerland, 2016). 7.

[26] Durga Das Basu, Constitutional Law of India, (6thed, Prentice-Hall of India 1991).132.

[27]P M Bakshi, Constitution of India, (Universal Law Publishing Company Limited, New Delhi, 2010), 92.

[28]Supra note 2.

[29]Supra note 21 at p.315.

[30] Wetlands Conservation-Approach and Initiatives, Ministry of Environment, Forest and Climate Change Government of India, <https://indianwetlands.in/wp-content/uploads/library/1707221982.pdf,>accessed 20March 2024.

[31]Supra note 18 at p. 3.

[32] Aditi Tandon, “Explained: What Are Wetlands and Why Are They Important?” Science the wire, (2021) <https://science.thewire.in/environment/explained-wetlands-why-are-they important/#:~:text=A%20National%20Wetland%20Inventory%20and,for%20each%20State%20and%20UT>, accessed23 March 2024.

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[36]Supra note 12.

[37] Press Information Bureau, Ministry of Information and Broadcasting, Government of India, Ministry of Environment, Forests and Climate Change, (February 01, 2023).

[38] Guidelines for implementing Wetlands (Conservation and Management) Rules, 2017, 49, Ministry of Environment, Forest and Climate Change Government of India (2020), <https://indianwetlands.in/wp-content/uploads/library/guideline-of-implemention.pdf,> accessed 20th Feb.2024.

[39] Clayton Rubec, Guidelines for developing and implementing National Wetland Policies,(1999), <https://www.ramsar.org/sites/default/files/documents/pdf/guide-nwp-e.pdf>, accessed  19 March 2023.

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[41]Supra note 11 at p.170.

[42]AIR 1993 Calcutta 215.

[43]Supra note 3 at p. 114.

[44]“Building Environmental Jurisprudence to Reclaim Lakes as Commons for Posterity: Compilation of ESG Lake Work”, (12th August, 2021), <https://esgindia.org/new/education/karnataka-high-court-directs-state-to-ensure-karnataka-lakes-are-protected-per-2012-order-in-esg-pil/>accessed 5 March 2023.

[45]Geetanjoy Sahu, “Implementation of Environmental Judgments in Context: A Comparative analysis of Dahanu Thermal Power Plant Pollution Case in Maharashtra and Vellore Leather Industrial Pollution Case in Tamil Nadu” Law, Environment and Development Journal,(2010) vol.6, issue 3, 342.

[46]Supra note 11 at p. 466.

[47]People United for Better Living in Calcutta v. East Kolkata Wetlands Management Authority, (W.P. No. 106 of 2007 (Original Side))- Decided On, 24 December 2008, <https://www.lawyerservices.in/People-United-for-Better-Living-in-Calcutta-Versus-East-Kolkata-Wetlands-Management-Authority-2008-12-24>, accessed 6March 2023.

[48]C M Abraham, Environmental Justice in India, (Springer publications, Netherlands, 1999)132.

[49]Akash Vashishta v. Union of India-National Green Tribunal (12th September 2017).

[50] Gunjan Piplani, “All You Need to Know about Dheerpur Wetlands Restoration Project”, (December 19th, 2017)<https://www.proptiger.com/guide/post/all-you-need-to-know-about-dheerpur-wetlands-restoration-project>,accessed 6 March 2023.

[51] The Indian Express, Tribunal notice to Centre, State over city’s Wetlands, (30th April, 2014).

[52]Jal Mahal Resorts P.Ltd. v. K.P.Sharma, Civil Appeal No.4912 of 2014, <https://www.legalauthority.in/judgement/jal-mahal-resorts-p-ltd-vs-k-p-sharma-5377>accessed 5 March 2023.

[53]Supra note 3 at p.115.

[54] Ensure zero tolerance towards encroachment of water bodies, Madras HC tells Govt. officials, The Hindu, (January 06, 2021), Chennai, <https://www.thehindu.com/news/national/tamil-nadu/ensure-zero-tolerance-towards-encroachment-of-water-bodies-madras-hc-tells-govt-officials/article33506463.ece>,accessed 10 April 2024.

[55]Aradhita Banerjee, “PILs to Protect Ramsar Site in Kolkata: Towards Realisation and Actualisation of SDGs”, 6, (September 15, 2022),<https://ssrn.com/abstract=4377127 or http://dx.doi.org/10.2139/ssrn.4377127>, accessed  4April 2024.

[56] Dhananjay Mahapatra, “Don’t mess around with nature: Supreme Court”, The Times of India, (Jan 26, 2024)<http://timesofindia.indiatimes.com/articleshow/107161254.cms?utm_source=contentofinterest&utm_medium=text&utm_campaign=cppst>,accessed10March 2024.

[57] National Green Tribunal, Anand Arya v. Union of India on 20 November, 2023.

[58](2019) 7 SCC 248, Kerala State Coastal Zone Management Authority v. Maradu Municipality &Ors.

[59] Shyama Kuriakose, “Legal Responses to Multiple Challenges Facing Wetland Management”, RGNUL Student Research Review, Rajiv Gandhi National University of Law, Punjab, (29th Nov.2019), <https://www.rsrr.in/post/legal-responses-to-multiple-challenges-facing-wetland-management>,accessed 5 April 2024.