UPSC Mains 2022 GS Paper 2 Q1: model answer
“The most significant achievement of modern law in India is the constitutionalization of environmental problems by the Supreme Court.” Discuss this statement with the help of relevant case laws.
What the question wants
Discuss, with cases, how the Supreme Court made environmental protection a constitutional matter.
How to structure it
Discuss with case laws: the textual base, the doctrines invented, then an assessment.
- Text
- Key cases and doctrines
- Assessment
How to think it through
The Constitution as written in 1950 didn't say 'environment' at all; Articles 48A and 51A(g) came only in 1976. The Court built the rest through Article 21. Arrange cases by doctrine, not by year, and the answer looks organised.
Model answer
In 1986 a gas leak at Shriram Foods in Delhi led the Supreme Court in M.C. Mehta v Union of India to create 'absolute liability' for hazardous industries, a rule stricter than English law.
The text
Articles 48A (state to protect environment) and 51A(g) (citizens' duty) were added by the 42nd Amendment, 1976. Both are nonjusticiable.
How the Court constitutionalised it
- Right to life includes a clean environment: Subhash Kumar (1991); Rural Litigation (Dehradun quarrying, 1985).
- Absolute liability: M.C. Mehta (Oleum gas, 1986).
- Polluter pays and precautionary principle: Vellore Citizens' Welfare Forum (1996).
- Public trust doctrine: M.C. Mehta v Kamal Nath (1997).
- Continuing mandamus: T.N. Godavarman (forests, from 1995), Delhi's CNG buses (1998).
- Inter-generational equity and sustainable development.
- Right against climate change: M.K. Ranjitsinh (2024), protecting the Great Indian Bustard.
- Led to the National Green Tribunal Act, 2010.
Assessment
It filled a legislative gap and gave citizens a remedy. Critics say courts lack technical expertise and orders are poorly implemented. Still, it ranks among the most important achievements of Indian law.
Draw: Tree with Article 21 as trunk and each doctrine as a branch.
Keywords, cases and data to drop in
Article 21, 48A, 51A(g), absolute liability, polluter pays, precautionary principle, public trust, Godavarman, M.K. Ranjitsinh 2024, NGT.
Where most answers lose marks
- Listing cases without naming the doctrines they created.
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Question text as printed in the official UPSC Civil Services (Main) question paper. The model answer is original Battle IAS work; use it to learn structure, not to memorise.
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