Summary and Analysis of Ms Triveni Engineering and Industries Ltd vs State of Uttar Pradesh & Ors 2025 INSC 1060

1. Heading of the Judgment

Supreme Court of India – Civil Appellate Jurisdiction
Civil Appeal Nos. 8119–8120 of 2022
Appellant: M/s. Triveni Engineering and Industries Ltd.
Respondents: State of Uttar Pradesh & Others
Date of Judgment: September 1, 2025
Judges: Hon’ble Mr. Justice Manoj Misra and Hon’ble Mr. Justice Ujjal Bhuyan

Citation: M/s. Triveni Engineering and Industries Ltd. v. State of Uttar Pradesh & Ors., 2025 INSC 1060 (Supreme Court of India, September 1, 2025).

2. Relevant Laws and Sections

• Water (Prevention and Control of Pollution) Act, 1974:
  Sections 21–22: Procedure for sampling and analysis of effluents

• Environment (Protection) Act, 1986:
  Sections 7, 8, 14A, 15: Prohibition of pollution and penalties

• National Green Tribunal Act, 2010:
  Section 19: Procedure and powers of NGT (guided by natural justice)
  Section 15: Relief and compensation

• Constitutional Principles:
  Natural justice (audi alteram partem)
  Article 14: Right to equality and fair procedure

3. Basic Judgment Details

The Supreme Court allowed the appeals filed by M/s. Triveni Engineering and Industries Ltd. and set aside the orders of the National Green Tribunal (NGT) dated February 15, 2022, and September 16, 2022. The NGT had imposed a compensation of ₹18 crores on the appellant for alleged environmental violations. The Supreme Court held that the NGT’s orders were passed in violation of statutory procedures and principles of natural justice.

4. Explanation of the Judgment

Background

The appellant, a sugar manufacturing company, was accused of discharging untreated effluents into a drain, contaminating groundwater in Muzaffarnagar, Uttar Pradesh. A complaint was filed before the NGT, which constituted a joint committee (CPCB, UPPCB, District Magistrate) to inspect the unit. The committee submitted reports alleging violations, including illegal disposal of effluents, dilution with fresh water, and absence of records. Based on these reports, the NGT directed the appellant to pay ₹18 crores as environmental compensation.

Key Issues Before the Supreme Court

1. Whether the NGT violated principles of natural justice by not impleading the appellant as a party or granting a hearing?

2. Whether the joint committee followed the statutory procedure under the Water Act, 1974?

3. Whether the NGT’s reliance on the committee’s reports without independent adjudication was legal?

Supreme Court’s Analysis & Directions

A. Violation of Natural Justice

• The appellant was not impleaded as a party in the original NGT proceedings, despite being the primary affected entity.

• No opportunity was given to the appellant to contest the joint committee’s reports or present its defense.

• The NGT passed adverse orders without hearing the appellant, violating the principle of audi alteram partem (hear the other side).

B. Non-Compliance with Statutory Procedure

• The joint committee did not follow Sections 21–22 of the Water Act, 1974, which mandate:
  Notice to the occupier before sampling.
  Collection and sealing of samples in the presence of the occupier.
  Analysis by authorized laboratories.
  Sharing of reports with the occupier.

• The committee’s reports were based on non-compliant procedures and were thus inadmissible as evidence.

C. NGT’s Abdication of Adjudicatory Role

• The NGT blindly relied on the committee’s reports without independent evaluation.

• It imposed compensation without adjudicating the merits or allowing the appellant to cross-examine or rebut the findings.

• The NGT outsourced its judicial function to an administrative committee, which is impermissible.

D. Precedents Relied Upon

• Municipal Corporation of Greater Mumbai v. Ankita Sinha (2021): NGT must hear affected parties before passing orders.

• Grasim Industries Ltd. v. State of Madhya Pradesh (2024): NGT cannot condemn a party unheard.

• A.K. Kraipak v. Union of India (1969): Principles of natural justice apply to administrative and quasi-judicial actions.

Conclusion

The Supreme Court held that the NGT’s orders were illegal and void due to:

• Violation of natural justice.

• Non-compliance with statutory procedures under the Water Act, 1974.

• Failure to exercise independent adjudicatory functions.

The appeals were allowed, and the NGT’s orders were set aside. However, the Court clarified that the Uttar Pradesh Pollution Control Board (UPPCB) is free to conduct a fresh inspection by following due process under the Water Act and principles of natural justice.