Abstract
Sustainable development concept which began to emerge as early as the 1970s, notably after the 1972 UN Conference in Stockholm[1], is a framework composed of different principles for global development that seeks to harmonize human well-being and environmental sustainability. The adoption of sustainable development goals in worldwide was a necessary step, as in the pursuit of development, the mostly exploited entity is the mother nature. In India, sustainable development goal 15 has found a firm foothold in jurisprudence through the interpretation of Article 21[2], Article 48-A[3] and 51-A (g)[4] of the Constitution, by the courts to protect and promote healthy environment. Environmental litigation particularly through Public Interest Litigation (PIL) in India has become a powerful mechanism for securing environmental justice and supporting the nation’s commitment towards sustainable development goal 15. The progressive interpretation of Indian judiciary enhances not only the transformative potential of the Constitution but also open new areas of environmental jurisprudence.
This paper primarily focuses on the contribution of environmental litigation in India to achieve SDG 15 and its role in enabling judiciary to perceive the constitutional vision of environmental protection. The objective of this paper includes examining the landmark cases in India, such as T.N. Godavarman Thirumulapad v. Union of India (2024)[5], State of Bihar and others. v. Pawan Kumar and others. (2021)[6], among others, which signifies ongoing efforts towards achieving the objectives of Goal 15: Life on Land.The methodology used for this paper is purely doctrinal. Analytical method has been adopted to analyse the primary sources. Secondary sources like reports, books, journal are also examined for the purpose of this research.
Keywords: Environmental litigation, Sustainable Development Goal 15, Indian Judiciary, Constitutional environmentalism, interpretation.
INTRODUCTION:
Environment furnishes all essentials for human life, the relationship between humans and nature has always been deeply interconnected. A healthy territorial ecosystem is necessary for sustaining economies, to prevent desertification and for the well-being of human and planet as living organism relies on a sound environment to flourish. However, the world today is confronted with a threefold planetary crisis- climate change, biodiversity and ecosystem loss, and rising pollution. World’s original forest cover has significantly declined leading to disruptions in the balance of healthy ecosystem. Resources of the nature are being exploited unsustainably in the name of development.These challenges undermine the enjoyment and protection of human rights and intensify environmental injustices across the globe. Conservation of world’s territorial ecosystem, forests, biodiversity can help to tackle these issues, including growing climate injustice and disappearance of countless species from nature.
In response to these global issues, the United Nations adopted the Sustainable Development Goal (SDGs), comprising 17 interlinked goals that inspired all the countries to collaboratively work towards a safer and sustainable world. Among these, SDG 15 particularly focuses the protection, restoration and promotion of ecosystem, biodiversity and forest, which are the most important components of nature.[7]
In India, the Constitution, through its Fundamental Rights, Directive Principles of State Policy (DPSP), and Fundamental Duty reflects a constitutional vision that recognizes the importance of environmental protection. Over the time, the Indian Judiciary has interpreted Article 48-A, Article 21 expansively to meet the evolving Environmental challenges and to align the national commitments with global standards such as SDG-15. The Supreme Court and Hight Courts, empowered by Article 32 and 226 have actively reviewed state actions, protected environmental rights and developed innovative legal principles through Public Interest Litigation and Suo Motu interventions and contributed to Environmental Jurisprudence. The major institutional developments in this regard are the National Green Tribunal 2010, that enacted to ensure speedy and effective disposal of environmental cases.
Thus, the Indian judiciary gradually developed concepts such as ‘Environmental Jurisprudence’, ‘Environmental Justice’ for the protection of nature, biodiversity, wildlife in India thereby reinforcing the Constitutional vision and strengthening India’s commitment to achieving SDG-15.
[1]United Nations, United Nations Conference on the Human Environment, Stockholm 1972, United Nations, https://www.un.org/en/conferences/environment/stockholm1972 (last visited Oct. 26, 2025).
[2]Constitution of India of 1950. art. 21
[3]Id. art. 48-A
[4]Id. art. 51-A (g)
[5]In Re: T. N. Godavarman Thirumulpad v. Union of India & Ors., INSC 178 (Delhi High Court 2024).
[6]The State of Bihar and Others v. Pawan Kumar and Ors., INSC 713 (2021).
[7]SDG 15: Life on Land, Naman Jain (Aug. 26, 2025), https://namanjain.in/2025/08/26/sdg-15-life-on-land/.