In a significant ruling with wider implications for grassroots environmental disputes, the Supreme Court on Wednesday upheld the National Green Tribunal’s dismissal of Talli Gram Panchayat’s challenge to a limestone mining clearance in Gujarat. The bench made it clear that the “first public communication” of an environmental clearance-not later discoveries-starts the clock for filing appeals. The decision effectively shut the door on the Panchayat’s delayed attempt to contest the 2017 clearance.
Background
The dispute began when the Ministry of Environment, Forest and Climate Change (MoEF&CC) granted environmental clearance (EC) on 5 January 2017 for a 193-hectare limestone mining project in Talli and Bambor villages, Gujarat. According to the case file, the EC was uploaded on the MoEF website the same day, and the project proponent submitted copies to local Panchayats by 9 January 2017. Advertisements announcing the EC also appeared in two local newspapers on 11 January.
Despite these steps, Talli Gram Panchayat approached the National Green Tribunal only on 19 April 2017-well beyond the maximum permissible 90-day appeal period. The Panchayat argued that it first learned of the EC only through an RTI reply dated 14 February 2017.
The NGT rejected this explanation, calling the RTI claim a “pretext,” and dismissed the appeal as time-barred. When the dispute reached the Supreme Court, the questions narrowed to one thing: When does “communication” of an EC legally occur?
Court’s Observations
During the hearing, the bench analyzed both statutory obligations and earlier legal precedents. The judges emphasized that multiple authorities-MoEF&CC, the project proponent, Pollution Control Boards-must place ECs in the public domain. Each has its own mode of communication, and these timings naturally don’t sync perfectly.
In a key line that shaped the entire judgment, the bench observed, “Limitation will commence from the earliest of the dates on which the communication is carried out by any of the duty bearers.”
The Court referred to the detailed compliance table reproduced by the NGT, noting that MoEF had uploaded the EC online on 5 January 2017, complete with confirmation logs. Local Panchayats acknowledged receipt by 9 January 2017, and newspaper notices followed on 11 January 2017. These steps, the Court said, meant the EC was already fully “in the public domain.”
Another important observation addressed a common confusion: whether the entire EC-including conditions and safeguards—must be published in newspapers. The Court rejected this interpretation as “pedantic.” The bench noted that announcing the fact of approval and directing readers to official portals is enough, explaining that “the size of the advertisement is immaterial; what it conveys is material.”
The Court also stressed that allowing appeals to start only when a late-acting authority completes its duty would “frustrate the very object of limitation law” and leave projects open to litigation indefinitely.
Decision
Concluding that the EC had been publicly communicated on 5 January 2017, the Supreme Court held that the appeal should have been filed no later than early April 2017, even after including the 60-day extendable period. Filing it on 19 April made it definitively time-barred.
With that, the Court dismissed the civil appeal, affirming the NGT’s order. “There is no error in the conclusion drawn by the Tribunal,” the bench said, ending the matter.
Case Title: Talli Gram Panchayat vs. Union of India & Others
Appeal Type: Civil Appeal No. 731 of 2023
Court: Supreme Court of India
Citation: 2025 INSC 1331
Date of Judgment: 19 November 2025