The Supreme Court of India has dismissed the petition filed by the Tamil Nadu Pollution Control Board (TNPCB) against Isha Foundation, stating that no coercive action should be taken regarding the construction of the Isha Yoga and Meditation Centre in Coimbatore.
The apex court upheld the Madras High Court's decision, which had earlier quashed the show cause notice issued to Isha Foundation for carrying out construction between 2006 and 2014 without obtaining environmental clearance. The bench, comprising Justice Surya Kant and Justice N.K. Singh, agreed with the High Court’s reasoning and dismissed TNPCB’s plea.
During previous hearings, the Supreme Court questioned TNPCB’s delay in filing the appeal—stating that it was raised two years after the High Court’s decision. The court also noted that Isha Foundation’s yoga center qualified as an educational institution, which was entitled to certain exemptions.
While ruling in favor of Isha Foundation, the Supreme Court emphasized:
"It goes without saying that if there is any need for expansion in future, the Respondent no.1 will seek prior submission of the competent authorities."
However, the court clarified that this ruling should not be used as a precedent to regularize other illegal constructions. It also mandated that any future expansions by Isha Foundation must comply with legal requirements and obtain necessary approvals.
Background of the Case
The case originated from a show cause notice issued by TNPCB on November 19, 2021, accusing Isha Foundation of undertaking construction without mandatory environmental clearance as per the Environment Impact Assessment (EIA) Notification, 2006.
Challenging the notice, Isha Foundation approached the Madras High Court, arguing that its construction activities began in 1994—long before the EIA Notification came into effect. The foundation also claimed exemption from environmental clearance, stating that it operates as an educational institution focused on mental and spiritual development.
The Central Government backed Isha Foundation's argument, stating that it met the criteria of an educational institution. A clarification issued in 2014 had exempted educational institutions, industrial sheds, and hostels from obtaining prior environmental clearance.
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Further, a memorandum issued in 2022 expanded the definition of "educational institution" to include centers imparting training essential for mental, moral, and physical development.
In 2022, the Madras High Court quashed TNPCB’s notice, reasoning that Isha Foundation’s yoga and group development activities fit within the definition of an "educational institution."
"Since the foundation is engaged in promoting yoga and group development activities, it falls within the purview of an educational institution and is exempt from obtaining prior environmental clearance."
Additionally, the High Court noted that a stay order issued by the Kerala High Court against such exemptions was only applicable within Kerala’s jurisdiction, and therefore did not impact Tamil Nadu.
Case Title: Tamil Nadu Pollution Control Board v. Isha Foundation, Diary No. 57906/2024