MP High Court Dismisses PIL Against Modern Bhopal Slaughterhouse, Calls It "Misuse Of Process"

The Madhya Pradesh High Court has dismissed a public interest litigation seeking the closure of a new, modern slaughterhouse built at Jinsi, Bhopal, holding that the plea amounted to a "misuse of process of law" raising issues already settled before the National Green Tribunal, and that it came three years too late, after the facility had already been constructed, licensed and put into operation.

A Division Bench of Acting Chief Justice Vivek Rusia and Justice Pradeep Mittal was hearing a petition filed by Dayoday Mahasangh, Rashtriya Jiv Sanshan Ekta Sangh and Jan Jagrati Samiti, three Bhopal-based organisations describing themselves as believers in "Ahinsa Parmodharmah," seeking a writ of mandamus for the immediate and permanent closure of the "massive-capacity" abattoir operating at Maida Mill Road, Jinsi.

Shri Sankalp Kochar and Shri Yash Lodha, advocates for the petitioners, argued that the new facility could not be permitted to operate in a manner that defeated the National Green Tribunal's 2015 order shutting down the old Jinsi Road slaughterhouse. That closure had followed findings that the old facility discharged untreated effluent into the Patra Nallah-Halali-Betwa river system without a functional treatment plant, in violation of the Water (Prevention and Control of Pollution) Act, 1974. The petitioners argued that identifying land adjoining the very site ordered shut, for a "modern" slaughterhouse, effectively circumvented the Tribunal's directions, and relied on the Supreme Court's ruling in Laxmi Narain Modi vs. Union of India.

The petitioners also pointed to the scale of the new facility, citing figures of roughly 200 metric tonnes of meat processing and 60 metric tonnes of rendering capacity daily, along with a stated slaughtering capacity of about 500 large animals and 1,000 small animals a day, as inconsistent with the spirit of the closure directions.

Appearing for the Bhopal Municipal Corporation, learned counsel submitted that the Corporation had acted precisely in furtherance of the Tribunal's directions, building a facility with substantially improved infrastructure and environmental safeguards that was "fundamentally different" from the old, non-compliant unit. Shri Anubhav Jain, Government Advocate, appeared for the State, while Shri Siddharth Seth represented MP Pollution Control Board and Shri Suyash Mohan Guru appeared for the Municipal Corporation.

Counsel for respondent No.5, Ms. Livestock Food Processors Pvt. Ltd., the private operator engaged under a design-build-finance-operate-transfer arrangement, was represented by Shri Rahul Chourey, Shri Shubham Patel and Shri Gaurav Tiwari. They submitted that roughly ₹29 crore had already been spent on the project, a fact the Supreme Court itself had noted in March 2024 while staying an earlier High Court order that had halted construction. They argued that a fully built and operational public infrastructure project could not now be undone.

The bench traced the full history: after prolonged NGT proceedings, a joint committee found 2.67 acres adjoining the old site suitable, and the Corporation issued a work order in June 2022 to the private operator. That decision was challenged separately in 2022, leading to a High Court stay in December 2023, a Supreme Court stay of that stay in March 2024, and eventual withdrawal of both the writ petition and the special leave petition by September 2024.

Weighing this, the court found that the present petitioners had approached it "after a period of 3 years," by which time the slaughterhouse stood fully constructed and operational. It noted that the Madhya Pradesh Pollution Control Board had already inspected the facility and granted the necessary licence. "The present public interest litigation is nothing but misuse of process of law raising issue which has already been concluded before the NGT, which is an competent forum under National Green Tribunal Act," the bench held, dismissing the petition.

Case Title: Dayoday Mahasangh and Others vs. The State of Madhya Pradesh and Others

Date of Order: September 1, 2026

Bench: Acting Chief Justice Vivek Rusia and Justice Pradeep Mittal