Supreme Court Sets Aside ₹5 crore Fine On Art of Living Over Yamuna Floodplains Damage

The Supreme Court has set aside the National Green Tribunal’s 2017 order holding Vyakti Vikas Kendra India, associated with the Art of Living Foundation, liable for environmental damage to the Yamuna floodplains arising from the organisation’s World Culture Festival held in Delhi in March 2016.

A Bench of Justices Satish Chandra Sharma and N. Kotiswar Singh allowed the appeal and directed the Delhi Development Authority (DDA) to refund the ₹5 crore environmental compensation deposited by the appellants.

"The Tribunal completely altered the character of the dispute before itself and converted it into a proceeding for fresh development of the Yamuna floodplain, and in doing so, it burdened the appellant to bear the expenses of such development activity. Effectively, the Tribunal burdened the appellant with the task of developing something that it never destroyed,” court has held.

The dispute arose from the World Culture Festival organised between March 11 and 13, 2016, on approximately 25 hectares of the Yamuna’s active floodplain. Environmental activists, including Manoj Misra of Yamuna Jiye Abhiyaan, approached the NGT contending that the large-scale construction and preparations for the event would cause serious ecological damage to the floodplain and the Yamuna ecosystem.

The NGT had appointed an expert committee to examine the condition of the site. On the basis of its report, the Tribunal, through an interim order dated March 9, 2016, permitted the event to proceed but directed the organisers to deposit ₹5 crore as environmental compensation. The amount was subsequently directed to be utilised for restoration and rehabilitation of the floodplain. In its final order of December 2017, the NGT held the Art of Living entity responsible for environmental degradation and directed restoration of the affected portion of the floodplain.

The Supreme Court, however, found that the evidence on record did not establish a direct causal connection between the event and the alleged environmental damage. The Court noted that the site was already in a substantially damaged or dilapidated condition before it was handed over to the organisers. Contemporary material also indicated that construction debris and other forms of deterioration were already present at the site.

A significant aspect of the judgment was the Court’s scrutiny of the expert committee’s findings. The Bench observed that the committee itself had acknowledged difficulties in determining the precise ecological condition of the floodplain before the event. Despite this uncertainty, its recommendations proceeded towards broader ecological rehabilitation. The Supreme Court held that the NGT relied upon this material without adequately reconciling it with other contemporaneous evidence concerning the pre-event condition of the site.

The Court also questioned the reliance placed on satellite imagery and the manner in which the NGT assessed the condition of the floodplain. According to the Supreme Court, the material before the Tribunal contained inconsistencies, including evidence suggesting that the site had suffered substantial degradation even before the festival. A subsequent government officials’ committee reportedly found grass and water at the site, no debris and no significant wetland or water body within the allotted area, while also finding no significant difference between certain pre- and post-event imagery.

Court nevertheless has not absolve public authorities of their responsibilities towards the Yamuna floodplains. It criticised the DDA’s decision to permit a large-scale event on the active floodplain and emphasised the authority’s obligations to protect the ecologically sensitive area. The Court noted that the DDA’s statutory responsibilities and the public trust doctrine required it to take preventive measures against further deterioration. However, the legality of the permission granted for the 2016 event was not directly before the Court in the present appeal.

Importantly, the judgment does not mean that rehabilitation of the Yamuna floodplains can be discontinued. The Supreme Court directed the DDA to continue rehabilitation work in accordance with the plans and directions issued by the NGT. Thus, while the Art of Living entity was relieved of financial liability for the alleged damage, the responsibility of restoring and protecting the floodplain remains with the concerned public authority.

While permitting DDA to continue with the rehabilitation of the floodplain as ordered by the NGT from time to time, the bench held, “The manner in which permission was granted by DDA to hold the event on an active floodplain of the river cannot be approved. It was not only avoidable, but was also not consistent with the precautionary principle and doctrine of public trust. The authority failed to act in accordance with its duties towards the public at large.”

The ruling therefore underscores that environmental liability must be supported by a demonstrable connection between the conduct of a particular party and the harm alleged against it.