Bhopal Municipal Corporation Vs Dr Subhash C. Pandey & Ors. (Supreme Court of India)
The Supreme Court heard two appeals arising from separate orders of the National Green Tribunal concerning environmental compliance by the Bhopal Municipal Corporation under the Solid Waste Management Rules, 2016. The Madhya Pradesh Pollution Control Board filed an additional affidavit and compliance status report. Upon review, the Court found partial compliance with the 2016 Rules but noted that further steps were required.
The Court observed that the Solid Waste Management Rules, 2026, effective from 01.04.2026, introduce a comprehensive and updated framework for solid waste management. Considering uneven compliance under the 2016 regime and the scale of challenges, the Court issued nationwide directions to ensure effective implementation of the 2026 Rules. It held that the right to a clean and healthy environment is part of the Right to Life under Article 21 of the Constitution, and that the State has a duty to protect the environment.
Referring to the Central Pollution Control Board’s Annual Report 2021–2022, the Court noted that approximately 170,000 tonnes per day of municipal solid waste was generated in the country, of which around 156,000 tonnes were collected, 91,000 tonnes treated, and 41,000 tonnes landfilled. Despite improved collection in some cities, processing remains a major bottleneck, with unprocessed waste ending up in unscientific landfills or legacy dumpsites. Segregation at source into wet, dry and hazardous streams remains incomplete in many areas.
