Why in news?
On 7 October 2025 the Supreme Court of India ruled that the public trust doctrine applies not only to natural water bodies but also to man‑made lakes that serve ecological functions. The case concerned Futala Lake in Nagpur, an artificial reservoir facing encroachment by commercial development. The court held that authorities are duty‑bound to safeguard such water bodies for public use and environmental health.
Background
The public trust doctrine, inherited from Roman law and adopted in Indian jurisprudence, declares that certain natural resources – such as air, water and forests – are held in trust by the State for the benefit of all citizens. In India it gained prominence through landmark cases like M.C. Mehta v. Kamal Nath (1997), where the Supreme Court restrained private encroachment on riverbanks. The doctrine flows from constitutional directives in Articles 48A and 51A(g), which mandate the State and citizens to protect the environment.
The Futala Lake case
- Man‑made yet ecological: Futala Lake was constructed in the eighteenth century for irrigation. Although artificial, it sustains biodiversity, recharges groundwater and provides recreation for Nagpur residents.
- PIL and High Court ruling: A public interest litigation challenged government plans to build hotels and commercial amenities on reclaimed land around the lake. The Bombay High Court had dismissed the petition, noting the lake was man‑made and not protected under the Wetlands (Conservation and Management) Rules.
- Supreme Court judgement: The apex court overturned this reasoning, stating that the public trust doctrine is not confined to natural wetlands. Any water body, natural or artificial, that performs environmental functions warrants protection. The court emphasised that the right to a healthy environment forms part of the fundamental right to life under Article 21.
- Directions: Authorities were directed to ensure no permanent constructions within the lake area and to maintain the ecological character of the water body.
Implications
- Broadened scope: The judgement extends environmental protection to man‑made lakes, ponds and reservoirs across India, closing a loophole that allowed commercial exploitation.
- Strengthened environmental jurisprudence: By grounding the public trust doctrine in fundamental rights, the court reaffirmed the State’s obligation to act as trustee of natural resources.
- Community empowerment: The ruling empowers citizens and civic groups to challenge encroachments on water bodies, fostering participatory conservation.
Conclusion
The Supreme Court’s decision underscores that environmental stewardship is a shared constitutional duty. Whether natural or man‑made, water bodies are part of our collective heritage; authorities must preserve them, and citizens must remain vigilant to ensure that development does not undermine ecological integrity.
Source: LawBeat · Down To Earth