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W.P.(MD) No.3663 of 2019 BEFORE THE MADURAI BENCH OF MADRAS HIGH COURT Date of Reserving the Order Date of Pronouncing the Order 05.11.2019 18.11.2019 CORAM: THE HONOURABLE MR.JUSTICE T.S.SIVAGNANAM and THE HONOURABLE MRS.JUSTICE R.THARANI W.P.(MD) No.3663 of 2019 and W.M.P.(MD) No.2865 of 2019 1.S.M.K.Balakrishnan 2.M.Selva Ganapathi 3.M.Mallarasan 4.K.K.Mani 5.T.M.V.Rathinasamy ... Petitioners -vs- 1.The Union of India represented by the Secretary Ministry of Environment and Forest Indiara Paryavaran Bhavan Jorbagh Road New Delhi-110 003 1/26 http://www.judis.nic.in W.P.(MD) No.3663 of 2019 2.The Government of Tamil Nadu Rep.by its the Secretary to the Government Department of Animal Husbandry and Fisheries Department Fort St.George Chennai-600 009 3.The Principal Chief Conservator of Forest Tamil Nadu Forest Department Panagal Maligai Saidapet, Chennai 4.The District Collector Dindigul District Dindigul 5.The Director of Fisheries Department of Fisheries Sivasankaran Road Chokkalingam Nagar Teynampet Chennai-6 6.The District Forest Officer Kodaikanal Wild Life Division Dindigul District 7.The Mannavanur Village Panchayat Rep.by its Special Officer/ Executive Officer Mannavanur Village Kodaikanal, Dindigul District ... Respondents PRAYER: Petition filed under Article 226 of the Constitution of India, to issue a writ of mandamus forbearing the respondent No.5 from establishing the fish farming Aqua Culture Center in S.No.967 to an extent of 86.93.00 Hectares at Mannavanur Village, Kodaikanal Taluk, Dindigul District. 2/26 http://www.judis.nic.in W.P.(MD) No.3663 of 2019 For Petitioners : Mr.T.Lajapathi Roy For Respondents : Mr.B.Rajesh Saravanan Central Government Standing Counsel for R1 Mr.A.K.Baskarapandian Special Government Pleader for R2 to R6 ORDER
T.S.SIVAGNANAM, J.
The petitioners five in number have filed this writ petition as a public interest litigation to forbear the Director of Fisheries / fifth respondent from establishing Aqua Culture Center, in the land comprised in Survey No. 967, measuring an extent of 86.93.00 Hectares, at Mannavanur Village, Kodaikanal Taluk, Dindigul District.
2. The petitioners are the residents of Kavunji Village, Kodaikanal Taluk, Dindigul District and stated to have been involved in creating public awareness, propagating the various welfare schemes evolved by the Government and also rendering assistance to the villagers whenever required.
3. It is stated that the land in question is a grassland used by the residents of the Village from time immemorial and it provides the ecosystem 3/26 http://www.judis.nic.in W.P.(MD) No.3663 of 2019 with clean water; prevents floods and also serves a grassing ground for cattle. Further, the grassland is an important habitat for several species of flora and fauna, including migratory birds. The area has unique biodiversity with several endemic and rare plants. Through the grassland, Thalavarai river flows, which is the irrigation source of around 2000 Acres of cultivable lands and it is stated to be the only water source to the residents of the village. It is stated that when the entire area is so unique in its biodiversity, the Fisheries Department, without giving importance to the protection of environment and ecosystem, have proposed to establish a massive fish hatchery unit in the grassland at Mannavanur Village.
4. It is further stated that if a fish hatchery or Aqua Culture Center is established in the said grassland, it would result in serious environmental degradation and the waste, which would be generated from the fish points, would result in contamination of the water resource and ultimately, destroy the entire grassland area. Therefore, the petitioners seek for a direction from this Court to forbear the Fisheries Department from establishing the Aqua Culture Centre in the subject land.
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5. Mr.T.Lajapathi Roy, learned counsel appearing for the petitioners, after elaborately describing about how the entire area in and around Mannavanur Village is an ecologically sensitive area, submitted that there is a duty cast upon the Department to protect the grasslands and establishing Aqua Culture Center in the ecologically sensitive area is against the public interest.
6. Referring to the decision of the Honourable Supreme Court, in the case of T.N.Godavarman Thirumulpad vs. Union of India and others (Writ Petition (Civil) No.202 of 1995, it is submitted that the areas, which are having the characteristics of forests and identified as deemed forests, irrespective of the ownership, require permission under the Forest (Conservation) Act, 1980 (in short, “the Act”) for putting them to use for non- forest activities.
7. Further, by referring to the decision of the Honourable Full Bench of this Court in the case of T.K.Shanmugam vs. State of Tamil Nadu, reported in 2015 (6) CTC 369, it is submitted that the Court had deprecated the practice of destruction of water bodies and stressed the importance of protection and preservation of the water bodies. 5/26 http://www.judis.nic.in W.P.(MD) No.3663 of 2019
8. Further, it is submitted that the Honourable Supreme Court, in the case of S.Jagannath vs. Union of India and others, reported in (1997) 2 SCC 87, has pointed out that the agricultural lands, salt pan lands, mangroves, wet lands, forest lands, land for village common purpose and the land meant for public purposes shall not be used / converted for construction of shrimp culture ponds.
9. It is further submitted that in terms of Section 2 of the Act, there is a restriction on the dereservation of forests or use of forest land for non- forest purpose.
10. Referring to the notification issued by the Ministry of Environment, Forests and Climate Change, Government of India, dated 29.01.2018, it is submitted that the Central Government had listed the activities, which constitute violation of provisions of the Act and the Rules made thereunder and issued guidelines for imposition of penalty, where offences are committed by certain agencies. It is pointed out in the said notification that diversion of forest land for non-forestry purposes, without the prior approval of the competent authority in the State, will be dealt with under the provisions of Indian Forest Act, 1927 or State Forest Acts or any other 6/26 http://www.judis.nic.in W.P.(MD) No.3663 of 2019 State Act dealing with such land as the case may be and the land in question will not be considered as diverted under the Act and the status of land shall continue to be forest.
11. Referring to the counter affidavit filed by the sixth respondent, namely, the District Forest Officer, Kodaikanal Wild Life Division, it is submitted that the Tamil Nadu Forest Department, as early as in the year 2012, had submitted a proposal to the District Collector, Dindigul / fourth respondent, proposing to declare the land in Mannavanur Village in Survey No.967, measuring an extent of 86.93 Hectares, as a forest, under Section 26 of the Tamil Nadu Forest Act, 1882 and the proposal is under consideration of the District Administration. Therefore, it is submitted that the appropriate Authority, namely, the Forest Department themselves has proposed to declare the area as forest and the proposal is pending before the District Collector, Dindigul, since 2012 and at this juncture, if the subject land is to be used for establishing of Aqua Culture Center, it will not only be an impediment for declaring the subject land as forest and after declaration, the said activity will be a non-forest activity. Therefore, it is submitted that the Court may consider the case of the petitioners and issue appropriate directions so that the Aqua Culture Center is not established in the land in question. 7/26 http://www.judis.nic.in W.P.(MD) No.3663 of 2019
12. Mr.A.K.Baskarapandian, learned Special Government Pleader appearing for the respondents 2 to 6, stressed the need for establishment of the Fish Seed Farm at Kodaikanal, because of other Fish Seed Farms are only seasonal, since appropriate whether condition is required for healthy rearing of the fish seedling and after much deliberation and after following the necessary procedures, the present site at Mannavanur Village has been identified by a team of officers of the Fisheries Department and the District Collector, Dindigul, by his proceedings dated 08.10.2018, ordered for exchange of land to an extent of 1.22.50 Hectares in Survey No.967, in favour of the Fisheries Department. It is submitted that the apprehension of the petitioners that the construction of Fish Farming Center will result in environmental degradation is ill founded and without any basis.
13. Further, by referring to the counter affidavit, it is submitted that in Tamil Nadu, the fish seed production of Indian major carps (south west monsoon) does not coincide with the seed requirement season (north east monsoon), when the water bodies get filled-up and this miss match hinders the stocking of fish seed in all the available water bodies. Further, it is submitted that the availability of common carp fingerlings is also very limited 8/26 http://www.judis.nic.in W.P.(MD) No.3663 of 2019 due to the constraints in the availability of breeder rearing space in most of the major fish seed production centers in Tamil Nadu. As a result of which, the common carp seeds are imported in large quantities by the private fish seed suppliers from Andhra Pradesh and West Bengal to meet out the demand. The costs of imported seeds are very high and the quality is poor due to transport stress. It is, therefore, submitted that the availability of the land and climate in Kodaikanal is suitable for common carp breeding and rearing in mass quantities to meet out the fish seed demand of Dindigul District as well as to the State of Tamil Nadu and that is why a modern common carp breeding and rearing center at Kodaikanal is proposed.
14. It is further submitted that out of 1.22 Hectares of land allotted to the Fisheries Department, construction would be made only in 3500 sq.meters of land and in the remaining vacant site, it was proposed to plant trees and herbal plants. It is further submitted that the water for the tanks will be supplied through the borewell and no chemical will be used and there will be no disturbance to the flora and fauna and the water consumption will not be excessive and therefore, the proposed activity will not deplete any water source.
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15. During the course of hearing, Mr.M.Kasinatha Pandian, Deputy Director of Fisheries, Madurai, was present and he also shared his views with the Court to state that the proposed activity will not cause any harm to the environment.
16. We have also heard Mr.B.Rajesh Saravanan, learned Senior Standing Counsel for the first respondent.
17. The land in question is situated in Mannavanur Village, in Kodaikanal Hills. The classification of the subject land, in the revenue records as on the date, is Government poramboku land and it is under the control of the Revenue Department. The District Collector, Dindigul, is the Head of the Revenue Department. Admittedly, the land is in close vicinity to forest land. This is clear, because the District Forest Officer and Wildlife Warden, Kodaikanal, in his counter affidavit, has stated that the Tamil Nadu Forest Department, as early as in the year 2012, has sent a proposal to the District Collector, Dindigul, requesting to notify the land in question as forest land. It is not clear as to why such a proposal has not been considered till date. The respondents may be right in stating that as on date, the land continues to be Government poramboku land. If such is the classification of the land, can it 10/26 http://www.judis.nic.in W.P.(MD) No.3663 of 2019 be said that the Fisheries Department would be entitled as a matter of right to establish their fish seedling farm in the subject land.
18. The Department of Fisheries seeks to sustain the proposed project by contending that there is a huge shortage of good quality fish seeds and this demand has not been able to be met by the Government, as a result of which, private pliers and middlemen can have a field day. Further, the Fisheries Department justified their stand to locate the said project in the land in question as the climate condition is most suited for rearing exotic carp and also justified their stand stating that there will be no environmental degradation, only an extent of 3500 sq.meters of the land allotted to them will be used for construction of tanks, no chemical will be used and the water requirement will be made by drawing water from the borewells and the project is not wider intensive and therefore, it will not deplete any water resources.
19. The Honourable Supreme Court in the case of Vellore Citizens' Welfare Forum vs. Union of India, reported in (1996) 5 SCC 647, dealt with about the concept of “sustainable development” and pointed out that the sustainable development, as a balancing concept between ecology and development, has been accepted as a part of the customary international law 11/26 http://www.judis.nic.in W.P.(MD) No.3663 of 2019 though its salient features have yet to be finalised by the international law jurists. Further, it was pointed that the precautionary principle and the polluter pays principle are essential features of sustainable development. Precautionary principle, in the context of the Municipal Law, was explained in the following terms:
“(i) Environment measures - by the State Government and the statutory Authorities must anticipate, prevent' and attack the causes of environmental degradation.
(ii) Where there are threats of serious and irreversible damage lack of scientific certainly should not be used as the reason for postponing, measures to prevent environmental depredation.
(iii)The "Onus of proof" is on the actor or the developer/industrial to show that his action is environmentally benign.”
20. The polluter pays principle was explained by referring to the decision in the case of Indian Council for Enviro-Legal Action vs. Union of India, reported in (1996) 3 SCC 212, wherein, it was pointed that once the activity carried on is hazardous or inherently dangerous, the person carrying on such activity is liable to make good the loss caused to any other person by his activity irrespective of the fact whether he took reasonable care while 12/26 http://www.judis.nic.in W.P.(MD) No.3663 of 2019 carrying on his activity. Further, it was pointed out that the precautionary principle and the polluter pays principle have been accepted as a part of the law of land. After referring to Articles 47, 48-A and 51-A(g) of the Constitution of India, it was held that apart from the constitutional mandate to protect and improve the environment, there are plenty of post-independence legislations on the subject, but more relevant enactments for the purpose are the Water (Prevention and Control of Pollution) Act, 1974, the Air (Prevention and Control of Pollution Act, 1981 and the Environment Protection Act, 1986. After discussing about these three enactments, the Court held that in the light of the constitutional and statutory provisions, the precautionary principle and the polluter pays principle are part of the environment law of the country.
21. The learned counsel appearing for the petitioners referred to the decision in the case of S.Jagannath (supra), which pertains to shrimp (prawn) culture industry in India and submitted that the observations and directions issued by the Honourable Supreme Court in the said decision by implementing the precautionary principle would be relevant for the instant case. Though the said decision was mainly pertained to shrimp culture industry, yet the Honourable Supreme Court has also considered the impact of aquaculture industries as they have the effect of causing salinity of soil or 13/26 http://www.judis.nic.in W.P.(MD) No.3663 of 2019 drinking water or wells by use of chemical feeds to increase shrimp or prawn production with consequent increase in sedimentation, which on putrefaction, is a potential health hazard, apart from causing siltation, turbidity of water courses and estuaries with detrimental implication on local fauna and flora and hence, they shall not be allowed by the authority constituted under the Coastal Regulation Zone.
22. Bearing the observations made by the Honourable Supreme Court in the aforementioned decision, we need to tread on careful lines to consider as to whether the Fisheries Department should be permitted to go ahead with the proposed project or not.
23. The proposal made by the Tamil Nadu Forest Department in the year 2012 to declare the area as a forest land is of significance importance. The Tamil Nadu Forest Department is the guardian of the forests in the State. In other words, they are the Trustees, who are constituted to protect the forests and forest areas. This Department took a conscious step during 2012 and made a proposal to the Government to declare the area as a forest land. Since the subject land falls within the control of the District Collector of Dindigul, the proposal obviously had to be routed through the District 14/26 http://www.judis.nic.in W.P.(MD) No.3663 of 2019 Collector, since the classification of the subject land in the revenue records is Government poramboke land. It is the Government, which is the ultimate authority to issue notification declaring a land as forest land. However, the proposal has been kept in cold storage. Even if it is so, it does not mean that the proposal is not feasible of consideration, because the endeavour of the State Government as well as the Government of India is to increase the forest cover in the State and in the country. Therefore, in our considered view, it will be an unreasonable stand on the part of the revenue administration or the Department of Fisheries to take a stand that as on date, the land is a Government poramboke land and therefore, the proposed project should be permitted. This thought process of the respondents clearly falls foul of the precautionary principle. This also will fall foul of the principle of sustainable development. In other words, merely because the proposal has not been considered, that would not be a ground to justify the sanction of the project in the area. This Court can take judicial notice of the fact that the entire Kodaikanal and Palani Hills area have been indiscriminately exploited by several individuals and corporates under the guise of promoting tourism. The local administration of Kodaikanal Hills closed their eyes for several years; unauthorized construction became rampant; multi-storeyed buildings were put up and to cater to the needs of those buildings, hotels etc., deep borewells 15/26 http://www.judis.nic.in W.P.(MD) No.3663 of 2019 were established, resulting in indiscriminate drawal of ground water. On account of these thoughtless development, the impact on the environment in the area was huge and action was initiated by the authorities only after this Court stepped in by issuing directions in public interest litigations. Several buildings have been locked and sealed and those violators are now before the Government by way of appeals, which have been dealt with by the Government. Therefore, in our view, time has come to take a firm stand on these issues and a stage has also been formed where it would be unsafe to leave the decision to certain wings of the Government. This is precisely the reason why the Courts have stepped in and issued directions preventing indiscriminate mining of river sand and other minor and major minerals in the State.
24. It is not clear as to whether the District Collector, while transferring the subject land to the Fisheries Department, vide proceedings dated 08.10.2018, had considered the far-reaching consequence, which may be caused, if a fish farm is established in a hill terrain, which is already ecologically very sensitive. We presume that the said proceedings would have been issued as any other administrative approval where transfer of lands takes place between two Departments. Grasslands are generally a flat terrain 16/26 http://www.judis.nic.in W.P.(MD) No.3663 of 2019 and to the naked eye, it will appear to be a land, which can be put to use for any purpose. However, many a times, what has lost sight of is the benefits of these grasslands as they serve as a filtration bed and help for recharging the ground water. Thus, merely because the lands are flat and large tracts are available, that does not mean that the lands do not contribute anything to environment.
25. The Planning Commission (Environment and Forests Division), vide letter number M-13033/1/2006-E&F, dated 21 August, 2006 constituted a Task Force on Grasslands and Deserts for the Environment and Forests Sector for the Eleventh Five-Year Plan (2007-2012). The Terms of References of the Task Force were as follows:
“1. Review the current laws, policies, procedures and practices related to conservation and sustainable use of grasslands and desert ecosystems and recommend correctives.
2. Similarly review the institutional and individual capacities available to address issues related to conservation and sustainable use of grassland and desert ecosystems and recommend how they may be adequately strengthened.
3. Assess the current issues and systems of integrating concerns relating to fragile grassland 17/26 http://www.judis.nic.in W.P.(MD) No.3663 of 2019 and desert ecosystems into other sectors (ministries, departments) and to recommend required new or remedial measures.
4. Review the current EIA laws, policies, procedures and practices as being applied in the grasslands and desert ecosystem context and recommend corrective measure to address significant issues that specifically arise in the context of these fragile ecosystems.”
26. The Report of the Task Force on Grasslands and Deserts would throw much light on grasslands. It has been stated that unique type of grassland type is the Shola grassland of the Western Ghats. This type is generally over looked or clumped with other grassland type. However, Shola grasslands are unique as they are confined to the high altitude in the Western Ghats and interspersed with tropical forests (generally found in the mountain folds and valleys). Shola grasslands are maintained by fire and frost and appear to be climax vegetation as an ancient and geographic relict species of ungulate (Niligir Tahr) is found in the shola grasslands and no where else in the world.
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27. Speaking about the grasses, it was observed that the grasses are considered to be the most evolved species of plants. They are efficient in absorbing rain water and play vital role in water retention and hydrology of an area.
28. Speaking about Grassland Protection, the report observed that grasslands are not managed by the Forest Department whose interest lies mainly in trees, not by the agriculture department who are interested in agriculture crops, nor the veterinary department who are concerned with livestock, but not the grass on which the livestock is dependent. It is further reported that the grasslands are the ‘common’ lands of the community and are the responsibility of none. They are the most productive ecosystems in the subcontinent, but they belong to all, are controlled by none, and they have no godfathers. The report further says that some of the rarest species of wildlife are found in the grasslands, many of them totally dependent on them.
29. Speaking about Legal Protection of grasslands, the report observed that the grasslands are the most neglected, abused and least protected ecosystems in India. They remain unprotected unless they are 19/26 http://www.judis.nic.in W.P.(MD) No.3663 of 2019 notified as Protected Areas under the Wild Life (Protection) Act, 1972 or notified as Protected or Reserve Forest under the Indian Forest Act, 1927.
30. Further, the Report further observed that most of the States in India have excluded the grasslands and have not identified them as “deemed forest” by the State Expert Committee’s pursuant to the landmark order dated 12.12.1996 in T.N.Godavarman Thriumalpad (supra). It is pointed out that in terms of the order passed by the Hon'ble Supreme Court the word ‘forest’ should be given a wide and liberal interpretation. Excluding grasslands and including lands only with tree cover as ‘forest’ is against the letter and spirit of the said order thereby denying the protection under the Forest (Conservation) Act, 1980 (F. C. Act). Further, it has been pointed out that the grasslands have spontaneous natural vegetative growth, these should also be treated as ‘forest land’ for the purposes of the Forest Conservation Act and restrictions on diversion of such lands for non-forest use should be applicable to these critical ecosystems as well. Further, the Report recommends that the Central Government should invoke the provisions of the Articles 251 and 254 of the Constitution to direct state governments to instruct Revenue Departments not to divert any grassland identified in the landscape for bustard/florican protection.
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31. In their recommendations, the Task Force states that certain grasslands (including grasslands in Tamilnadu) should be recognized as ecologically sensitive ecosystems and any development projects in these areas will have to undergo stringent environmental impact assessments. Further, the Task Force recommends framing of a National Grazing Policy and in the said recommendation, the Report states that in our country, only livestock is considered as wealth, not the grasslands on which this livestock depends nor the traditional knowledge that helps maintain this livestock! Interestingly, protection of fodder producing, natural grasslands greatly help in the protection of many endangered species. The Report recommends modifications to the EIA guidelines by including ecologically fragile and environmentally sensitive areas where prior EIAs will have to be made mandatory. Also, presence of representatives from identified institutions and experts should be made mandatory during public hearing whenever an EIA is done in the grassland and desert ecosystems so as to review the identified impacts, prediction and mitigation. The Report recommends to the Ministry of Environment and Forest (MoEF), Government of India to start a Division or Section to look after the grassland issues. The Report of the Task Force on Grasslands and Deserts, Government of India, Planning Commission is an 21/26 http://www.judis.nic.in W.P.(MD) No.3663 of 2019 eyeopener and the State has to change its though process and the Report of the Task Force cannot be disregarded as merely a report. Many a times, the Reports of such expert bodies have ultimately crystallized into legislation. Therefore, the State of Tamilnadu can lead the country in evolving policies to preserve the grassland rather than to take a technical stand based on the revenue classification of the land in question.
32. Rearing of fish in an ecologically sensitive area, more particularly, in a land, which was proposed to be declared as a forest land, should be termed as a non-forest activity. For the purpose of enforcement of the provisions of the Act or the Tamil Nadu State Forest Act, boundaries and perimeters of forest area would be relevant to decide as to whether any violation has been committed or not. But, the same yardstick cannot be applied to the lands adjoining forest, which one day will come to be included within the forest area. Therefore, it is essential that these areas are also protected.
33. We do not seriously doubt the stand taken by the Fisheries Department that they will not use any chemicals while rearing fish seeds. Nevertheless, rearing of fish seeds requires water and feed, which may be 22/26 http://www.judis.nic.in W.P.(MD) No.3663 of 2019 organic, but, definitely can have an impact if the water is drained to the nearby areas. But, the Fisheries Department states that they will draw water from borewells. Therefore, they propose to extract ground water, which is already in depleted stage in Kodaikanal Hills. The only reason, which appears to have assumed predominant to locate the fish farm in the subject land, is climatic condition. In our considered view, this cannot be the sole reason as we are required to balance environment and industry. Technology has developed where temperature controlled environment is being created to rear rare varieties of plants and herbs and they have also been done on large scale basis. Therefore, merely because Kodaikanal Hills has a cool climate, it cannot be a justification to state that fish seed farm should be located in the land in question. Therefore, we are of the clear view that the project as proposed by the Fisheries Department has to be necessarily shelved.
34. That apart, as we have observed that the proceedings of the District Collector, dated 08.10.2018, transferring a portion of the land to the Fisheries Department having been done without examining the far-reaching consequence, has to be necessarily held to be unsustainable and we are inclined to set aside the same.
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35. For all the above reasons, the writ petition is allowed and the respondents are permanently restrained from establishing fish seed farm in the land, comprised in Survey No.967, measuring 86.93.00 Hectares, at Mannavanur Village, Kodaikanal Taluk, Dindigul District and consequently, the proceedings of the District Collector, Dindigul / fourth respondent, in R.O.C.No.19793/2018/D4, dated 08.10.2018, are set aside and the subject land shall be restored to the Revenue Department and if any mutation has been done in the revenue records reflecting the name of the Department of Fisheries, the same shall be cancelled and the original revenue entry be restored. No costs. Consequently, connected miscellaneous petition is closed.
[T.S.S.,J.] [R.T.,J.] 18.11.2019 Index : Yes / No Internet : Yes / No krk / sj 24/26 http://www.judis.nic.in W.P.(MD) No.3663 of 2019 To: 1.The Secretary, Ministry of Environment and Forest, Union of India, Indiara Paryavaran Bhavan, Jorbagh Road, New Delhi-110 003. 2.The Secretary to the Government, Department of Animal Husbandry and Fisheries Department, Government of Tamil Nadu, Fort St.George, Chennai-600 009. 3.The Principal Chief Conservator of Forest, Tamil Nadu Forest Department, Panagal Maligai, Saidapet, Chennai. 4.The District Collector, Dindigul District, Dindigul. 5.The Director of Fisheries, Department of Fisheries, Sivasankaran Road, Chokkalingam Nagar, Teynampet, Chennai-6. 6.The District Forest Officer, Kodaikanal Wild Life Division, Dindigul District. 25/26 http://www.judis.nic.in W.P.(MD) No.3663 of 2019 T.S.SIVAGNANAM, J. and R.THARANI, J. krk / sj ORDER IN W.P.(MD) No.3663 of 2019 and W.M.P.(MD) No.2865 of 2019 18.11.2019 26/26 http://www.judis.nic.in