—Sanya Darakhshan Kishwar, Assistant Professor of Law, Jindal Global Law School, O.P. Jindal Global University, India, and Arham Nahar, BBA LL.B. (Hons.) student, Jindal Global Law School, O.P. Jindal Global University, India
Introduction
Stretching over 670 kilometres from Gujarat to Delhi, the Aravalli Range is among the oldest mountain systems on the planet, predating even the Himalayas. For decades, the Aravallis have been treated less as an ecological system but more as a cache of exploitable land – mined, built over, and reshaped through regulatory permissions that prioritised economic use over environmental function. The Aravalli Hills have not declined merely through blatant violations of law, but through quiet acts of reclassification – through decisions about what qualifies as a hill, what is deemed “revenue land,” and what may therefore be mined, flattened, or sold. As the urban frontiers of Gurugram and Faridabad expanded outward, the Aravallis were simultaneously compressed inward, not by physical erasure but by administrative redefinition. Scientific research has long demonstrated that fragmentation of even low-lying ridge systems weakens groundwater recharge and ecological stability across the National Capital Region, yet these warnings were routinely overridden by land records designed for profiteering rather than ecology. This practice displays how seemingly neutral administrative classifications can undermine ecological integrity and while doing so, compromise the constitutional safeguard of environmental rights implicit in Article 21.
The Aravalli Judgement
In its judgment dated 20 November 2025, the Indian Supreme Court adopted a uniform elevation-based definition of the Aravalli Hills: only landforms rising 100 metres or more above local relief, along with their slopes and adjacent land, qualify as part of the range. Clusters within 500 metres form an “Aravalli Range.” This geomorphological test emphasizes the continuity of ridges, slopes, and rocky formations. Critics, however, argue that it ignores the ecological connectivity of lower scrub hills that historically formed part of the Aravalli system.
The Indian Court invoked established constitutional environmental doctrines such as the Precautionary Principle, Inter-Generational Equity, and the Constitution’s Article 21’s guarantee of life with dignity to justify a moratorium on new mining leases until a scientific management plan for sustainable mining is prepared. These principles, rooted in earlier jurisprudence, e.g., Vellore Citizens Welfare Forum, require balancing development with ecological preservation for the benefit of future generations.
The judgment relied on technical studies from the Survey of India, Forest Survey of India (FSI), and Indian Institute of Technology Delhi, which mapped the range and assessed its role as a “green barrier” against desertification, a groundwater recharge zone, and a pollution sink. FSI data revealed that under the 100-metre criterion, only 8.7 per cent of 12,081 mapped hills remain protected, raising concerns about fragmentation and loss of ecological services.
Significantly, the Court rejected state-level attempts to regularise encroachments and dilute conservation zones, reiterating that Aravalli protection is a matter of national ecological security. It directed scientific mapping and prohibited any new mining until compliance with sustainable norms, underscoring that short-term economic gains cannot override long-term environmental rights under Article 21 of the Indian Constitution.
Why the Definitions Were Contested: Ecological Reality and the Limits of Revenue Classifications
The conflict over what constitutes the “Aravalli Hills and Ranges” did not arise organically. It was produced through a persistent gap between ecological reality and administrative categorisation. For decades, the Indian States of Haryana and Rajasthan relied on revenue labels – “gair mumkin pahar, gair mumkin raa’, or banjar land” – to determine whether a rocky ridge counted as a hill or merely as unproductive revenue land. These classifications were never intended to track geomorphological continuity or ecological function; they were instruments of land management and taxation.
This mode of regulatory dilution stands in clear tension with the Indian Supreme Court’s own environmental jurisprudence. In T.N. Godavarman Thirumulpad v. Union of India, the Court decisively rejected the idea that ecological protection could hinge on administrative labels, holding that the term “forest” must be understood according to its ecological characteristics rather than its description in government records. By severing the link between revenue categorisation and environmental identity, Godavarman established a foundational principle: nature cannot be governed through paperwork alone. Earlier orders in the M.C. Mehta series – particularly those addressing mining in the Aravalli region – echoed this concern by recognising the range’s ecological fragility, even as they struggled with the absence of a uniform definition that Indian States continued to exploit.
It was this unresolved definitional vacuum that the Indian Supreme Court finally confronted in May 2024 in the M.C. Mehta line of cases. The Court acknowledged that vagueness over the scope of the Aravalli Hills and Ranges had repeatedly stalled enforcement of mining restrictions and conservation protocols within the area. It subsequently accepted the recommendations of an expert committee and adopted a scientific, geomorphological basis for identification of areas and landforms constituting Aravalli Hills and Ranges , decisively moving away from state-specific revenue classifications that had enabled regulatory dilution. That 2024 ruling, however, generated significant contestation from State governments and affected stakeholders, particularly over its scope and implementation. This, in turn, prompted the Court in late 2025 to revisit the issue, clarify the application of its definition, address concerns relating to mapping and enforcement, and reaffirm a principle first articulated in Godavarman: ecological identity cannot be altered through administrative labelling.
Implications: Ecological, Legal and Planning
The most immediate ecological significance of the Supreme Court’s intervention lies not in the protection of individual hills, but in its recognition of the Aravallis as a connected landscape system. By shifting the focus from discrete elevations to geomorphological continuity, the ruling compels regulators to assess cumulative ecological impacts rather than treating degradation as a series of isolated, permissible acts. This has relevance for groundwater governance in the National Capital Region (NCR)- the metropolitan multi state planning area centred on Delhi, where aquifer recharge depends on networks of low-lying ridges that have historically been dismissed as expendable “rocky land.” The judgment thus recalibrates the ecological baseline against which future interventions – roads, townships, mining leases – will be evaluated.
The ruling solidifies an important standard in Indian environmental adjudication: where ecological characteristics are scientifically ascertainable, state discretion in land classification cannot override them. By treating geomorphological evidence as determinative, the Indian Court restricts the long-standing practice of States justifying environmentally harmful activity through revenue descriptions alone. This materially strengthens the environmental rule of law by converting scientific assessment from a persuasive input into a binding reference point in regulatory decision-making. At the same time, the Court’s reliance on expert committees reflects not judicial ambition but an administrative deficit. This institutional vacuum reflects the absence of statutory frameworks for uniform ecological mapping and the marginalisation of scientific evidence into routine ordinance. judicial mediation of scientific evidence emerges less as an instance of overreach and more as a response to an institutional vacuum
The planning implications are likely to be both immediate and contested. The NCR Regional Plan 2041, which already acknowledges the Aravallis as an ecological constraint, will now have to contend with a judicially endorsed scientific definition that may cut across existing zoning categories. This may necessitate revisions to master plans and development permissions across Gurugram, Faridabad, and adjoining regions, particularly where projects were premised on narrow revenue classifications. Expanded identification of Aravalli landscapes may also influence future delineation of Eco-Sensitive Zones, intensifying scrutiny over construction and mining in peripheral areas. Finally, the ruling is likely to recalibrate Centre-State relations in land governance by constraining a key site of discretionary power – one closely tied to revenue generation and political patronage, raising questions about compliance and resistance at the implementation stage.
Critiques and Gaps
Despite its ecological intent, the Indian Supreme Court’s ruling faces serious implementation challenges, risking what experts term “paper ecology” i.e., legal protection that exists only on maps while enforcement collapses on the ground. Weak institutional capacity, fragmented governance, and lack of trained personnel for GIS-based mapping make compliance uncertain.
The judgment has also reignited the judicial overreach debate, as the Court prescribed a technical geomorphological criterion without legislative backing. Critics argue that such elevation-based definitions bypass democratic processes and may strain federal-State relations, especially where land-use decisions intersect with State autonomy.
A deeper structural gap lies in the absence of statutory geomorphological standards. Currently, the 100-metre elevation rule rests on judicial directions rather than codified law, leaving it vulnerable to contestation. Experts and political leaders have called for urgent legislative action to integrate scientific criteria into environmental statutes.
Finally, institutional capacity remains a bottleneck. State agencies lack resources for continuous monitoring, inter-agency coordination, and enforcement of mining bans. Reliance on ad hoc committees or judicial oversight cannot substitute for robust statutory frameworks and empowered bodies like the Forest Survey of India.
Without systemic reforms, statutory clarity, scientific standards, and institutional strengthening, the ruling risks remaining symbolic rather than transformative.
Conclusion
The Indian Supreme Court’s Aravalli judgment serves as a pivot toward ecologically truthful governance, reaffirming that environmental protection is integral to constitutional values under Article 21 of the Indian Constitution. By introducing a scientific criterion for defining the range and invoking doctrines like the Precautionary Principle and Inter-Generational Equity, the Court has set a strong normative foundation. However, the future of this ruling depends on legislative follow-through codifying geomorphological standards and robust inter-state compliance to prevent dilution through local exceptions. Without statutory clarity and institutional capacity, the judgment risks remaining aspirational. If implemented effectively, it could transform fragmented conservation efforts into a coherent ecological security regime for one of India’s oldest mountain systems.
Suggested citation: Sanya Darakhshan Kishwar and Arham Nahar, Ecology by Classification: The Aravalli Judgment and the Limits of Administrative Labels, Int’l J. Const. L. Blog, Jan. 7, 2026, at: http://www.iconnectblog.com/ecology-by-classification-the-aravalli-judgment-and-the-limits-of-administrative-labels/