Public Trust Doctrine in Environmental Law – Meaning, Origin and MC Mehta v Kamal Nath Case Explained

Introduction:-

Environmental protection has become one of the most crucial legal issues in modern constitutional jurisprudence. One of the strongest doctrines used by courts to protect natural resources is the Public Trust Doctrine. This principle ensures that essential natural resources are preserved for public use and cannot be transferred for private or commercial exploitation. This article is especially useful for Law students, Judiciary aspirants, UPSC candidates, law exams and general public.

What is Public Trust Doctrine?

Public Trust Doctrine recognized in the ancient Roman Empire. The Public Trust Principle of The public trust doctrine regarding environmental protection was Environmental Protection was based on the belief that natural resources such as rivers, beaches, forests and air are held as a trust by the government. Rivers, forests, beaches and pure air should be held in the form of trust by the government for the unconditional and free use of common people. The government is the trustee of this trust and the general public is the beneficiary of this trust. Our emotional concern about the environment is related to the Public Trust principle. According to Roman law, these natural resources are held by an individual or by the common man as common property. According to English common law, the emperor is the owner of these natural resources, but their ownership is vested in nature. No one should be allowed to use these sources for personal entertainment such as boating or fishing. Prof. Joseph L. Sax is considered an exponent of the modern public trust theory.

Public Trust Doctrine in Indian Jurisprudence

In the matter of Association for Environment Protection v. State of Kerala (A.I.R. 2013 S.C. 2500) it was held by the Supreme Court that the principle of public trust was developed by the Roman rulers. It was also said by the Supreme Court that - air, sea, water, forest etc. are some common property which is very important for human life. The government is the trustee of the properties. It is the duty of the government to protect these properties.

Public Trust Doctrine and Article 21 of the Indian Constitution

The Supreme Court has consistently held that the Public Trust Doctrine flows from Article 21 of the Constitution of India, as the right to life includes the right to a clean, healthy, and pollution-free environment. Protection of natural resources like air, water, rivers, and forests is therefore a constitutional obligation of the State. It is the duty of the government to protect these properties.

What is the Scope of Public Trust Principle?

The summary of the public trust principle is that the air, sea, rivers, natural springs, water and forests are so important to the general public that it is completely inappropriate to make them the subject matter of private entertainment. Air, water and forests are such a gift given by nature to humanity that they should be made freely available to the common man. According to the Public Trust principle, the above natural gifts should be protected by the government in the public interest and their personal and commercial use should be restricted.

According to Professor Joseph L. Sax, the Public Trust is under this principle. These sources reserved for public use should not be converted into private ownership.

Which Case Established Public Trust Doctrine in India?

The principle of public trust in India was recognized by the Supreme Court in the case of MC Mehta v. Kamal Nath [(2000) 6 S.C.C. 213]. This dispute is also known as the span motel case. The main facts of this case were as follows -

According to news published in the Indian Express, a private company, Span Motel Private Limited, with which the family of former Environment Minister Kamal Nath had direct links, had built the club on the banks of the Beas River between Kullu and Manali in Himachal Pradesh. At the time of the construction of the club, this Span Motel Private Limited had occupied most of the forest land, then Kamal Nath was the Union Environment Minister. This illegal occupation of forest land was regularized in 1993-94 by giving lease by the government. Machines like bulldozers were used to change the course of the river. According to the news, the river's current was changed to save the motel from future floods. Supreme Court took cognizance of this news.

Justice Kuldeep Singh of the Supreme Court delivered the Judgment of this suit on 13 December 1996, two weeks before his retirement. Justice Kuldeep Singh applied the principle of public trust propounded in the decision of the Supreme Court of California in the American Mono Lake case, on the facts of this case, saying that the principle of public trust propounded in respect of natural sources is applicable in India also. According to the theory, natural sources like air, water, beaches, rivers and forests are important and valuable gifts given by nature to to the common man. This natural resource is a public trust. The government is its trustee and the general public is the beneficiary of this trust. If the Government transfers these properties to a private person for personal gain and use, such as boating, fishing, it will be said that the Government has not performed the duties of its trustees and the general public holds the right to seek remedies against it. The general public has the right to hope that the natural features of those natural sources will be retained.

Justice Kuldeep Singh said that the principle of public trust was adopted in the Roman Empire, this principle has been recognized in the jurisprudence of America and Britain. So there is no reason why this principle should not be accepted in Indian jurisprudence.

Case Summary Box (Exam-Oriented)

Case Name: MC Mehta v. Kamal Nath
Citation: (2000) 6 SCC 213
Popular Name: Span Motel Case
Principle Applied: Public Trust Doctrine
Court: Supreme Court of India
Significance: Natural resources cannot be transferred for private use; government is trustee of environment.

Exam Tip:
MC Mehta v. Kamal Nath (2000) is the leading and most frequently asked case on the Public Trust Doctrine in India in Judiciary, UPSC, and Law examinations.

Supreme Court Directions in Span Motel Case

The Supreme Court propounded the following principles -

The public trust principle discussed in this judgment is a part of Indian jurisprudence and Indian law.
The lease granted to Span Motel Pvt Ltd is hereby cancelled.
Government of Himachal Pradesh to restore the land to its original natural form.
The cost of restoring the environment and ecology of this area will be borne by the Span Motel.
The cost of bringing the status, quo by removing the construction done by the motel on the Beas river bank will be borne by the motel.
Motel Management should give reasons why he should not be prosecuted for this act.

Public Trust Doctrine in Simple Words (For Beginners)

Public Trust Doctrine means that nature does not belong to the government or private companies. The government only manages natural resources on behalf of the public. Rivers, forests, air, and water must be protected for public use and future generations.

Frequently Asked Questions (FAQ)

1. What is Public Trust Doctrine in Environmental Law?

It is a legal principle which states that natural resources are held by the government as a trustee for public use and cannot be privatized.

2. Which case recognized Public Trust Doctrine in India?

The doctrine was clearly recognized in MC Mehta v. Kamal Nath (2000) by the Supreme Court.

3. Is Public Trust Doctrine part of Article 21?

Yes. The Supreme Court has linked it with the Right to Life under Article 21, which includes the right to a clean and healthy environment.

4. Who is the father of modern Public Trust Theory?

Professor Joseph L. Sax is considered the exponent of the modern Public Trust Theory.

5. Why is Span Motel case important?

It established that the government cannot lease or regularize natural resources for private benefit.

Conclusion

The Public Trust Doctrine is one of the strongest tools available for environmental protection in India. It imposes a legal duty on the State to protect natural resources and prevents their misuse for private or commercial gains. Therefore, the Public Trust Doctrine under environmental law acts as a constitutional limitation on the State while dealing with natural resources. This doctrine plays a crucial role in balancing development with environmental protection.

Monday, January 19, 2026