Legal Drafting

How to Draft an Original Application Before the National Green Tribunal (NGT)

Author: Jeet Sinha

Introduction

The National Green Tribunal (NGT) is a specialised judicial forum established under the National Green Tribunal Act, 2010 for the effective and expeditious disposal of cases relating to environmental protection, conservation of forests and other natural resources, and enforcement of legal rights relating to the environment.

A person seeking relief before the NGT must present the case in the prescribed manner and establish the Tribunal’s jurisdiction, the environmental dispute involved, the cause of action, maintainability and the relief sought.

This article explains how to draft an Original Application before the NGT, including its basic structure, important pleadings, grounds and prayer.

Important: This article is verified and contains exact content for drafting an Original Application(OA). It has been cross-checked by an advocate who practices NGT Matters. However, sole reliance on this article is cautioned; any person trying to file an OA must consult an advocate specialised in NGT matters. Read NGT Act, 2010 and NGT Practice and Procedure Rules for more guidance. At the bottom of this article, a downloadable Word document and a video are attached that will help in better understanding.

1. What is an Original Application before the NGT?

An Original Application is one of the principal proceedings through which a person can approach the NGT in matters falling within its statutory jurisdiction.

Section 14 of the NGT Act deals with the Tribunal’s jurisdiction over civil cases involving a substantial question relating to the environment, including enforcement of legal rights relating to the environment.

Section 15 empowers the Tribunal to grant certain reliefs, including:

  • relief and compensation to victims of pollution and environmental damage;
  • restitution of property damaged; and
  • restitution of the environment.

Section 18 deals with the persons who may apply to the Tribunal and the manner of making such applications.

Therefore, depending upon the facts, an Original Application may seek directions for environmental compliance, restoration of the environment, prevention of pollution, compensation and other appropriate reliefs.

2. Basic Structure of an NGT Original Application

A properly prepared NGT application will ordinarily contain the following components:

  1. Index
  2. Synopsis
  3. List of Dates
  4. Memo of Parties
  5. Original Application
  6. Grounds
  7. Prayer
  8. Interim Relief, wherever required
  9. Affidavit
  10. Verification
  11. Vakalatnama/Authorisation, wherever applicable
  12. Annexures
  13. Other documents required under the applicable procedural requirements

3. Cause Title

The application begins with the name of the Tribunal and the concerned Bench.

Sample Format

BEFORE THE NATIONAL GREEN TRIBUNAL
EASTERN ZONAL BENCH, KOLKATA, WEST BENGAL

(Under Section 18(1) read with Sections 14 and 15 of the National Green Tribunal Act, 2010)

Original Application No. ____ of 2026

IN THE MATTER OF:

XYZ
[Full particulars of the Applicant]
…Applicant

VERSUS

ABC
[Full particulars of Respondent No. 1]

DEF
[Full particulars of Respondent No. 2]

…Respondents

The cause title should correctly identify:

  • the applicant;
  • all necessary respondents;
  • their addresses; and
  • the statutory provisions under which the application is being filed.

4. Index

The index enables the Tribunal and registry to identify the documents forming part of the application.

A basic index may contain:

Sl. No.ParticularsAnnexurePage No.
1.Original Application
2.Affidavit
3.Verification
4.Vakalatnama/Authorisation
5.Relevant DocumentsAnnexure A-1 onwards

The annexures should be arranged sequentially and referred to properly in the body of the application.

5. Synopsis

The synopsis provides the Tribunal with a short overview of the dispute.

It should answer:

  • What is the environmental issue?
  • Who is responsible?
  • What environmental law or condition is allegedly violated?
  • What steps has the applicant already taken?
  • What action has been taken by the authorities?
  • Why is the NGT being approached?
  • What relief is sought?

Drafting Tip

Do not turn the synopsis into the entire petition. It should provide the Tribunal with a quick understanding of the dispute.

Sample Opening

SYNOPSIS

The present Original Application is being filed under Sections 14, 15 and 18 of the National Green Tribunal Act, 2010 by the Applicant seeking appropriate directions for enforcement of applicable environmental laws and conditions imposed upon the Respondent in relation to [briefly describe the project/activity].

The Respondent is engaged in [describe activity], which is alleged to have resulted in [briefly describe environmental impact]. Despite repeated representations and complaints made before the concerned authorities, effective remedial action has not been taken.

The Applicant submits that the alleged violations have resulted in continuing environmental harm and require intervention by this Hon’ble Tribunal for prevention, control and remediation of the environmental damage.

The Applicant therefore seeks appropriate directions against the Respondents, including compliance with applicable environmental conditions, restoration of the affected environment and such environmental compensation or other relief as may be permissible in law.

6. List of Dates

A List of Dates should present the important events chronologically.

DateParticulars
DD.MM.YYYYEnvironmental clearance/consent/permission granted.
DD.MM.YYYYRespondent commenced the relevant activity.
DD.MM.YYYYApplicant noticed alleged environmental violation.
DD.MM.YYYYComplaint submitted to the concerned authority.
DD.MM.YYYYReminder/representation submitted.
DD.MM.YYYYRTI application filed, if applicable.
DD.MM.YYYYInformation received from the authority.
DD.MM.YYYYContinuing violation/environmental damage.
DD.MM.YYYYPresent Original Application filed before the NGT.

Drafting Tip

Include only dates that are legally relevant. A good chronology can make a complicated environmental dispute substantially easier to understand.

7. Memo of Parties

The parties must be properly identified.

Applicant

Provide, as applicable:

  • full name;
  • father’s/mother’s name;
  • residential address;
  • email;
  • telephone/mobile number;
  • occupation, where relevant; and
  • other particulars required by the applicable procedure.

Respondents

For each respondent, mention:

  • complete name/designation;
  • official address;
  • department/organisation;
  • email/contact details where required; and
  • their connection with the environmental dispute.

Government authorities should generally be described by their proper designation, rather than merely naming an individual officer.

8. Main Application

The main application contains the factual and legal foundation of the case.

A useful structure is:

Paragraph 1 — Applicant

Explain who the applicant is and why the applicant is approaching the Tribunal.

Paragraph 2 — Respondents

Explain who the respondents are and their connection with the dispute.

Paragraph 3 onwards — Facts

Set out the material facts chronologically.

For example:

  • nature of the project/activity;
  • location;
  • environmental clearance;
  • consent/permission;
  • conditions imposed;
  • alleged violations;
  • environmental consequences;
  • complaints made;
  • inspections;
  • governmental action/inaction;
  • supporting documents.

9. Establishing NGT Jurisdiction

This is one of the most important parts of the drafting.

The application should explain why the dispute falls within the jurisdiction of the NGT.

Depending upon the facts, the pleading may identify:

  • the substantial question relating to the environment;
  • the environmental law involved;
  • the legal right allegedly violated;
  • the environmental damage or threat;
  • the relief sought under Section 15; and
  • the statutory basis for approaching the Tribunal.

Avoid simply writing:

“This Hon’ble Tribunal has jurisdiction.”

Instead, explain how the facts satisfy the statutory requirements.

10. Limitation

Limitation must be addressed carefully.

Section 14(3) of the NGT Act prescribes the limitation period for applications under Section 14, subject to the statutory provisions concerning delay.

Where the alleged environmental violation is continuing, the drafting should clearly identify:

  • when the violation began;
  • whether it continues;
  • subsequent events demonstrating continuation;
  • the latest cause of action; and
  • why the application is within limitation.

Important Drafting Point

Do not automatically state that every continuing environmental violation creates a fresh cause of action indefinitely.

The limitation provisions should be analysed based on the specific relief, statutory provision invoked and facts of the case. Remember NGT is very strict about the limitation.

11. Previous Representations and Complaints

If the applicant has approached government authorities before filing the NGT application, the application should provide details of those efforts.

For example:

On [date], the Applicant submitted a representation before Respondent No. __ highlighting the alleged environmental violations.

Then mention:

  • acknowledgment;
  • inspection;
  • response;
  • reminder;
  • RTI response;
  • action taken; or
  • failure to act.

The relevant documents should be annexed.

This helps demonstrate that the applicant has placed the environmental issue before the competent authorities and provides the Tribunal with the relevant documentary record.

12. Environmental Violations

This is the core factual section of an environmental application.

The applicant should identify the violation with precision.

For example:

Alleged Violation of Environmental Clearance Conditions

Instead of merely stating:

“The Respondent is violating the EC.”

identify:

“Condition No. __ of the Environmental Clearance dated __ requires ____. However, the Respondent is allegedly undertaking ____, contrary to the said condition.”

This drafting technique makes the pleading much stronger.

Use a violation table where appropriate

EC ConditionRequirementAlleged ViolationSupporting Document
Condition 1________Annexure A-1
Condition 2________Annexure A-2
Condition 3________Annexure A-3

13. Environmental Impact

The application should explain what environmental harm has occurred or is threatened.

Depending upon the case, this may involve:

  • air pollution;
  • water pollution;
  • groundwater contamination;
  • illegal discharge;
  • waste mismanagement;
  • destruction of vegetation;
  • damage to wetlands;
  • forest degradation;
  • ecological damage;
  • noise pollution;
  • soil contamination;
  • damage to biodiversity; or
  • other environmental consequences.

The applicant should connect the alleged activity with the environmental consequence using available evidence.

14. Grounds

The grounds should translate the facts into legal reasons for granting relief.

Common grounds may include:

A. Violation of Environmental Clearance Conditions

Where the respondent has failed to comply with binding conditions imposed through environmental clearance.

B. Violation of Environmental Laws

Where the facts disclose non-compliance with applicable environmental legislation, rules, notifications or statutory requirements.

C. Failure of Statutory Authorities

Where the competent authorities have failed to discharge their statutory responsibilities despite information or complaints regarding alleged violations.

D. Precautionary Principle

Where there is a credible threat of serious environmental harm and preventive measures are required.

E. Polluter Pays Principle

Where environmental damage attributable to the polluter warrants appropriate compensation and/or restoration measures.

F. Sustainable Development

Where the dispute requires balancing development activity with environmental protection in accordance with applicable law.

G. Restoration of Environment

Where environmental damage has already occurred and remedial or restoration measures are required.

15. Drafting the Grounds — Important Rule

Every ground should ideally contain:

Fact → Legal violation → Consequence → Relief

For example:

BECAUSE the Respondent has failed to comply with Condition No. __ of the Environmental Clearance dated __, which requires ____. Such non-compliance has resulted in/threatens ____. The Respondent is therefore liable to comply with the said condition and undertake appropriate remedial measures.

This is much better than making broad allegations such as:

“The Respondent is harming the environment.”

16. Principles of Environmental Law

Depending upon the facts, the application may rely upon recognised environmental principles.

Polluter Pays Principle

The principle requires the polluter to bear appropriate costs associated with preventing and remedying environmental damage, as recognised in Indian environmental jurisprudence.

Precautionary Principle

Environmental protection need not always wait until damage becomes irreversible where there is a serious environmental risk.

Sustainable Development

Development must be pursued consistently with environmental protection and applicable legal requirements.

Public Trust Doctrine

Natural resources may be subject to obligations upon the State to protect them for the benefit of the public.

Drafting caution: These principles should not be inserted mechanically. The facts should demonstrate why a particular principle is relevant.

17. Prayer Clause

The prayer should correspond directly with the facts and grounds.

A prayer may seek, depending on the case:

  1. directions for compliance with environmental clearance conditions;
  2. directions to stop or regulate an environmentally harmful activity;
  3. inspection or assessment by a competent authority;
  4. environmental restoration;
  5. environmental compensation;
  6. remediation of pollution;
  7. restoration of damaged property/environment;
  8. constitution of an expert committee, where appropriate;
  9. directions to statutory authorities to perform their legal duties; and
  10. any other appropriate relief within the Tribunal’s jurisdiction.

Sample Prayer

PRAYER

In view of the facts and circumstances stated hereinabove, it is most respectfully prayed that this Hon’ble Tribunal may graciously be pleased to:

a. Direct the Respondents to comply with the applicable Environmental Clearance conditions and other statutory environmental requirements;

b. Direct the concerned statutory authorities to undertake an appropriate inspection/inquiry into the alleged environmental violations;

c. Direct the Respondents to take appropriate remedial and environmental restoration measures in respect of the damage caused to the environment;

d. Determine and impose such environmental compensation as may be permissible in law, having regard to the nature and extent of the environmental damage and the applicable legal principles;

e. Direct the Respondents to take such preventive measures as may be necessary to prevent further environmental degradation; and

f. Pass such other and further order(s) as this Hon’ble Tribunal may deem fit and proper in the interests of justice and environmental protection.

18. Interim Relief

Where immediate environmental harm is occurring, the applicant may consider seeking interim relief.

The application should explain:

  • the urgency;
  • the continuing environmental risk;
  • why immediate intervention is necessary;
  • what specific interim direction is sought; and
  • why the requested relief is connected with the final relief.

Do not seek vague interim orders.

Instead of:

“Pass appropriate interim orders.”

prefer a specific request such as:

“Direct the Respondent to maintain status quo with respect to the activity described in paragraph __ pending consideration of the present application.”

The exact relief must, of course, be tailored to the facts and applicable law.

19. Annexures

Documents should be carefully arranged and referred to in the application.

Common documents may include:

  • Environmental Clearance;
  • Consent to Establish;
  • Consent to Operate;
  • environmental compliance reports;
  • inspection reports;
  • photographs;
  • laboratory reports;
  • government correspondence;
  • complaints;
  • representations;
  • RTI applications;
  • RTI replies;
  • satellite imagery, where legally and factually relevant;
  • expert reports;
  • notices/orders of statutory authorities; and
  • other material supporting the allegations.

Example

A copy of the Environmental Clearance dated __ is annexed herewith and marked as Annexure A-1.

The same document should then appear in the annexure index.

20. Affidavit and Verification

The application should be supported by the required affidavit and verification in accordance with the applicable procedural requirements.

The verification should distinguish, where appropriate, between:

  • statements based on personal knowledge; and
  • statements based on information/documents believed to be true.

False or exaggerated statements should never be included in an environmental application.

21. Vakalatnama

Attach a vakaltnama stating that you are the Counsel representing so and so client in so and so matter before NGT.

22. Download Sample Draft and Watch Video

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