Public Interest Litigation No.105 of 2025 (Bombay High Court, DB: Shree Chandrashekhar, CJ. and Gautam A. Ankhad, J., 18.11.2025) seeking a mandamus to declare mangrove forest areas of Mumbra and Diva a designated 'mangrove protection area' and eight further directions (restraint on destruction, removal of obstructions and encroachments, eco-tourism parks, a mangrove restoration fund, monthly satellite monitoring, and accounting of National Committee on Mangroves & Coral Reefs funds) dismissed in limine. Held: (i) a writ court under Article 226 has no jurisdiction to conduct a roving enquiry and issue such directions, nor to gather facts from affidavits to grant relief to a person projecting himself as aggrieved; (ii) the writ pleadings disclosed no destruction of mangroves except in paragraph 19, confined to survey nos. 124, 43, 102, 120, 44 and other areas of village Mumbra; the petitioner admitted he is not a resident of Mumbra or Diva and never visited the area; (iii) a PIL directed against an individual or a group of individuals — here the Goyal family and Naruttam Nagar Co-operative Housing Society named in the petitioner's representation dated 05.08.2025 — cannot be taken cognizance of; (iv) relying on BALCO Employees' Union v. Union of India (2002) 2 SCC 333, a writ petition labelled as a PIL cannot be entertained at the behest of a person who fails to indicate any public interest; (v) treating Bombay Environmental Action Group v. State of Maharashtra (W.P. (Stamp) No.32461 of 2004) as a basis for such petitions would flood the Courts with petitions by persons not born when the 06.10.2005 directions in W.P. (Lodging) No.3246 of 2004 were issued, and the Court deprecated repeated writ petitions by individuals or groups; the petitioner, aged about 44, had complained only on 05.08.2025.
