Dileep v Saptarshi and 2 Ors. vs Assistant Commissioner Municipal Corporation of Greater Mumbai-H West Ward and 3 Ors.

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2025:BHC-OS:9866-DB

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IN THE HIGH COURT OF JUDICATURE AT BOMBAY ORDINARY ORIGINAL CIVIL JURISDICTION

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PUBLIC INTEREST LITIGATION NO.43 OF 2025

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Dileep V. Saptarshi and Ors. ...Petitioners

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V/s.

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Assistant Commissioner, Municipal Corporation of Greater Mumbai and Ors. ...Respondents

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WITH WRIT PETITION NO.353 OF 2020

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Pravin Sajjan Mohite and Ors.

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...Petitioners

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V/s.

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Municipal Corporation of Greater Bombay and Ors. ...Respondents

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______________ Ms. Gayatri Singh, Senior Advocate i/b. Ms. Ronita Bhattacharya Bector for the Petitioner in PIL/43/2025.

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Mr. Pradeep Havnur for the Petitioner in WP/353/2020.

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Ms. Dhruti Kapadia with Ms. Oorja Dhond i/b. Ms. Komal Punjabi for Respondent Nos.1 and 2-MCGM in PIL/43/2025.

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Ms. Oorja Dhond i/b. Ms. Komal Punjabi for Respondent No.1MCGM in WP/353/2020.

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Smt. Uma Palsuledesai, AGP for Respondent Nos.3 and 4-State in PIL/43/2025.

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Dr. Milind Sathe, Senior Advocate with Mr. Jagdish G. Aradwad (Reddy) for Respondent No.5-SRA in PIL/43/2025.

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Smt. Usha Rahi, AGP for Respondent Nos.5 & 9-State in WP/353/2020.

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Mr. Abhijit P. Kulkarni with Ms. Sweta Shah for Respondent Nos.3 and 4-SRA in WP/353/2020.

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Ms. Rama Subramanian for Respondent No.6.

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Ms. Anshu Awasthi for Respondent No.7.

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CORAM: ALOK ARADHE, CJ. &

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SANDEEP V. MARNE, J. Dated: 30 JUNE 2025.

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Order: (Per Sandeep V. Marne J.)

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Public Interest Litigation No.43 of 2025 is filed seeking a direction against the Municipal Corporation for Greater Mumbai ( MCGM) to demarcate/fence plot of land admeasuring 6000 sq.mtrs for use as Playground out of Plot bearing CTS No.1143 (previous No.1143-D) situated at Ambedkar Road, H West Ward, Khar, in such a manner that size/dimension of the plot is not reduced. Further direction is sought against the MCGM for development of the said plot of land admeasuring 6000 sq.mtrs. as Playground. Petitioners have

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also sought direction against MCGM to restrain it from allowing any construction to take place on the said plot of land admeasuring 6000 sq.mtrs. Further direction for conduct of enquiry against concerned officers failing to demarcate the Playground admeasuring 6000 sq.mtrs is also sought.

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Writ Petition No.353 of 2020 is filed by three Petitioners challenging Annexure-II prepared by Respondent Nos.1 to 4 in respect of the same land with further directions for conduct of fresh survey for the purpose of inclusion of names of Petitioners therein.

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Thus, while the PIL seeks to ensure that the entire land admeasuring 6000 sq.mtrs is maintained and fenced as Playground, Writ Petition seeks implementation of Slum Rehabilitation ( SR ) Scheme on the part of the said land by including the names of Petitioners as eligible slum dwellers.

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Brief facts as pleaded in the PIL are that:-

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In the Development Plan of 1966 the land admeasuring 10,350 sq.mtrs. was shown as pond and a recreation ground. In the Development Plan of 1991, the reservation in respect of the said plot of land was changed as a Playground. In the Development Plan of 1991 sanctioned vide Gazette Notification dated 7 May 1992, the plot bearing CTS No.1143 came to be divided into three parts viz., Playground of 6000 sq.mtrs., Police Station admeasuring 1200 sq.mtrs and land for housing of the dishoused

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admeasuring 1200 sq.mtrs. The Petitioners filed Writ Petition No.2889 of 1988 for demarcation of the recreational ground area as per Development Plan of 1966. An interim order was passed by this Court on 28 November 1988 directing MCGM to ensure that no further encroachment takes place on the plot. Interim order was challenged before the Apex Court by MCGM in Special Leave Petition (Civil) No.21277 of 1994. According to the Petitioners, the Hon’ble Apex Court directed that no construction of any dwelling unit shall be made on area admeasuring 6000 sq.mtrs. on plot bearing CTS No.1143, which is reserved for playground by vacating the interim order dated 28 November 1988 in respect of balance portion of the land. It is the case of the PIL Petitioners that despite direction of the Hon’ble Apex Court, MCGM failed to ensure that land admeasuring 6000 sq.mtrs. is demarcated and fenced as a playground and instead, MCGM is permitting implementation of the SR scheme in respect of some portion of the land. Accordingly, the Petitioner has filed the present PIL seeking directions against the MCGM for demarcation and fencing of land admeasuring 6000 sq.mtrs. as playground.

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We have heard Ms. Singh, the learned senior advocate appearing for the PIL Petitioners, who would submit that action of MCGM in not demarcating land admeasuring 6000 sq.mtrs. and not fencing the same is in teeth of order passed by the Hon’ble Apex Court. That instead of protecting the concerned plot of land by preventing encroachment, the MCGM is in fact

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permitting implementation of slum scheme by carrying out development on the land. She would submit that developers have taken over substantial portion of the land for carrying out construction activities. That despite passing of interim order by this Court, construction activity is still going on. That the order passed by the Hon’ble Apex Court is not modified in any manner and that the Respondents are duty bound to ensure that entire land admeasuring 6000 sq.mtrs is maintained and protected as a playground.

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Dr. Sathe, the learned senior advocate appearing for the Slum Rehabilitation Authority ( SRA) would submit that under Regulation 17(3)(D)(a)(2)(ii) of Development Control and Promotion Regulation, 2034 (DCPR, 2034) if the plot has open space reservation exceeding 500 sq.mtrs the land can be developed for slum redevelopment on a condition of maintaining 35% land open for reservation. That there was similar provision even in DCR 1991. That therefore it cannot be contended that SR scheme cannot be implemented on the land reserved for playground. He would submit that recently, this Court has upheld the said provision in the DCPR promoting implementation of the SR scheme on reserved land. He would accordingly justify implementation of the SR scheme on the concerned plot of land. He would submit that the minimum percentage of land prescribed under the DCPR 2034 would be kept open as a playground after implementation of the SR scheme.

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Ms. Kapadia, the learned counsel appearing for MCGM would submit that the actual reservation of playground is only of 5250 sq.mtrs and not 6000 sq. mtrs. as per Development Plan, 1991. However, the PR card shows the actual area of 4802 sq.mtrs upon measurement. She would rely upon measurements conducted by City Survey Officer to demonstrate that the actual open space available is only 4802 sq.mtrs. as against reservation of land admeasuring 5250 sq.mtrs. in the Development Plan. She would submit that since SR scheme can be implemented in order to rehabilitate the slum dwellers under the DCPR 2034, SRA has taken up and sanctioned proposal for implementation of the slum scheme.

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Ms. Subramanian, the learned counsel appearing for Respondent No.6 and Ms. Awasthi, the learned counsel appearing for Respondent No.7 would complain that implementation of SR scheme is withheld on account of interim order passed by this Court. That their clients are suffering huge financial losses on account of SR scheme being put on hold.

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We have also heard Smt. Rahi, the learned AGP for Respondent Nos.3 and 4-State Government.

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Having considered the submissions canvassed by the learned counsel appearing for the parties it is seen that Petitioners essentially seek enforcement of the order passed by

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the Hon’ble Apex Court on 3 April 1995 in SLP (C) No.21277 of 1994 restraining construction of any dwelling units on land admeasuring 6000 sq.mtrs., whereas the contesting Respondents in the PIL as well as Petitioners in Writ Petition No.353 of 2020 believe that the DCPR 2034 envisages implementation of the SR scheme even in respect of land reserved as a Playground and that therefore the encroached portion of the plot can be used for housing the eligible encroachers.

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It would be apposite to reproduce the directions issued by the Hon’ble Apex Court in the order dated 3 April 1995, which reads thus:-

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The order dated October 21, 1994 passed by the High Court on Notice of Motion No.690 of 1994 is, therefore, set aside and the said Notice of Motion No.690 of 1994 taken out by the appellant is allowed and the operation of the interim order dated November 28, 1988 passed by the High Court is modified and it is directed that no construction of any dwelling unit shall be made or permitted to be made on an area of 6000 sq.mtrs. of plot bearing Survey No.1143 reserved for play ground in the Revised Development Plan of 1992 which area should be demarcated by the appellant as per the Revised Development Plan of 1992, and the said interim order dated November 28, 1988 is vacated in respect of the rest of the area of the plot bearing Survey No.1143 referred to above. The appeal is disposed of accordingly. No costs.

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Thus, the MCGM has been specifically ordered not to permit construction of any dwelling unit on land admeasuring 6000 sq.mtrs. which is reserved as Playground.

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It is however, contention of the MCGM that correct area of reservation for Playground in the Development Plan is

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only 5250 sq.mtrs. MCGM also believes that in respect of encroachment on certain portion of the said plot, it is permissible to implement SR scheme. Thus, for twin reasons of (i) difference in the area of Playground reflected by the order of the Apex Court and the area indicated in the Development Plan and (ii) on account of existence of slum structures, MCGM, is unable to implement the directives of the Hon’ble Apex Court.

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About the exact area of the land reserved as Playground, the City Survey Officer has filed an Affidavit after conduct of joint measurement on 2 March 2022 stating that the correct area of land reserved for Playground is 5255 sq.mtrs.

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SRA also contends that it is permissible to implement SR scheme even on plot reserved as a Playground under the DCPR 2034. That it was permissible to do so even in DCR 1991.

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Reliance is placed by the contesting Respondents on provisions of Regulation 17(3)(D)(a)(2)(ii) of DCPR, 2034, which reads thus :-

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Where the area of site having non-buildable/open space reservations more than 500 sq.meters, such sites may be allowed to be developed for slum redevelopment subject to conditions, that the ground area of the land so used shall not be more than 65% of the reservation and leaving 35% rendered clear thereafter for the reservation.

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Thus, under the above Regulation, if the area of land having open space reservation exceeds 500 sq.mtrs., such land can be developed as a SR scheme subject to condition of not utilising more than 65% of reservation for the implementation of the scheme and keeping 35% of the reserved land open. The SRA has clarified that structures of 49 pavement dwellers are noticed on the land in question in addition to several slum dwellers. SRA believes that the concerned plot of land can be developed as a SR scheme and has accordingly issued Letter of Intent for implementation of the SR scheme.

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According to SRA, out of the area of the Playground, area admeasuring 1184.98 sq.mtrs is encumbered by slum, area admeasuring 649.63 sq.mtrs is encumbered by pavement dwellers leaving open land admeasuring 3415.39 sq.mtrs. It is further contended on behalf of the SRA that 65% of the land encumbered by slum of 1184.98 sq.mtrs as well as 65% of land encumbered by pavement dweller of 643.69 sq.mtrs would only be utilised for implementation of SR scheme and 35% land encumbered by slum dwellers and pavement dwellers would be kept vacant. The relevant part of the Affidavit filed by SRA reads thus:-

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I say that as per the aforementioned provisions, the Architect of the SR Scheme on the subject property claimed 65% encumbered PG area admeasuring 1192.49 sq.mt. (i.e.65% of 1184.98, area encumbered by the slum and 65% of 649.63 sq.meters, encumbered by 49 pavement dwellers, whose structures were originally located on PG land).

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The vacant PG area admeasuring 3415.39 sq.meters with 35% encumbered PG area admeasuring 642.11 sq.mtr(i.e. 35% of 1184.98, area encumbered by the slum and 35% of 649.63 sq.meters, encumbered by 49 pavement dwellers, whose structures were originally located on PG land) i.e. aggregate total 4057.50 sq.meters is proposed to be kept clear for reservation of PG on the subject property.

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This is how SRA contends that even after implementation of SR scheme, total aggregate land 4057.50 sq.meters (original vacant land of 3415.39 sq.meters plus 35% area arising from implementation of SR Scheme of 642.11 sq.meters) would be kept open for the purpose of Playground. Thus, it is sought to be suggested that as against the land for Playground indicated by the Hon’ble Apex Court as 6000 sq.meters and as against the land actually indicated in the Development Plan of 5250 sq.meters, the actual Playground of 4057.50 sq.meters would actually be maintained even after implementation of the slum scheme.

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MCGM is desirous of clearing and improving the slum and is expecting SRA to implement the SR Scheme. SRA is willing to implement the Scheme, but is facing opposition from the PIL Petitioners. The slum and pavement dwellers are also looking forward to secure houses on ownership basis upon implementation of the SR Scheme. The developers, who are issued LoI by SRA, are unable to carry forward the work of rehabilitation of the slum on account of interim order passed by this Court in the PIL.

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While PIL Petitioners expect that no portion of the land reserved as Playground can be utilized for any purposes, including implementation of SR Scheme and that the entire land admeasuring 6000 sq.mtrs. must be made vacant for use as Playground, the Respondents believe that what is permissible under the DCPR-2034 cannot be denied in the present case only because there is an order of the Supreme Court passed in the present case.

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This Court notes the fact that very recently, validity of Regulation 17(3)(D)(2) of DCPR, 2034 making provision for implementation of the SR Scheme in respect of land reserved as open space has been upheld by the Division Bench of this Court in NGO Alliance for Governance and Renewal (NAGAR) and Ors. Vs. State of Maharashtra and Ors.¹ The Division Bench has held in its judgment dated 19 June 2025 as under :-

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354 . Accordingly, while upholding the validity of Regulation 17(3)(D)(2), in exercise of our jurisdiction under Article 226 of the Constitution of India, and in furtherance of the duties cast upon the State under Article 48A of the Constitution and the mandate of Sections 22, 31 and 158 of the MRTP Act, this Court issues the following directions to ensure preservation and protection of lands reserved as open spaces in the sanctioned Development Plan (DP) of Mumbai:

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(i) In every slum redevelopment project approved under Regulation 17(3)(D)(2), the Municipal Corporation of Greater Mumbai and the Slum Rehabilitation Authority shall ensure that at least 35% of the total plot area is clearly marked, preserved, and developed as an open space. This portion shall be used for parks, gardens, or playgrounds, in accordance with Development Plan. The open

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1 Writ Petition (OS) No.1152 of 2002 decided on 19 June 2025.

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space should be in one continuous stretch and not scattered into unusable fragments.

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(ii) The 35% open space shall be treated as a public amenity and not a private area for use only by the residents of the rehab buildings. It must remain open and accessible to the general public, including other residents in the surrounding area. Once the project is completed, the open space must be handed over to the Municipal Corporation or any other appropriate public body for maintenance and management, unless the Corporation specifically permits joint maintenance with the housing society under prescribed conditions. Under no circumstances shall this space be enclosed or restricted in a way that prevents entry of the local public. No portion of the open space shall be reserved exclusively for any private group, resident association, or developer.

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(iii) The State Government and the SRA shall form a dedicated monitoring committee or senior officer, who will oversee the implementation of the Regulation on the ground. Field officers shall submit quarterly reports to the SRA and the UDD stating : Whether the 35% open space has been properly marked; Whether development like landscaping and park creation has started and completed; Whether the land has been officially handed over to the civic body; Whether public access is being maintained. Public access and scrutiny of such quarterly reports of the Special Monitoring Cell shall be ensured by uploading them on the websites of SRA and UDD within two weeks of the end of each quarter.

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(iv) Any violation, such as building beyond the allowed 65% area or not providing the promised open space, must be corrected immediately, and disciplinary action shall be considered if necessary. The Court makes it clear that the 35% open space is a minimum requirement, not an average or flexible figure. In fact, if any project manages to retain more than 35% through better planning, it should be appreciated and encouraged.

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(v) It is directed that in every slum rehabilitation scheme undertaken on lands reserved for public open spaces (POS) under the Development Plan, the minimum 35% open space required to be

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retained under Regulation 17(3)(D)(2) of the DCPR 2034 : (a) Shall be clearly demarcated in the final approved layout plan at the time of issuance of Letter of Intent (LoI) or Commencement Certificate (CC), as the case may be. (b) The layout shall reflect the precise location, dimensions, shape, and orientation of the open space so that it cannot be subsequently modified or shifted under the guise of layout readjustments or design exigencies. (c) No approval shall be granted to any proposal unless this requirement is visibly and verifiably complied with.

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(vi) The retained 35% open space must be developed as a functional and usable public park, which includes : (a) Green landscaping with appropriate vegetation and shaded areas; (b) Walking/jogging tracks with proper surfacing and illumination; (c) Installation of seating areas (benches), children's play equipment, and fitness zones wherever feasible; (d) Lighting, drainage, and safety features ensuring usability during all hours of public operation; (e) Signage indicating that the space is public in nature and maintained under the authority of the local body.

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(vii) The entire open space shall be formally handed over to the Municipal Corporation or the local planning authority (as the case may be) within 90 days of the date of obtaining the Occupation Certificate for the rehabilitation component. At the time of handover, the developer or scheme proponent shall : (a) Provide a basic capital grant or maintenance corpus, as may be determined by the Planning Authority or Municipal Corporation, to ensure upkeep; (b) Furnish an undertaking to indemnify the authority in case of deficiencies in development or maintenance obligations for a period of three years.

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(viii) The State Government, through the MCGM and the SRA, shall ensure that no new encroachment is permitted or allowed to occur after the reservation of land as open space in the sanctioned Development Plan. In particular, lands reserved for Recreation Grounds (RGs), Playgrounds (PGs), Gardens, Parks, and similar civic amenities shall be treated as non-buildable zones, except as permitted under judicially sanctioned frameworks and statutory exceptions.

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(ix) The MCGM shall, within 90 days of the upload of this judgment on the website of this Court, prepare a ward-wise action plan listing all reserved open spaces and submit the same to the UDD. The SRA and MCGM shall jointly constitute a Special Monitoring Cell headed by a Deputy Municipal Commissioner not below the rank of Class I officer, along with a representative of the Planning Department, to carry out quarterly inspections and submit reports identifying any fresh encroachments.

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(x) The MCGM shall, with the assistance of MahaIT and the State Remote Sensing Application Centre, complete a GIS-based mapping and geo-tagging of all plots designated as open space in the sanctioned Development Plan, including their current usage status, within a period of 4 months from the date of this judgment. The mapping database shall be published on the MCGM website and kept updated bi-annually, so as to ensure transparency and public access.

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(xi) No slum rehabilitation scheme under Regulation 17(3)(D)(2) of DCPR 2034 shall be sanctioned or implemented on a reserved open space unless the following mandatory conditions are fulfilled : (a) The encroachment must have existed prior to the date of reservation under the sanctioned Development Plan; (b) A certificate of unavailability of alternative land must be issued by the Collector and endorsed by the UDD; (c) The scheme must retain at least 35% of the total plot area as open space in one contiguous, accessible, and functional parcel, and such area shall be : (i) developed as a recreation ground or park or used as as shown in Development Plan, (ii) handed over to MCGM for public use and maintenance, (iii) not enclosed or made exclusive to residents; (d) The scheme must be reviewed and approved by a Special Urban Planning Review Committee to be constituted by the State within 60 days.

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(xii) The UDD, MCGM, and SRA shall file biannual compliance affidavits before the Registry of this Court for a period of three years, detailing : Status of geo-tagging and mapping, List of reserved open plots with existing encroachments, Action taken to prevent or remove encroachments, Details of slum rehabilitation schemes approved under Regulation 17(3)(D)(2), Development and

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handover status of the 35% open space under each project. The affidavits shall be placed before appropriate bench of this court for monitorial review.

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(xiii) Simultaneously, the quarterly reports of the Special Monitoring Cell shall be uploaded on the websites of MCGM and UDD for public scrutiny.

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(xiv) The State Government shall undertake a comprehensive policy review of Regulation 17(3)(D)(2) of DCPR 2034 within a period of 24 months, including : A field-wise environmental and urban health impact assessment, Stakeholder consultations including residents' associations and urban planners, Evaluation of whether the 35 : 65 ratio serves the goals of sustainable development. If necessary, the State shall frame revised regulations ensuring a higher retention of open space, enhanced civic safeguards, and exclusion of fresh encroachments from rehabilitation benefits.

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(xv) The State Government shall issue a comprehensive circular/resolution within four weeks from the date of this order, incorporating these directions and requiring compliance in all schemes under Regulation 17(3)(D)(2).

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(xvi) Our decision should not be read as giving a free hand to the State to reduce open spaces in the city. The responsibility to maintain and increase open spaces continues. The State and local planning bodies must take concrete steps to improve the per capita open space availability, especially in areas where it is dangerously low. These steps must include : Identifying and purchasing private lands that can be converted into gardens or parks; Turning unused NDZ areas or buffer lands into recreation zones where environmentally suitable; Strictly enforcing open space provisions in all layouts, residential or commercial. Preserving what remains is not enough. The city needs new and better open spaces for its growing population.

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(xvii) We make it clear that our decision is based on the present structure and implementation of the Regulation. If future developments, such as ground-level data, environmental reports, or public grievances, show that the 35% open space is not enough, the State will be bound to revisit the policy. The State may then

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consider : Increasing the minimum open space, or Introducing stricter controls on the size and number of houses or floors allowed under such projects. Our approval of the Regulation is based on the balance currently offered between public space and housing needs. That balance must remain flexible and sensitive to future challenges. It cannot be static. The welfare of the people must always be the guiding principle.

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We, therefore, decline to strike down Regulation 17(3)(D)(2). The writ petition, to that extent, stands dismissed. However, keeping in mind the important constitutional values involved, such as the need to protect the environment, the public trust doctrine, the rights of slum dwellers, and the goal of sustainable development, we have exercised our powers under Article 226 of the Constitution and issued specific directions (i) to (xvii) earlier in this judgment.

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Thus as per the Division Bench judgment in NGO Alliance for Governance and Renewal (NAGAR) it is permissible to implement slum scheme even on land reserved for Playground subject to keeping open 35% of encroached land open for public amenity.

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In our view, since there is a prohibition imposed by the Hon’ble Apex Court by order dated 3 April 1995 on construction of any dwelling units on land admeasuring 6000 sq.mtrs, it would be necessary for the parties to approach Hon’ble Apex Court seeking clarification about twin aspects of (i) the alleged error in recording reservation in respect of land admeasuring 6000 sq.mtrs instead of 5255 sq.mtrs and (ii) permissibility to implement SR scheme for rehabilitation of pavement dwellers and slum dwellers, leaving open land admeasuring 4057.50 sq.meters.

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If the contesting Respondents contend that implementation of the SR scheme is permissible on concerned plot of land, they must seek an appropriate clarification from the Hon’ble Apex Court so that the order dated 3 April 1995 passed by the Hon’ble Apex Court would not come in the way of implementation of the SR scheme. We therefore deem it appropriate that MCGM as well as all other affected parties secure a clarification from the Hon’ble Apex Court for implementation of SR scheme as well as for reflecting correct area of reservation of the plot as Playground.

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So far as Writ Petition No.353 of 2020 is concerned, the question of deciding eligibility of the Petitioners would arise only in the event the Apex Court clarifies that SR scheme can be implemented in respect of the plot in question.

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We accordingly proceed to pass the following order:-

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(a) MCGM, SRA, Respondent Nos.6 and 7 and any other interested party shall seek a clarification from the Hon’ble Apex Court in respect of order dated 3 April 1995 passed in SLP (C) No.21277 of 1994 as to whether SR Scheme can be implemented on the concerned plot of land in accordance with the provisions of Regulation 17(3)(D)(a)(2)(ii) of DCPR, 2034.

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(b) The parties would also be at liberty to seek a clarification regarding the exact area of reservation of land as Playground in the Development Plan.

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(c) Till a clarification is issued by the Hon’ble Supreme Court, the interim order dated 29 November 2021 passed in PIL No.43 of 2025 shall continue to operate.

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(d) Respondent No.5-SRA in PIL No.43 of 2025 can implement SR Scheme on the concerned plot of land through the developers nominated by it only after seeking clarification from the Hon’ble Apex Court.

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(e) In the event of the Hon’ble Apex Court permitting implementation of the SR Scheme, Petitioners in Writ Petition No.353 of 2020 shall be at liberty to raise a grievance relating to eligibility before the concerned Competent Authority and if aggrieved by the decision of the Competent Authority, they would be at liberty to file a fresh Petition. All contentions with regard to their eligibility are expressly kept open.

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With the above directions, the Public Interest Litigation and Writ Petition stand disposed of.

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[SANDEEP V. MARNE, J.] [CHIEF JUSTICE]

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Signed by: Megha S. Parab Designation: PA To Honourable Judge Date: 02/07/2025 18:04:56

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Page No. 18 of 18 30 June 2025

Dileep v. Saptarshi and 2 Ors. v Assistant Commissioner Municipal Corporation of Greater Mumbai-H West Ward and 3 Ors.

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Dileep v. Saptarshi and 2 Ors. v Assistant Commissioner Municipal Corporation of Greater Mumbai-H West Ward and 3 Ors.

Case brief

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