Disposed

Kapil Chauhan v. State of Uttar Pradesh through Its Chief Secretary

NGT31 Aug 2026Original Application No. 247/2025

Case brief

AI extract

What is this about?

The Tribunal held that the District Survey Report (DSR) for Saharanpur was approved by SEAC and SEIAA without the full Replenishment Study Report being placed before them. Consequently, the Tribunal directed the authorities to reappraise the DSR and sustain the validity of e-auction notices subject to the final outcome of this reappraisal.

What did the court decide?

Direction to SEAC and SEIAA, UP to reappraise the DSR of District Saharanpur after deliberating upon the replenishment study report.

Kapil Chauhan vs State of Uttar Pradesh through Its Chief… — Environment and Pollution | NGT (2026)

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Item Nos. 1A to 1E Court No. 1

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BEFORE THE NATIONAL GREEN TRIBUNAL PRINCIPAL BENCH, NEW DELHI

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Original Application No. 1345/2024 (IA No 624/2024 & IA No 625/2024)

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Anees Ali Applicant

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Versus

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State of Uttar Pradesh & Ors. Respondent(s)

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WITH

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Original Application No. 119/2025 (IA No 189/2025)

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Mursleen Applicant

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Versus

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State of Uttar Pradesh & Ors. Respondent(s)

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WITH

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Original Application No. 134/2025

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Arif Khan Applicant

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Versus

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State of Uttar Pradesh & Ors. Respondent(s)

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WITH

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Original Application No. 247/2025

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Kapil Chauhan Applicant

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Versus

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State of Uttar Pradesh & Ors. Respondent(s)

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WITH

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Original Application No. 427/2025 (IA No 573/2025) Ameel Khan Applicant

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Versus

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State of Uttar Pradesh & Ors. Respondent(s)

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Date of completion of hearing and reserving of order: 30.05.2026 Date of pronouncement of order: 31.08.2026

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CORAM: HON’BLE MR. JUSTICE PRAKASH SHRIVASTAVA, CHAIRPERSON HON’BLE DR. AFROZ AHMAD, EXPERT MEMBER

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Applicants: Mr. Ajit Sharma, Mr. Yuvrajsinh C. Solanki & Mr. Kanchan Kumar, Advs. for Applicant in OA 1345/2024 & OA 134/2025

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Mr. Gaurav Kumar Bansal, Ms. Nandita Bansal & Ms. Chandrika Upadhyaya, Advocates for Applicant in OA 247/2025 Mr. Vanshdeep Dalmia, Ms. Anisha Jain, Ms. Shambhavi Singh & Ms. Prerna Cheema, Advs. for Applicant in OA 427/2025

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Respondents: Mr. A.N.S. Nadkarni, Senior Advocate with Mr. V.K. Shahi, AAG with Mr. Ankit Verma, Ms. Himanshi Nagpal & Ms. Manisha Gupta, Advs. for the State of UP

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Mr. Ardhendumauli Kumar Prasad, Senior Advocate with Ms. Priyanka Swami, Ms. Meghna Singhal, Mr. Abhishek Khare, Mr. Siddhanth Kumar & Ms. Dippt Anubhuti, Advs. for SEIAA, UP

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Ms. Pushpila Bisht, Mr. Abhay Singh Malik & Ms. Anupriya Dixit, Advs. for R – 11 & 14 to 17 to in OA 427/2025 Mr. A.N.S. Nadkarni, Senior Advocate with Mr. Mukesh Verma & Ms. Vatsala Tripathi, Advs. for R - 1 & 2 in OA 1345/2024 (Through VC) Mr. Narender Pal Singh, Adv. for MoEF & CC in OA 1345/2024 (Through VC)

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Mr. Pradeep Misra & Mr. Daleep Dhyani, Advs. for UPPCB in OA 119/2025 (Through VC)

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Mr. Gautam Singh, Adv. for R - 12 in OA 427/2025

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Mr. Avinash Kumar Tyagi, Adv. for R-8 to 10 in OA 427/2025 (Through VC) Mr. Ajay Kumar Pandey, Adv. for MoEF & CC in OA 134/2025 (Through VC)

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Mr. Prakhar Srivastava, Adv. in I.A No. 466/2026

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ORDER

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This order will govern the disposal of OA No. 1345/2024, OA No. 119/2025, OA No. 134/2025, OA No. 247/2025 and OA 427/2025. All these original applications in substance challenge the District Survey Report (DSR) of Saharanpur.

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In OA No. 1345/2024 , the Applicant, in addition to challenging the DSR, 2024 for District Saharanpur, has also sought a direction to the respondents to carry out fresh replenishment study for Saharanpur and Yamuna Nagar, prayed for a river audit of river Yamuna and preparation of fresh DSR of District Saharanpur.

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In OA No. 119/2025 , the Applicant has challenged the e-auction notice dated 22.02.2025 issued by the District Magistrate, Saharanpur and has sought a direction to the respondents to conduct a replenishment study for District Saharanpur by a credible institution.

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In OA No. 134/2025 , Applicant has challenged the auction notice dated 28.02.2025 and prayed for a direction that fresh auction notice be issued only after replenishment study is conducted by a government

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agency and no mining activity be permitted in District Saharanpur without uploading the DSR of Saharanpur on the district administration website of District Yamuna Nagar, Haryana and District Sirmaur, Himachal Pradesh and without seeking comments of public residing in those districts.

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In OA No. 247/2025 , the Applicant, in addition to challenging the DSR of District Saharanpur, has challenged the replenishment study 2023-24 and has prayed for setting aside the e-auction notice dated 28.02.2025 with a direction to the respondents to conduct fresh replenishment study in terms of the Sand Mining Management Guidelines, 2016 (SSMG-2016) and Enforcement & Monitoring Guidelines for Sand Mining, 2020 (EMGSM-2020) and has sought an enquiry for alleged unlawful reliance on replenishment study of 2023-24.

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In OA No. 427/2025 , in addition to challenging the DSR for District Saharanpur, the Applicant has challenged the auction notices dated 28.02.2025, 26.05.2025, 05.06.2025 and 07.08.2025 issued by the District Magistrate, Saharanpur and has also challenged the 2024 replenishment study. Additionally, he has challenged the LOI issued to the Respondents No. 7 to 17 in pursuance to these auction notices.

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Factual Background:

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The case of the Applicants is that earlier DSR of District Saharanpur was prepared in 2017 which had expired in 2022 after completing its five years validity period. The District Magistrate, Saharanpur vide order dated 02.05.2022 had constituted a Sub-Divisional Committee for conducting replenishment study in District Saharanpur. The draft DSR for District Saharanpur was published on 13.01.2023 on the website of local administration inviting comments from the public. The SEIAA and SEAC, Uttar Pradesh in the joint meeting held on 02.02.2024 had adopted a detailed Standard Operating Procedure (SOP) regarding preparation and

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updating of DSR for sand mining or RBM which was made applicable with immediate effect throughout the State of Uttar Pradesh. The draft DSR was approved by SEAC-1 and SEAC-2, UP in its joint meeting held on 03.05.2024. This draft DSR was subsequently approved by SEIAA, UP in its meeting dated 24.05.2024.

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According to the Applicants, the replenishment study and the DSR for District Saharanpur have not been conducted/prepared by following the SSMG-2016 and EMGSM-2020. Further case of the Applicants is that the SEAC and SEIAA in its meeting dated 06.03.2025 had admitted that the DSRs in the different districts in the State of UP were approved without submitting a copy of the replenishment study to SEAC/SEIAA, UP and, therefore, in that joint meeting it was decided to keep all the previously approved DSRs in the State of UP (including the DSR of Saharanpur) in abeyance until the replenishment studies are conducted/submitted to SEIAA. Thereafter, the Additional District Magistrate, Saharanpur vide letter dated 09.04.2025 for the first time had submitted the replenishment study conducted for the year 2023-24 to SEIAA, UP. The Applicants in the aforesaid background have questioned the auction notices dated 28.02.2025, 26.05.2025, 05.06.2025 and 07.08.2025.

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The respondents have filed their reply taking the stand that the replenishment study was duly conducted, the DSR has been prepared by following the requisite procedure and the auction notices do not suffer from any error.

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Regulatory Regime and Judicial Pronouncements:

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Before entering into merits of the controversy, it would be appropriate to examine the binding force of the SSMG-2016 and EMGSM2020 on which the Applicants are relying upon and the relevant judgments on this point. This issue has been considered by the Tribunal in the recent

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order dated 27.05.2026 passed in OA No. 9/2025 in the matter of Vinay

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Shrivastav vs. State of Uttar Pradesh Through Chief Secretary as under:

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“Need for regulating the sand mining:

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11. Sand and gravel are important construction material used in developmental and infrastructural activities. River is an important source of sand and gravel with the increasing construction, development and infrastructural activities. There is a proportionate increase in the demand for sand and gravel, but unregulated extraction of sand and gravel from the river bodies adversely affect the river ecology and environment. It is a recognized fact that removing sediments from the active channel bed in river interrupt the continuity of sediment transported through the river system, disrupt the sediment mass balance in the river downstream and induces channel adjustments extending considerable distances beyond the extraction site. It is also a recognized fact that excessive and disproportionate mining of sand and gravels from the riverbed is threatening the environment eco-system. Hence, there is a need for proper scientific assessment of the available mineable quantity of sand, gravel and aggregates and adoption of best practices and stringent measures to ensure regulated mining of such material only upto the permissible limit. Hon’ble Supreme Court in the matter of State of Uttar Pradesh & Anr. vs. Gaurav Kumar & Ors. , reported in 2025 SCC OnLine SC 1069 has held:

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“1.1. Unregulated sandmining disrupts riverine ecosystems, alters natural flow patterns, and leads to erosion and habitat loss. Aquatic biodiversity suffers as spawning grounds are destroyed and water quality deteriorates. The destabilisation of riverbanks increases flooding, risking human life and animal habitat alike. Moreover, the illicit sand trade often operates under the shadow of organised crime, undermining the rule of law and weakening governance structures. Therefore, absolute standards with get tough policies, strict enforcement and quick accountability are compelling for effective regulatory control.”

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Regulatory Regime for Sand Mining:

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12. The Central Government had issued the Notification dated 14.09.2006 under the provisions of the Environment (Protection) Act, 1986 providing for the requirement of prior environmental clearance in respect of the project and activities covered by the said notification. The schedule to the notification requires the EIA for extraction of miner minerals.

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13. Hon’ble Supreme Court in the matter of Deepak Kumar & Ors. vs. State of Haryana & Ors. , reported in (2012) 4 SCC 629 had considered the issue of environmental degradation and threat to biodiversity on account of the sand mining and extraction of alluvial material. In this regard, the Hon’ble Supreme Court had observed in the matter of Deepak Kumar (supra) as under:

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“9. Extraction of alluvial material from within or near a streambed has a direct impact on the stream's physical habitat characteristics. These characteristics include bed elevation,

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substrate composition and stability, instream roughness elements, depth, velocity, turbidity, sediment transport, stream discharge and temperature. Altering these habitat characteristics can have deleterious impacts on both instream biota and the associated riparian habitat. The demand for sand continues to increase day by day as building and construction of new infrastructures and expansion of existing ones is continuous thereby placing immense pressure on the supply of the sand resource and hence mining activities are going on legally and illegally without any restrictions. Lack of proper planning and sand management cause disturbance of marine ecosystem and also upset the ability of natural marine processes to replenish the sand.”

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14. The Hon’ble Supreme Court had noted that river sand mining was an important economic activity, but excessive instream mining causes degradation of river. Accordingly, the Hon’ble Supreme Court in the above matter had expressed the need for effective framework for mining plan and framing of model guidelines by observing as under:

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“25. Quarrying of river sand, it is true, is an important economic activity in the country with river sand forming a crucial raw material for the infrastructural development and for the construction industry but excessive instream sand and gravel mining causes the degradation of rivers. Instream mining lowers the stream bottom of rivers which may lead to bank erosion. Depletion of sand in the streambed and along coastal areas causes the deepening of rivers which may result in destruction of aquatic and riparian habitats as well. Extraction of alluvial material as already mentioned from within or near a streambed has a direct impact on the stream's physical habitat characteristics.

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26. We are of the considered view that it is highly necessary to have an effective framework of mining plan which will take care of all environmental issues and also evolve a long-term rational and sustainable use of natural resource base and also the bio-assessment protocol. Sand mining, it may be noted, may have an adverse effect on biodiversity as loss of habitat caused by sand mining will affect various species, flora and fauna and it may also destabilise the soil structure of river banks and often leaves isolated islands. We find that, taking note of those technical, scientific and environmental matters, MoEF, Government of India, issued various recommendations in March 2010 followed by the Model Rules, 2010 framed by the Ministry of Mines which have to be given effect to, inculcating the spirit of Article 48A and Article 51-A(g) read with Article 21 of the Constitution.

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27. The State of Haryana and various other States have not so far implemented the above recommendations of MoEF or the guidelines issued by the Ministry of Mines before issuing auction notices granting short-term permits by way of auction of minor minerals boulders, gravel, sand, etc., in the riverbeds and elsewhere of less than 5 ha. We, therefore, direct all the States. Union Territories, MoEF and

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the Ministry of Mines to give effect to the recommendations made by MoEF in its Report of March 2010 and the model guidelines framed by the Ministry of Mines, within a period of six months from today and submit their compliance reports.”

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15. The Hon’ble Supreme Court in the above judgment had further directed to grant environmental clearance only after EC for the lease of miner minerals for an area of less than 5 hectares by directing as under:

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“29. We, in the meanwhile, order that leases of minor minerals including their renewal for an area of less than five hectares be granted by the States/Union Territories only after getting environmental clearance from MoEF. Ordered accordingly.”

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16. Considering the judgment of the Hon’ble Supreme Court in the matter of Deepak Kumar (supra) and also the judgment of the Tribunal in this regard, the MoEF&CC vide Notification dated 15.01.2016 had amended the EIA Notification, 2006 and had incorporated Clause-7(iii) relating to preparation of the District Survey Report by providing as under:

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“ 7 (iii) Preparation of District Survey Report for Sand Mining or River Bed Mining and Mining of other Minor Minerals:

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(a) The prescribed procedure for preparation of District Survey Report for sand mining or river bed mining and mining of other minor minerals is given in Appendix X.

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(b) The prescribed procedure for environmental clearance for mining of minor minerals including cluster situation is given in Appendix XI.”;

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17. By this amendment, Appendix X relating to the procedure for preparation of District Survey Report to the following effect was incorporated:

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“APPENDIX - X

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[See paragraph 7 (iii) (a)] PROCEDURE FOR PREPARATION OF DISTRICT SURVEY REPORT

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The main objective of the preparation of District Survey Report (as per the Sustainable Sand Mining Guideline) is to ensure the following:

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Identification of areas of aggradations or deposition where mining can be allowed; and identification of areas of erosion and proximity to infrastructural structures and installations where mining should be prohibited and calculation of annual rate of replenishment and allowing time for replenishment after mining in that area.

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The report shall have the following structure:

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1. Introduction

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2. Overview of Mining Activity in the District

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3 The List of Mining Leases in the District with location, area and period of validity

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4. Details of Royalty or Revenue received in last three years

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5. Detail of Production of Sand or Bajari or minor mineral in last three years

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6. Process of Deposition of Sediments in the rivers of the District

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7. General Profile of the District

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8. Land Utilization Pattern in the district: Forest, Agriculture, Horticulture, Mining etc.

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9. Physiography of the District

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10. Rainfall: month-wise

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11. Geology and Mineral Wealth

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In addition to the above, the report shall contain the following:

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(a) District wise detail of river or stream and other sand source.

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(b) District wise availability of sand or gravel or aggregate resources.

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(c) District wise detail of existing mining leases of sand and aggregates.

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A survey shall be carried out by the DEIAA with the assistance of Geology Department or Irrigation Department or Forest Department or Public Works Department or Ground Water Boards or Remote Sensing Department or Mining Department etc. in the district.

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Drainage system with description of main rivers

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	S. No. N	ame of the Riv	er Area (Sq. Km	drained )	% Area in the D	drained istrict
	Salient Featu	res of Importan	t Rivers and St	reams:
	S. No. Na Riv	me of the er or Stream	Total Length in the District (in Km)	Place origin	of Al Or	titude at igin
Por Riv Str Re for Co	tion of the er or eam commended Mineral ncession	Length of area recommended for mineral concession (in kilometer)	Average width of area recommended for mineral concession (in meters)	Area recom for conces square	mended mineral sion (in meter)	Mineable mineral potential (in metric tonne) (60% of total mineral potential)

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Mineral Potential

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Boulder	Bajari (MT)	Sand (MT)	Total Mineable
(MT)			Mineral
			Potential (MT)

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Annual Deposition

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S. No.	River or Stream	Portion of the river or stream recommended for mineral concession	Length of area recommended for mineral concession (in kilometer)	Average width of area recommended for mineral concession (in meters)	Area recommended for mineral concession (in square meter)	Mineable mineral potential (in metric tonne) (60% of total mineral potential)
Tota Dist	l for the rict

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A Sub-Divisional Committee comprising of Sub-Divisional Magistrate, Officers from Irrigation department, State Pollution Control Board or Committee, Forest department, Geology or mining officer shall visit each site for which environmental clearance has been applied for and make recommendation on suitability of site for mining or prohibition thereof.

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Methodology adopted for calculation of Mineral Potential :

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The mineral potential is calculated based on field investigation and geology of the catchment area of the river or streams. As per the site conditions and location, depth of minable mineral is defined. The area for removal of the mineral in a river or stream can be decided depending on geo-morphology and other factors, it can be 50 % to 60 % of the area of a particular river or stream. For example in some hill States mineral constituents like boulders, river born Bajri, sand up to a depth of one meter are considered as resource mineral. Other constituents like clay and silt are excluded as waste while calculating the mineral potential of particular river or stream.

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The District Survey Report shall be prepared for each minor mineral in the district separately and its draft shall be placed in the public domain by keeping its copy in Collectorate and posting it on district’s website for twenty one days. The comments received shall be considered and if found fit, shall be incorporated in the final Report to be finalised within six months by the DEIAA.

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The District Survey Report shall form the basis for application for environmental clearance, preparation of reports and appraisal of projects. The Report shall be updated once every five years.”

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Sustainable Sand Mining and Management Guidelines, 2016:

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18. The MoEF&CC thereafter had framed the Sustainable Sand Mining and Management Guidelines, 2016 (SSMG-2016). The SSMG2016 under the heading “Need for Policy Guidelines” mentions that the mining aggregates have reached to the level threatening the environment and ecosystem besides also reaching a level of scarcity that would threaten the economy. Therefore, the need for sand &

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aggregate mining and quarrying only after sound scientific assessment and adopting best practices to limit the impact on the environment has been expressed. These guidelines record that uncontrolled sand mining is not sustainable. It also mentions that mining within or near riverbed has a direct impact on stream's physical characteristics, such as channel geometry, bed elevation, substratum composition and stability, in-stream roughness of the bed, flow velocity, discharge capacity, sediment transport capacity, turbidity, temperature, etc. The alteration or modification of these attributes may cause hazardous impact on ecological equilibrium of riverine regime and may also cause adverse impact on in-stream biota and riparian habitats and may also result in changes in channel configuration and flow-paths. The SSMG-2016 records the effects of the sand and gravel mining as under:

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“The effects of sand and gravel mining are as follows:

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a) Extraction of bed material in excess of replenishment by transport from upstream causes the bed to lower (degrade) upstream and downstream of the site of removal.

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b) In-stream habitat is impacted by increase in river gradient, suspended load, sediment transport and sediment deposition. Excessive sediment deposition for replenishment increases turbidity which prevents penetration of light required for photosynthesis and reduces food availability of aquatic fauna.

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c) Riparian habitat including vegetative cover on and adjacent to the river banks it controls erosion, provide nutrient inputs into the stream and prevents intrusion of pollutants in the stream through runoff. Bank erosion and change of morphology of the river can destroy the riparian vegetative cover.

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d) Bed degradation are responsible for channel shifting, causing loss of properties and degradation of landscape, it can also undermine bridge supports, pipe lines or other structures.

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e) Degradation may change the morphology of the river bed, which constitutes one aspect of the aquatic habitat.

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f) Degradation can deplete the entire depth of gravelly bed material, exposing other substrates that may underlie the gravel, which could in turn affect the quality of aquatic habitat. Lowering of ground water table in the flood plain because of lowering of riverbed level as well as river water level takes place because of extraction and draining out of excessive ground water from the adjacent areas. So, if a floodplain aquifer drains to the stream, groundwater levels can be lowered as a result of bed degradation.

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g) Lowering of the water table can destroy riparian vegetation.

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h) Excessive pumping of ground water in the process of mining in abandoned channels depletes ground water

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causing scarcity of irrigation and drinking water. In extreme cases it may create ground fissures and subsidence in adjacent areas.

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i) Flooding is reduced as bed elevations and flood heights decrease, reducing hazard for human occupancy of floodplains and the possibility of damage to engineering works.

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j) The supply of overbank sediments to floodplains is reduced as flood heights decrease.

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k) An un-scientific and unregulated sand and gravel mining tends to increase channel bank scouring and erosion. This causes a large degree of meandering of rivers and sometimes it could be in kms.

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l) Rapid bed degradation may induce bank collapse and erosion by increasing the heights of banks.

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m) Polluting ground water by reducing the thickness of the filter material especially if mining is taking place at top of recharge fissures.

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n) Choking of sand layer which acts as filter for ingress of ground water from river by dumping of finer material, compaction of filter zone due to movement of heavy vehicles. It also reduces the permeability and porosity of the filter material.

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o) Removal of gravel from bars may cause downstream bars to erode if they subsequently receive less bed material than is carried downstream from them by fluvial transport.

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p) Ecological effects on bird nesting, fish migration, angling, etc.

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q) Indiscrete mining activities lead to increased concentration of suspended sediment in the river which in turn causes siltation of water resources projects.

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r) Un-scientific and unregulated sand and gravel mining leads to the severe health hazards like air quality degradation and dust fog.

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s) Direct destruction from heavy equipment operation; discharges from equipment and refueling.

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t) Biosecurity and pest risks.

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u) Impacts on coastal processes.

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The other deleterious impacts of indiscrete mining include

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Loss of riparian habitat resulting from direct removal of vegetation along the stream bank to facilitate the use of a dragline or through the process of lowering the water table, bank

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undercutting, and channel incision. The physical composition and stability of substrates are altered as a result of instream mining and most of these physical effects may exacerbate sediment entrainment in the channel.

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Furthermore, the process of in-stream mining and gravel washing produces fine sediments under all flow conditions, resulting in a deposition of fine sediment in riffles as well as other habitats at low discharge. Excess sediment is considered the greatest pollutant in waters and constitutes one of the major environmental factors in the degradation of stream fisheries.

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However, in-stream mining may contribute additional sediment to downstream reaches due to the disruption of substrate stability. Once sediment enters the stream, it is best to let natural geomorphological and hydrological processes reach a dynamic equilibrium, rather than further exacerbating the situation by additional disturbance.”

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19. Thus, scientific and regulated mining is the need of the hour to protect the river ecology and environment.

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Enforcement and Monitoring Guidelines for Sand Mining 2020 :

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20. Taking note of the judgment of the Hon’ble Supreme Court in the matter of Deepak Kumar (supra) and the orders of the Tribunal dated 04.09.2018 in OA No. 173/2018 in the matter of Sudarsan Das v. State of West Bengal & Ors., order dated 05.09.2018 in OA No. 44/2016 in the matter of Mushtakeem Vs. MoEF & CC & Ors., order dated 10.09.2018 in OA No. 304/2015 in the matter of Jai Singh & Anr.Vs. Union of India Ors. and order dated 05.04.2019 in OA No. 360/2015 in the matter of National Green Tribunal Bar Association & Anr. vs. Union of India & Ors., the MoEF&CC has framed the Enforcement and Monitoring Guidelines for Sand Mining in January 2020 (EMGSM-2020). These guidelines do not substitute SSMG2016, but these guidelines supplement the existing guidelines. Therefore, they are being read and implemented in sync with each other. The EMGSM-2020 provide that in case any ambiguity or variation between the provision of both these document, the provisions made in the 2020 Guidelines will prevail. The EMGSM2020 contains the guidelines for preparation of the District Survey Report. It in clear terms provides that the District Survey Report for sand mining will be prepared before auction/e-auction/grant of the mining lease/Letter of Intent (LoI) by Mining department or department dealing the mining activity in respective States. It gives detailed guidelines for preparation of the DSR. The EMGSM-2020 contains the provision relating to the replenishment study, which are extracted as under:

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“ 5.0 REPLENISHMENT STUDY

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The need for replenishment study for river bed sand is required in order to nullify the adverse impacts arising due to excessing sand extraction. Mining within or near riverbed has a direct impact on the stream's physical characteristics, such as channel geometry, bed elevation, substratum composition and stability, in-stream

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roughness of the bed, flow velocity, discharge capacity, sediment transport capacity, turbidity, temperature etc. Alteration or modification of the above attributes may cause an impact on the ecological equilibrium of the riverine regime, disturbance in channel configuration and flow-paths. This may also cause an adverse impact on instream biota and riparian habitats. It is assumed that the riparian habitat disturbance is minimum if the replenishment is equal to excavation for a given stretch. Therefore, to minimize the adverse impact arising out of sand mining in a given river stretch, it is imperative to have a study of replenishment of material during the defined period.

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5.1 Generic Structure of Replenishment Study

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Initially replenishment study requires four surveys. The first survey needs to be carried out in the month of April for recording the level of mining lease before the monsoon. The second survey is at the time of closing of mines for monsoon season. This survey will provide the quantity of the material excavated before the offset of monsoon. The third survey needs to be carried out after the monsoon to know the quantum of material deposited/replenished in the mining lease. The fourth survey at the end of March to know the quantity of material excavated during the financial year. For the subsequent years, there will be a requirement of only three surveys. The results of year-wise surveys help the state government to establish the replenishment rate of the river. Based on the replenishment rate future auction may be planned.

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The replenishment period may vary on nature of the channel and season of deposition arising due to variation in the flow. Such period and season may vary on the geographical and precipitation characteristic of the region and requires to be defined by the local agencies preferable with the help of the Central Water Commission and Indian Meteorological Department. The excavation will, therefore, be limited to estimated replenishment estimated with consideration of other regulatory provisions.”

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21. It also provides for methodology for replenishment study in detail, including physical survey of the field by the conventional method, use of UAV/Drone and other image data processing techniques, accuracy assessment of Aerial Data and the details which the replenishment study should have. It also provides the enforcement mechanism.

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Standard Operating Procedure issued by SEAC, SEIAA and DGM, UP

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22. In the present case, for their own convenience, the Joint Committee of SEAC, SEIAA and DGM, UP had issued the Standard Operating Procedure (SOP) for preparation/modification of DSRs for sand mining or RBM by District Level Sub-Divisional Committee and its appraisal/approval by SEAC/SEIAA, UP. The said SOP provides the following procedure for preparation of DSR by respective districts of Uttar Pradesh:

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“Procedure for Preparation of DSR by respective District of Uttar Pradesh SL. No Details Action Required /Step

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1 Formation of Sub-Divisional Committee (SDC) in the district by District Magistrate comprising Sub-Divisional Magistrate, Officers from Irrigation Department, State Pollution Control Board or Committee. Forest Department, Geological or Mining Officer. Reference-Para 14(i) of the Hon'ble Supreme Court Judgement delivered in Civil Appeal- 3661-3662 of 2020 in the matter of State of Bihar and Others Vs. Pawan Kumar and Others Etc	• D.M. shall issue an Memorandum Office regarding nomination and formation of Sub- Divisional committee in the district.
. 2 Preparation of DSR - DSR which is a technical document shall be prepared in line with the MoEF&CC Notification, dated 15/01/20216. dated 25-July-2018 and ESMMG 2020. The contents of DRAFT DSR shall be as under:-	• The sub-divisional committee (SDC) will prepare the draft DSR. If required the SDC may take help/assistance of QCI/NABET
*Contents of Report:-* 1. Introduction	Consultants, DGM Approved Exploration
2. Overview of Mining Activity in the District (brief history of old working, pre-existing and proposed mining activities). 3. List of Mining Leases in the District with location, area and period of validity. 4. Details of Royalty or Revenue received in last three years.	Agencies as per Government Order ref. no 1659/86-2023 dated 17-May-2023 issued by Secretary Geology & Mining.
5. Detail of Production of Sand/Morrum/RBM or other minor mineral in last three years.	• Additionally, the SDC may also take
6. Process of deposition of sediments in the Rivers of the District (River Geometry). 7. General Profile of the District. 8. Land utilization Pattern in the district: Forest. Agriculture, Horticulture, Mining etc. 9. Physiography of the District. 10. Rainfall: month-wise.	help/assistance of renowned academic institutions/ Universities having domain expertise in Environment/ Geology and Mining.
11 Geolo and Mineral Wealth
. gy . 12. The report shall also contain:- a) District wise detail of river or stream	• It will be the responsibility of
and other sand source; b) District wise availability of sand or gravel or aggregate resources; c) District wise detail of existing mining leases of sand and aggregates. 13. Drainage system with description of main rivers	SDC/hired agency to collect primary and secondary data, DSR drafting with Annexure- 1 to Annexure-VII and conduct presentation before SEAC/SEIAA and
a) Name of the river. b A did k	DGM.
) rea rane (sq. m) c) Percentage area drained in the Dii	• Whenever a new lease is
strct. 14. Salient Features of Important Rivers and Streams:-	identified for adding in the DSR, the SDC/hired agency will follow the
a) Name of the river or stream. b) Total length in the district. (in Km.) c) Place of origin.	entire procedure every time on the basis of existing DSR. The
d) Altitude at origin. e) Portion of the river or stream recommended for mineral concession. f) Length of area recommended for mineral concession. (in Kms)	validity of amended or modified DSR will be upto the validity of the original DSR.
g) Average width of area recommended for mineral concession	• The SDC/hired agency will update the data in
(in meters) h) Area recommended for mineral	the revised DSR with
concession (in square meter)	reference to the primary

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i) Mineable mineral potential (in metric tonne) (60% of total mineral potential) 15. Mineral Potential:- a) Boulder (MT) b) Bajari (MT) c) Sand (MT) d) Total Mineable Mineral Potential (MT) 16. Annual Deposition:- a) River or Stream. b) Portion of the river or stream recommended for mineral concession. c) Length of area recommended for mineral concession.(in Kms) d) Average width of area recommended for mineral concession (in meters) e) Area recommended for mineral concession (in square meter) f) Mineable mineral potential (in metric tonne) (60% of total mineral potential) g) Total for the District • After this Annexure-l to Annexure-IV shall also be prepared as per the format provided in Enforcement & Monitoring Guidelines for Sand Mining-2020, which will be enclosed as annexure to the Draft DSR (Reference-Page-64 to 67 of EMGSM- 2020).	DSR. Special focus on collection of latest data will be done w.r.t. land use pattern, rainfall, IMD data, river geometry, updated geology (if any), water table, population data etc. as such parameters generally change in every 5 years. • The source of secondary data used in DSR should have proper citation reference and in case primary data has been collected, then the name and details of experts involved in collection and synthesis and interpretation of data will be mentioned in the DSR. • It should be specifically ensured that DSR is the district specific environmental document in which all the environmental and
• Lease wise NOC will be taken from Irrigation and Forest Department and Deposit Verification/Estimation reports shall also be prepared by SDC. • The proposed lease should clearly identify and mark the mineable deposit on satellite image/drone image. • The mineable resource is to be calculated based on field investigation, geology of the catchment area, site conditions locations, depth of mineral availability and other geomorphic features. The mineable resource should be 50 to 60% of the total ilbl	safety parameters as per the guidelines and notifications should be covered and reflected in the DSR document. • For this a district specific mineral resource map shall be prepared in which the drainage patterns of rivers along with explored mineral resources shall be reflected.
resource avaae. 3 Once the Draft DSR and Annexure 1 to IV is prepared, then all the SDC members evaluate and approve it, which will be uploaded in the District Website for 30 days for public comments/objections as well as DM/ADM/MO office. For this the notification should be issued by District Authority about draft DSR for suggestions/comments /objections from public in minimum two newspapers having wide circulation. Date of uploading and last date of receiving suggestions/comments/objections should be clearly mentioned in the notification. (Reference - EMGSM--2020, Para 4.1.1 (clause-O & P: Page-19)	For this a letter to the District Information Office will be issued for uploading the draft DSR in District Website for 30 days.

i) Mineable mineral potential (in metric
tonne) (60% of total mineral potential)
15. Mineral Potential:-
a) Boulder (MT)
b) Bajari (MT)
c) Sand (MT)
d) Total Mineable Mineral Potential
(MT)
16. Annual Deposition:-
a) River or Stream.
b) Portion of the river or stream
recommended for mineral concession.
c) Length of area recommended for
mineral concession.(in Kms)
d)
Average
width
of
area
recommended for mineral concession
(in meters)
e) Area recommended for mineral
concession (in square meter)
f) Mineable mineral potential (in metric
tonne) (60% of total mineral potential)
g) Total for the District
• After this Annexure-l to Annexure-IV shall
also be prepared as per the format
provided in Enforcement & Monitoring
Guidelines for Sand Mining-2020, which
will be enclosed as annexure to the Draft
DSR (Reference-Page-64 to 67 of EMGSM-
2020).

DSR. Special focus on
collection of latest data
will be done w.r.t. land
use
pattern,
rainfall,
IMD
data,
river
geometry,
updated
geology (if any), water
table, population data
etc. as such parameters
generally
change
in
every 5 years.
• The source of secondary
data used in DSR should
have
proper
citation
reference and in case
primary data has been
collected, then the name
and details of experts
involved
in
collection
and
synthesis
and
interpretation
of
data
will be mentioned in the
DSR.
• It should be specifically
ensured that DSR is the
district
specific
environmental document
in
which
all
the
environmental
and

• Lease wise NOC will be taken from
Irrigation and Forest Department and
Deposit Verification/Estimation reports
shall also be prepared by SDC.
• The proposed lease should clearly identify
and mark the mineable deposit on satellite
image/drone image.
• The mineable resource is to be calculated
based on field investigation, geology of the
catchment area, site conditions locations,
depth of mineral availability and other
geomorphic
features.
The
mineable
resource should be 50 to 60% of the total
ilbl

safety parameters as
per the guidelines and
notifications should be
covered and reflected in
the DSR document.
• For this a district specific
mineral resource map
shall be prepared in
which
the
drainage
patterns of rivers along
with explored mineral
resources
shall
be
reflected.

resource avaae.
3
Once the Draft DSR and Annexure 1 to IV is
prepared, then all the SDC members evaluate
and approve it, which will be uploaded in the
District Website for 30 days for public
comments/objections
as
well
as
DM/ADM/MO office.
For this the notification should be issued by
District Authority about draft DSR for
suggestions/comments
/objections
from
public in minimum two newspapers having
wide circulation. Date of uploading and last
date
of
receiving
suggestions/comments/objections should be
clearly mentioned in the notification.
(Reference - EMGSM--2020, Para 4.1.1
(clause-O & P: Page-19)

For this a letter to the
District Information Office
will be issued for uploading
the draft DSR in District
Website for 30 days.

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4	The Draft DSR shall be withdrawn from District Website after 30 days and SDC Members shall conduct a joint meeting to mitigate/resolve the public comments/objections received, if any. (Reference - EMGSM--2020, Para 4.1.1 (clause - p: Page-19) In case no objection/comments are received then Mining Officer will issue a Certificate that no comments/objections have been received in the period of uploading.	For this a joint meeting of SDC Members is required for final draft DSR examination /evaluation.
5	Thereafter, the draft DSR shall be finalized including Annexure-1 to Annexure-VII which will be signed by all SDC Members and then forwarded to D.M. for perusal and approval.	For this a recommendation of SDC Members is required who will finalize the draft DSR and forward it to the D.M.
6	• The DM shall forward the proposed DSR to SEAC for examination and approval. • The Member Secretary/Nodal Officer will forward it to DGM, U.P. for comments and suggestions. The SEAC will evaluate after getting the comments and suggestions of DGM. U.P. • The SEAC may invite a representative of DGM, U.P. to assist SEAC in appraisal of the draft DSR. • The SEAC will evaluate and recommend for approval of the draft DSR on the basis of SDC recommendations as well as DGM, U.P. comments/suggestions. • The SEIAA may approve the draft DSR on the basis of recommendations of SEAC. Reference (Para 141 & ii) of the Hon'ble Supreme Court Judgement delivered in Civil Appeal-3661-3662 of 2020 in the matter of State of Bihar and Others Vs. Pawan Kumar and Others Etc.)	• The DM of respective district shall send the draft DSR, along with following documents Following shall be the Annexures of the DM letter:- 1. Primary DSR which requires addition/modification. 2. Draft Modified/ Revised DSR Document. 3. Annexure-1 to VII. 4. Lease wise NOC from Irrigation and Forest Department. 5. Revenue report and resource evaluation/ reserve estimation. 6. Notification regarding the constitution of the SDC. 7. Minutes of the SDC about draft DSR 8. Office order for uploading the draft DSR in the district website for a period of 30 days along with newspaper notification. 9. Minutes of the SDC
		recommendingdraft DSR
7	• The SEAC shall examine the draft DSR within a period of 6 weeks and its report shall be forwarded to SEIAA. • The SEIAA on receipt of SEAC recommendation report shall consider the grant of approval of DSR within a period of 6 weeks. Reference (Para 14(1 & ii) of the Hon'ble Supreme Court Judgement delivered in Civil Appeal-3661-3662 of 2020 in the matter of State of Bihar and Others Vs. Pawan Kumar and Others etc.)	. The DSR being a public document after approval shall be signed with seal (in each page of DSR) by the competent authority of SEIAA and will be uploaded in the respective district portal within a week.

¶168

Relevant Judicial Pronouncements

¶169

23. The Hon’ble Supreme Court in the matter of State of Bihar & Ors. vs. Pawan Kumar & Ors ., reported in (2022) 2 SCC 348 has

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¶171

considered the issue of preparation of DSR through private consultants and has also taken note of the 2016 amendment in the EIA Notification and EMGSM-2020. The Hon’ble Supreme Court has emphasized the need for formation of the Sub-Divisional Committee for preparing the DSR and has expressed that when the EMGSM2020, SSMG-2016 and amendment to EIA notification provide for constitution of Sub-Divisional Committee of the officials of the State, there is no necessity of preparing the DSR through private consultants. The Hon’ble Supreme Court in this regard has held that:

¶172

“xxx …………………………….xxx………………………………….xxx

¶173

12. It could thus be seen that in accordance with the 2020 Guidelines, the DSR is required to be prepared before the auction/e-auction/grant of mining lease by Mining Department or Department dealing with mining activity in the respective States. It is further provided that the potential site for mining having its impact on the forest, protected area, habitation and bridges should be avoided. For this, a Sub-Divisional Committee is required to be formed which, after the site visit, is required to decide regarding the suitability of the sites for mining. The SubDivisional Committee is further required to record its reasons for selecting the mining lease in the patta land. Various details are required to be given in the annexures appended to the said policy.

¶174

13. It is further to be noted that Appendix X of the Notification dated 15-1-2016, issued by MoEF and CC also provides for composition of the Sub-Divisional Committee:

¶175

"A Sub-Divisional Committee comprising of Sub-Divisional Magistrate, Officers from Irrigation Department, State Pollution Control Board or Committee, Forest Department, Geology or Mining Officer shall visit each site for which environmental clearance has been applied for and make recommendation on suitability of site for mining or prohibition thereof."

¶176

14. It is to be noted that with the advent of modern technology, various technological gadgets like drones and satellite imaging, etc. can be used for identification of the potential sites and preparation of the DSR and also to check misuse and unauthorised mining.

¶177

15. We further find that when the 2020 Guidelines as well as the notification issued by MoEF and CC of 2016 itself provide for constitution of Sub-Divisional Committees comprising of the officers of the State Government from various Departments for identification of the potential sites for mining. there would be no necessity of the DSRs being prepared through private consultants as directed by the Tribunal in the impugned order. The Sub-Divisional Committee consists of various officers from Revenue Department, Irrigation Department, State Pollution Control Board, Forest Department and Geology and Mining Department of the State Government. They are better equipped to visit the sites and prepare the draft DSR for the

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¶179

district concerned. Apart from that, preparation of DSR through private consultants would also unnecessarily burden the public exchequer. We are therefore of the view that the direction in that regard issued by the Tribunal requires to be modified. We are further of the considered view that until the DSRs are finalised and granted approval by SEAC and SEIAA, it is appropriate that certain necessary arrangements are permitted so that the State can continue with legal mining activities. This apart from preventing illegal mining activities, would also ensure that the public exchequer is not deprived of its share in legalised mining.

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16. We therefore find it appropriate to substitute the directions issued by the Tribunal vide judgment and order dated 1410-2020¹, with the following directions:

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16.1. The exercise of preparation of DSR for the purpose of mining in the State of Bihar in all the districts shall be undertaken afresh. The draft DSRs shall be prepared by the Sub-Divisional Committees consisting of the SubDivisional Magistrate, Officers from Irrigation Department, State Pollution Control Board or Committee, Forest Department, Geological or Mining Officer. The same shall be prepared by undertaking site visits and also by using modern technology. The said draft DSRs shall be prepared within a period of 6 weeks from the date of this order. After the draft DSRs are prepared, the District Magistrate of the district concerned shall forward the same for examination and evaluation by SEAC. The same shall be examined by SEAC within a period of 6 weeks and its report shall be forwarded to SEIAA within the aforesaid period of 6 weeks from the receipt of it. SEIAA will thereafter consider the grant of approval to such DSRs within a period of 6 weeks from the receipt thereon.

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16.2. Needless to state that while preparing DSRs and the appraisal thereof by SEAC and SEIAA, it should be ensured that a strict adherence to the procedure and parameters laid down in the policy of January 2020 should be followed.

¶183

16.3. Until further orders, we permit the State Government to carry on mining activities through Bihar State Mining Corporation for which it may employ the services of the contractors. However, while doing so, the State Government shall ensure that all environmental concerns are taken care of and no damage is caused to the environment.”

¶184

24. In the matter of Union Territory of Jammu & Kashmir & Anr. vs. Raja Muzaffar Bhat & Ors. , reported in 2025 SCC OnLine SC 1789 , the Hon’ble Supreme Court has considered the need for replenishment study and had held that:

¶185

“xxx ……………………………….xxx……………………………….xxx

¶186

¶187

3. It is, therefore, compelling to hold that a DSR is valid and tenable only when a proper replenishment study is conducted.”

¶188

25. The Hon’ble Supreme Court in this case has considered in detail its 2016 amendment, SSMG-2016, EMGSM-2020 and while expressing the need for replenishment study for a valid DSR has held that:

¶189

“xxx ………………………..…….xxx………..…………………….xxx 26. As per the 2016 Guidelines, the preparation of DSR is essential for (i) identification of areas of aggradation/deposition where mining can be allowed, (ii) calculation of annual rate of replenishment, (iii) identifying ways of scientific and systematic mining, (iv) implementing safeguards in place to ensure the mining carried out is sustainable. The scope of the DSR should include detailed information for each district, covering rivers, streams, and other sand sources, along with the availability of sand, gravel, and aggregate resources. It must also provide data on existing mining leases for these materials. Additionally, the classification of mining areas should distinguish between sections of rivers, streams, and other sources that are suitable for sand and aggregate extraction and those where such activities are strictly prohibited. It is further provided that such survey document shall be prepared in the district based on direct and indirect benefits of mining and identification of the potential threats to the river/stream beds in the district.

¶190

26. In the above order, Hon’ble Supreme Court expressing the need for replenishment study before grant of environmental clearance had also observed that:

¶191

“xxx …………………………….xxx………………………………….xxx

¶192

30. Over the past two decades, environmental statutory and regulatory law in India has undergone significant evolution, particularly in response to the challenges posed by unregulated and unsustainable sand mining. Recognizing the adverse ecological impacts of such activities, successive legal and policy frameworks have progressively tightened the requirements for environmental compliance. In order to appreciate the present controversy, it was necessary to retrace the legal trajectory. Recently, this Court has discussed, in detail, the legal regime surrounding the preparation, nature, scope and importance of DSR in Gaurav Kumar (supra). However, the focal point for present discussion is the value that must be appended to replenishment study before EC is granted to mining operations.

¶193

31. Demand for construction-grade sand is growing at a tremendous rate and it is said that the world is expected to run out of this resource by 2050. Construction-grade sand, can be found in aquatic environments, such as rivers and is a provisioning ecosystem service. Even under controlled circumstances, the practice of extracting sand from the riverbed and banks impacts the environment. In the

¶194

¶195

physical environment, the primary effects are riverbed widening and lowering. In the biological environment, the overarching effect is a reduced biodiversity and stretches from the aquatic and shoreline flora and fauna to the whole floodplain area. Due to easy access, river sand and gravel have been used extensively in construction projects. Depending on the mining operation method as well as morphologic and hydraulic characteristics of the river, sand mining may cause bed and bank erosion or other negative consequences for the river eco-system. It is, therefore, necessary to conduct appropriate studies, including that of replenishment to explore sustainable and cost-effective methods for river mining.

¶196

32. Without a proper study of the existing position of the riverbed and its sustainability for further sand mining, grant of environmental clearances would be detrimental for the ecology. It has therefore been held that a detailed study leading to a preparation of the replenishment report is an integral part of the DSR. If the DSR becomes the foundation for consideration of an application for environmental clearance, then it is compelling to ensure replenishment studies are undertaken in advance and the report forms an integral part of the DSR.

¶197

33. In view of the existing legal regime that mandates preparation of replenishment report in a scientific manner and such a report forming an integral part of the District Survey Report, we hold that a District Survey Report without a proper replenishment study is equally untenable.”

¶198

27. The Hon’ble Supreme Court in the matter of State of Uttar Pradesh vs. Gaurav Kumar , reported in 2025 SCC Online SC 1069 has declared that valid and subsisting DSR is mandatory for grant of environmental clearance for sand mining by observing as under:

¶199

“20. Conclusion: Having considered the regulatory regime introduced from time to time, increasing the width as well as the depth of scrutiny before granting an environmental clearance for sand mining, we are of the opinion that there is a mandatory requirement of preparation of a DSR. The DSR shall form the basis for application of environmental clearance. It shall also be the basis for preparation of reports and also appraisal of the projects. Another important facet of DSR is that it shall be prepared for all the districts and the draft is to be placed in the public domain. There is a requirement for keeping a copy of DSR in Collectorate. It must also be posted on the district's website for 21 days. After comments are received, they shall be considered and if found correct, they will be incorporated in the final report. The final DSR will then be finalized within 6 months by the DEIAA. The lifetime of the report is five years. After five years the existing DSR will not be tenable and a new DSR will have to be prepared and finalized. The purpose and object of prescribing a lifetime of five years for subsistence of a DSR is for the reason that

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¶201

the position of ecology and the environment is rapidly changing and the position that exists five years back, may not subsist for later days. It is true that it might have changed even before the expiry of five years but a reasonable estimate, to work as a benchmark is a policy consideration. May be a precautionary principle, it is not only legal and valid but is also mandatory. It must be enforced strictly and with all vigor.

¶202

21. We conclude by holding that:

¶203

(i). A District Survey Report is a document of seminal importance as it enables informed decision making.

¶204

(ii). Preparation of a DSR as per the procedure prescribed for its preparation under Appendix X, read with para 7(iii)(a), is required to be followed meticulously.

¶205

(iii). A valid and a subsisting DSR alone can be the basis for an application for grant of EC. A draft DSR is untenable for grant of an EC.

¶206

(iv). Preparation of reports and appraisal of projects by DEIAA and DEAC shall be on the basis of a valid and a subsisting DSR.

¶207

(v). DEIAA and DEAC are recognized as the authorities fastened with the statutory duty of preparing the DSR every five years and this duty compels them to have a comprehensive and a real time perspective of the environment position of the district including its ecosensitivity and other fragilities.”

¶208

28. Thus, it is settled that preparation of DSR is essential and mandatory for granting lease for sand mining in a district and for preparation of the DSR, replenishment study is essential.”

¶209

In the judgments noted and quoted above following issues have been settled:

¶210

(i) A district survey report is a document of seminal importance as it enables informed decision making ( State of UP & Anr. vs. Gaurav Kumar & Ors. , (supra)).

¶211

(ii) The draft DSR is to be prepared by the Sub-Divisional Committee by undertaking the site visit and also by using modern technology ( State of Bihar & Ors. vs. Pawan Kumar & Ors , (supra)).

¶212

(iii) A DSR is valid and tenable only when a proper replenishment study is conducted ( Union Territory of Jammu & Kashmir & Anr. vs. Raja Muzaffar Bhat & Ors. , (supra)).

¶213

¶214

(iv) A detailed study leading to the preparation of the replenishment report is an integral part of the DSR. It is necessary to ensure that replenishment studies are undertaken in advance and the report forms an integral part of the DSR ( UT of J&K vs . Raja Muzaffar Bhat , (supra)).

¶215

(v) A district survey report without a proper replenishment study is untenable ( UT of J&K vs. Raja Muzaffar Bhat , (supra)).

¶216

(vi) A district survey report is to be prepared by meticulously following the procedure prescribed under Appendix-X read with paragraph 7(iii)(a) ( State of UP & Anr. vs. Gaurav Kumar & Ors. , (supra)).

¶217

(vii) District Environment Impact Assessment Authority (DEIAA) and District Expert Appraisal Committee (DEAC) are the authorities fastened with the statutory duty of preparing the DSR every five years ( State of UP & Anr. vs. Gaurav Kumar & Ors. , (supra)).

¶218

Hon’ble Supreme Court in the matter of Raja Muzaffar Bhat (supra) has already settled that a DSR is valid and tenable only when a proper replenishment study is conducted. The Hon’ble Supreme Court has also observed in paragraph 32 of this judgment that without a proper study of the existing position of riverbed and its sustainability for further sand mining, grant of environmental clearances would be detrimental to the ecology. Therefore, a detailed study leading to preparation of a replenishment report forms integral part of DSR. It has further been held that if the DSR becomes foundation for consideration of an application for environmental clearance, then it is compelling to ensure replenishment studies are undertaken in advance and the report forms an integral part of the DSR.

¶219

¶220

Scanning the case in present OAs on merits :

¶221

In the present case, the replenishment study was conducted and “pre-monsoon replenishment study and reserved estimation report of RBM mining leases- District Saharanpur (study period – pre-monsoon-2022)” has been placed on record as Annexure R-1 to the additional affidavit of the District Magistrate, Saharanpur dated 11.09.2025 filed in OA No. 119/2025. It is a detailed replenishment study report running in atleast six volumes. This replenishment study report does not bear any date. The details of manner of preparation of the replenishment study have been disclosed in the affidavit of the District Magistrate, Saharanpur dated 06.05.2025 filed in OA No. 119/2025 as under:

¶222

“xxx …………………………..………..xxx…………………….……………xxx

¶223

11. That in compliance with the Enforcement & Monitoring Guidelines for Sand Mining-2020, the Sustainable Sand Mining Management Guidelines 2016, and the notifications issued on 15.01.2016 and 25.07.2018, as well as the order passed by the Hon'ble Supreme Court, a Sub-Divisional Committee (SDC) was constituted by the deponent on 02.05.2022 to conduct Replenishment Study for preparation of DSR. A copy of formation of the Sub Divisional Committee is annexed herewith and marked as Annexure R-2.

¶224

12. That the Sub-Divisional Committee includes the following members: Additional District Magistrate (Revenue/Administration) of Saharanpur, Sub-Divisional Magistrate, DFO (Shivalik Range, Saharanpur) from the Forest Department, Executive Engineer from the Irrigation Department, Executive Engineer from the PWD Department, Regional Officer from the Pollution Control Department, and Mining Officer from the Mining Department, Saharanpur.

¶225

13. That the updated DSR which was duly prepared by the Sub Divisional Committee was forwarded on 18.01.2023 to the Special Secretary Geology and Mining and Director, Geology and Mining Department State of UP.”

¶226

A perusal of the record reveals that replenishment study report has been prepared by M/s. GreencIndia Consulting Pvt. Ltd., a QCI/NABET Accredited Origination under Mining Sector-1(a) as per the MoEF&CC schedule. It has been prepared under the supervision of the Sub-Divisional Committee – District Saharanpur. This report has been duly signed by the members of the Sub-Divisional Committee.

¶227

¶228

The main issue is if this replenishment study report formed the basis of draft DSR and was placed before the SEAC and SEIAA while approving the impugned DSR of District Saharanpur. The SEAC-1 and SEAC-2, UP in their joint meeting held on 03.05.2024 had recommended for approval of the DSR of District Saharanpur. The minutes of the joint meeting of SEAC-1 and SEAC-2, UP held on 03.05.2024 are reproduced below:

¶229

“ Minutes of the Joint Meeting of SEAC -1 and SEAC-2, U.P. held on 03/05/2024

¶230

The Joint Meeting of State Expert Appraisal Committee (SEAC – 1 & 2) was held in Directorate of Environment, U.P. on 03/05/2024, following members were in the meeting:

¶231

1. Shri Rajive Kumar, Chairman, SEAC-1

¶232

2. Dr. Harikesh Bahadur Singh, Chairman, SEAC-2

¶233

3. Shri Ashish Tiwari, Member-Secretary, SEAC - 1 & 2

¶234

4. Dr. Ajai Mishra, Member, SEAC-1

¶235

5. Shri Om Prakash Srivastava, Member, SEAC-1

¶236

6. Shri Umesh Chand Sharma, Member, SEAC-1

¶237

7. Dr. Ratan Kar, Member, SEAC-1

¶238

8. Dr. Brij Bihari Awasthi, Member, SEAC-1

¶239

9. Dr. Amrit Lal Haldar, Member, SEAC-2

¶240

10. Shri Tanzar Ullah Khan, Member, SEAC-2 11. Prof. Jaswant Singh, Member, SEAC-2

¶241

12. Dr. Shiv Om Singh, Member, SEAC-2

¶242

13. Shri Subhash Singh, Mining Officer, Saharanpur

¶243

14. Shri Deveshwar Kain Senior Assistant, Mining Office, Saharanpur 15. Shri Vimlesh Jaiswal, DGM, Lucknow

¶244

16. Dr, Anju Verma , DGM, Lucknow

¶245

The Nodal Officers welcomed the Chairman’s, Members and Officers of Mining Department in the meeting which was conducted via dualmode (virtually/physically).

¶246

In the Joint committee meeting of SEAC-1 and SEAC-2 following agenda were discussed and resolved:-

¶247

Agenda: - Evaluation/Appraisal of District Survey Report (DSR) of District Saharanpur .

¶248

Background :

¶249

In the joint meeting of SEIAA, SEAC-1 & SEAC-2 the detailed Standard Operating Procedure was formulated for the preparation and modification of D.S.R. for Sand Mining or R.B.M., as well as in-situ rocks, which was send to Director, Geology and Mining by SEIAA. This SoP was prepared in accordance with various guidelines such as MoEF&CC, GoI, Notification No. S.O. 141(E) dated 15-Jan-2016, S.O. 3611 (E) dated 25-July-2018, Sustainable Sand Mining Management Guidelines 2016, Enforcement & Monitoring Guidelines for Sand Mining 2020, and the Hon’ble Supreme Court Judgement passed in Civil Appeal – 3661-3662 of 2020 in the matter of State of Bihar and

¶250

¶251

Others Vrs. Pawan Kumar, along with MoEF&CC, GoI letter dated 04/12/2023.

¶252

The District Magistrate, Saharanpur submitted the draft DSR vide its letter no. 2613/kha anu/DSR/2023-24, dated 18/12/2023 for evaluation /appraisal/approval before SEIAA/SEAC. The draft DSR was forwarded to the Director – Geology & Mining by Secretariat for comments and suggestions. The Director, Geology & Mining has provided his comments and suggestions vide letter no. 85/DSR, dated 19/04/2024 and mentioned as follows:

¶253

".... उत्तर प्रदेश शासन द्वारा गठित तकनीकी समिमत एवं मनदेशालय स्तर पर गठित समिमत द्वारा जनपद सहारनपुर द्वारा प्रस्तुत ड्राफ्ट डी०एस०आर० का परीक्षण ठकया गया। परीक्षण िें प्रस्ताव Sustainable Sand Mining Management Guideline-2016, पयाावरण वन एवं जलवायु पररवतान िंत्रालय की अमिसूचना ठदनांक 15-01-2016 एवं ठदनांक 25-4-2018 Enforcement and Monitoring Guidelines for Sand Mining -2020 एवं SEIAA/SEAC द्वारा जारी SOP के अनुरूप पाया गया...."

¶254

The Secretariat put up this DSR in joint meeting of SEAC-1 & SEAC-2 in dated 03/05/2024. During the meeting a presentation was given by Shri Subhash Singh, Mining Officer along with other senior officers of DGM.

¶255

Evaluation/Appraisal in Joint Meeting of SEAC-1 & SEAC-2 on 03/05/2024

¶256

Joint meeting of SEAC-1 & SEAC-2 was convened on 03/05/2024 for evaluation/appraisal of DSR of District-Saharanpur. Based on the documents submitted, a presentation on DSR Saharanpur for minor mineral River Bed Material - RBM (Sand/Bajri/Boulder) / Sand Mining-2022 was made by Shri Subhash Singh, District Mining OfficerSaharanpur along with Senior Officials of D.G.M. -UP.

¶257

Para wise response and compliance as per the "Standard Operating Procedure" formulated by the Joint committee of SEAC/SEIAA was presented before the SEAC-1&2. On the basis of documents and presentation the following facts have emerged:-

¶258

1. The initial District Survey Report of District-Saharanpur having 37 areas was prepared in Year-2017 in line with the MoEF Notification dated 15-Jan-2016.

¶259

2. Thereafter the updated DSR of District-Saharanpur was prepared by Sub-Divisional Committee of District-Saharanpur in Year-2022 and total 22 areas have been proposed.

¶260

3. It was informed that out of 22 areas in the updated DSR, NOC for 01 area (Village - Rahena, Lot No-3, area 8.050 ha.) has not been provided by Forest Department. Accordingly, the revised DSR Saharanpur now has total 21 Areas. Lease wise area, gata/khand no., proposed minable quantity, geo-coordinates are proposed in Annexure-1 to Annexure-7 of proposed DSR.

¶261

¶262

4. As per the information provided vide District Magistrate, Saharanpur letter no. 3154/kha anu/DSR/2023-24, dated 28/03/2024 the DSR was uploaded in public domain for more than 30 days and 03 complaints were received in this period and 01 PIL was filed by the complainant. The details of complaint and its disposal is narrated as under:-

¶263

*SL.* No	*Complaint/PIL details*	*Details of* *reply/disposal*
1	Shri Daljeet Singh of Yamunanagar Haryana vide letter dated 18.01.2022 submitted 20 points complaint letter on issues related to revision of DSR in 5 years, wrong process of e-tender, non compliance of Hon’ble Supreme Court order in Deepak Kumars Vs State of Haryana, separate DSR for each minor mineral required, non- compliance of formats, non- compliance of Hon’ble Supreme Court order in The State of Bihar Vs Pawan Kumar, Cluster Analysis, requirement of replenishment studies and stake holding of DSR with adjoining district in case of inter-state/inter-district boundaries.	The District Magistrate vide letter no. 2016/Kha Anu/ShikayatDSR2022- 2023 dated 27/02/2023 responded point wise reply and compliances to Shri Daljeet Singh of Yamunanagar Haryana as per the comments provided by SubDivisional Committee and disposed the complaint.
2	Shri Gaurav Kumar of Yamunanagar Haryana vide letter dated 25.01.2022 submitted 19 points complaint letter and the issues were identical as mentioned in Sl. No.1	The District Magistrate vide letter no. 2017/Kha Anu/ShikayatDSR2022- 2023 dated 27/02/2023 responded point wise reply and compliances to Shri Gaurav Kumar of Yamunanagar Haryana as per the comments provided by Sub- Divisional Committee and disposed the complaint.
3	Shri Sumit Singh Rana of Yamunanagar Haryana submitted 14 points complaint letter and the issues were identical as mentioned in Sl. No.1. Apart from this various NGT orders specific to DSR and Sand Mining were cited in the complaint letter.	The District Magistrate vide letter no. 2064/Kha Anu/ShikayatDSR2022- 2023 dated 03/03/2023 responded point wise reply and compliances to Shri Gaurav Kumar of Yamunanagar Haryana and disposed the complaint.
4	Civil Writ PIL no. 595/2023 Sumit Singh Rana Vs State of U.P and Ors.	The Hon’ble High Court vide order date 28/03/2023 dismissed the petition of Shri Sumit Singh Rana.

¶264

¶265

The operative para of the
same is as under:- “At
this stage, in this
circumstances,
interference claimed
under Article 226 of the
Constitution of India is
declined. Present
petition is accordingly
dismissed, leaving it
open to the petitioner to
approach National
_Green Tribunal” _

¶266

5. The Updated DSR of District-Saharanpur has been also examined by the Director, Directorate of Geology & Mining, U.P.

¶267

6. Lease wise NOC from Forest and Irrigation Department for 21 areas has been obtained for existing and proposed leases.

¶268

SEAC Deliberation :

¶269

1. SEAC asked about the current scenario/status of the leases as DSR was updated in year 2022?

¶270

District Mining Officer, Saharanpur vide letter dated 03/05/2024 informed the DSR of district Saharanpur was prepared in year-2022 after conducting replenishment studies in which the reserves were calculated on the basis of replenishment in the post-monsoon – 2022 scenario. Lease wise replenishment studies were also conducted in year – 2023 which depicts that the rate of replenishment is good in the area. Geologically the area is part of shivalik region and there is no significant change in the formation of leases. The leases are getting over replenished and requires removal of deposits to maintain channel of river. The maximum leases are fresh for which LoI has been issued to project proponents who are in the process of securing E.C.

¶271

2. SEAC asked about the status of utilization of DMF Funds?

¶272

District Mining Officer Saharanpur informed that funds amounting to Rs. 9.32 Crores approx. have been allotted and phase wise utilized since 2017 from DMF funds which were used as per the objectives of DMF Rules.

¶273

3. SEAC while evaluating presentation suggested that lease should be demarcated after each monsoon period .

¶274

District Mining Officer Saharanpur informed that as a matter of practice the lease holders are directed to get demarcation of lease after each monsoon period and erect pillars (in case damaged in monsoon) under the supervision of Mining and Revenue officials. A demarcation report in this aspect is prepared and issued to lease holder.

¶275

4. SEAC suggested that composite digital mapping of all the leases should be done and displayed in the district website .

¶276

¶277

District Mining Officer Saharanpur informed that mapping of lease has been done in SOI toposheet, Drainage pattern sheet, Google satellite images and cadastral revenue maps. It was informed that the concept of uploading composite digital mapping of all the leases shall be implemented and uploaded in district web site along with approval of DSR of SEIAA/SEAC.

¶278

5. SEAC asked on the method adopted for verification of mineral deposits which are recommended in DSR?

¶279

District Mining Officer Saharanpur informed that pre and post monsoon replenishment studies were conducted by SubDivisional committee prior preparing DSR. The studies included physical survey, DGPS survey and Drone based survey in pre and post monsoon periods. Accordingly lease wise recommendation reports were made as compliances.

¶280

6. SEAC suggested that demarcation report of the lease only includes corner pillar coordinates and should also mention details of non-working/restricted zone in case active water channel is observed in the lease while conducting demarcation?

¶281

District Mining Officer Saharanpur informed that as per the Rule of UPMMCR-2021, geo-coordinates of the lease area are published in e-tender and initial demarcation report of corner pillar coordinates is issued to project proponent along with LoI and Lease Map. The RQP/Consultant prepares the surface and geological maps in mine plan in which the features of nonworking/restricted zone is presented. The DGM Lucknow after satisfaction approves such mine plans and such zones are shown in EIA and salient features of E.C. under workable / nonworkable area category.

¶282

7. SEAC asked about the further mineral development in district Saharanpur?

¶283

Shri Deveshwar Kain, Senior Assistant, Mining Office, Saharanpur informed that three new areas has been identified in the district which has mineral potential. The SEAC informed that Sub-Divisional Committee has to follow the entire procedure every time, in case any new lease is identified, as per SOP issued by SEIAA/SEAC.

¶284

The joint committee after detailed deliberation recommended to approve the District Survey Report (DSR) of District-Saharanpur along with following conditions :

¶285

1. The period of validity of Revised DSR Saharanpur-2022 shall be for the remaining balance period of 03 years from the date of its approval.

¶286

2. The submitted DSR has 22 areas. NOC for 01 area (Village – Rahena, Lot No-3, area 8.050 ha.) has not been provided by Forest Department. Accordingly, approval of only 21 areas (except Village – Rahena, Lot No-3, area 8.050 ha.) is recommended in the revised DSR Saharanpur.

¶287

¶288

3. If any new lease is identified, its validity will be co-terminous with the validity period of current DSR and Sub-Divisional Committee will follow the entire procedure every time on the basis of existing DSR.

¶289

4. After approval of DSR from SEIAA, the District Administration shall upload the DSR in public domain along with Lease Wise Digital Maps showing the status of deposits and pillar wise coordinates of existing and proposed areas.

¶290

5. The District Administration shall utilize the District Mineral Foundation Funds as per notification no. 866/86-2017-132/2016 dated 15/05/2017 issued by Department of Geology and Mining, Government of U.P. or any modification in it by competent authority.

¶291

6. The District Administration shall periodically conduct audits of operative mine leases using drone based survey and take corrective measures in case of adverse observations and a quarterly report on this shall be send to SEIAA as compliance.

¶292

The meeting ended with a vote of thanks of Chairman.”

¶293

In the above minutes of the joint meeting of SEAC-1 and SEAC-2, UP, the draft DSR of District Saharanpur placed before the SEIAA and SEAC vide letter dated 18.12.2023 was examined. The minutes of the meeting record that the DSR was uploaded in public domain and the objections/complaints were considered. But the minutes of the meeting do not indicate that a copy of the replenishment study report was placed in the joint meeting of the SEAC. Under the SEAC deliberation, only mention is that the District Mining Officer, Saharanpur had “informed” that the DSR of District Saharanpur was prepared in the year 2022 calculating the reserve on the basis of replenishment in the post monsoon, 2022 scenario and that Mining Officer had “informed” that pre and post monsoon studies were conducted by SDC. The approval to the DSR could have been granted by the SEAC after comparing and analysing the details of availability of mineral and permissible mining, lease area, etc. disclosed in the DSR in the light of the details gathered and recorded in the replenishment study, but no such exercise appears to have been done in the joint meeting of SEAC. The minutes of the meeting do not even mention that the replenishment study report was placed before SEAC or it was examined by

¶294

¶295

the SEAC. If the District Mining Officer had merely informed SEAC that the DSR was prepared after conducting the replenishment study, that is not enough.

¶296

The SEIAA, UP in its 814^th meeting held on 24.05.2024 had approved the DSR of District Saharanpur. These minutes of meeting have been placed on record as Annexure A-7 alongwith OA No. 134/2025 which are reproduced below:

¶297

“Minutes of the 814^th Meeting of the State Level Environment Impact Assessment Authority, UP (SEIAA) held on 24-05-2024

¶298

The meeting of 814^th State Level Environment Impact Assessment Authority, UP (SEIAA) was held on-line on 24.05.2024 the Directorate of Environment. The following were present in the meeting:-

¶299

1. Smt. Mamta Sanjeev Dubey Chairman, SEIAA, U.P

¶300

2. Shri Paras Nath Member, SEIAA, U.P 3. Shri Sanjeev Kumar Singh Member Secretary, SEIAA, U.P

¶301

Agenda-A

¶302

1. District Survey Report of Saharanpur .

¶303

SEIAA agreed with the recommendation of SEAC to approve the District Survey Report (DSR) of District-Saharanpur along with following conditions:-

¶304

1. Mining Department, UP is advised to develop a mechanism for issuing online Lol.

¶305

2. As per MoEFCC notification S. O. 141(E) dated 15.01.2016- The District Survey Report shall be prepared for each minor mineral in the district separately. Hence, DSR for each minor mineral should be submitted separately.

¶306

3. The study for mineral availability and its finding should be uploaded on District website.

¶307

4. SEIAA noted that in draft DSR unit of quantity is not similar, like under list of potential mining lease (existing and proposed) rivers and cluster and contiguous detail, total excavation is given in MT/Year whereas in final list of cluster geological reserve is given in cubic meter, hence a clarification must be submitted and it should be same as given in Lol.”

¶308

The above minute of meeting also do not indicate that the replenishment study report was placed before SEAC, UP or SEIAA, UP and

¶309

they had applied their mind to the facts and figures disclosed in

¶310

¶311

replenishment study report while approving the DSR of District Saharanpur. The above minutes in fact indicate that SEIAA, UP had noted certain discrepancies in the draft DSR in respect of unit of quantity and had sought a clarification. SEIAA should not have approved the DSR without getting the requisite clarification and without considering the replenishment study.

¶312

Though SEIAA, UP in its reply dated 11.11.2025 filed in OA No. 119/2025 in paragraphs 13 and 14 has stated that in compliance of Para 4.1.1(a) of the EMGSM, 2020, the replenishment study was conducted for pre and post monsoon period of 2023 and was uploaded on the official District Mining Portal, but the Applicant has filed Annexure A1/12 in OA No. 247/2025 to show that the pre and post monsoon replenishment study of 2023 was uploaded on 09.04.2025 much after the approval of the DSR by SEIAA on 24.05.2024.

¶313

It is also worth noting that the issue of approval of the DSR in different districts of Uttar Pradesh without furnishing the replenishment study came up in 876^th joint meeting of SEIAA, UP and SEAC-1 and SEAC2 held on 06.03.2025 wherein a decision was taken to put all the DSRs in abeyance until submission of replenishment study for each DSR. The minutes of these joint meeting dated 06.03.2025 are extracted below:

¶314

“ Joint Meeting Minutes of State Level Environment Impact Assessment Authority, U.P. (876^th SEIAA Meeting) & State Level Expert Appraisal Committee-1&2. U.P. held on 06/03/2025

¶315

xxx ……………………………….….xxx………………………………….xxx

¶316

7. SEIAA/SEAC understands that the submission of Replenishment Study reports is an essential requirement for preparation of DSRs in sand mining projects. It has repeatedly directed the Mining Department to furnish the necessary replenishment studies. Despite sustained efforts and ongoing communication, the required information has not been received from the Mining Department till date.

¶317

8. Acknowledging the critical importance of Replenishment Studies and non compliance of assurance given by Geology and Mining

¶318

¶319

Department, State Uttar Pradesh and concerned District Authorities, SEIAA/SEAC, after thorough discussions, has decided to keep all previously approved DSRs in abeyance until compliance with this requirement is ensured.

¶320

Accordingly, it has been decided to issue a formal communication to the Directorate of Geology and Mining, Uttar Pradesh, informing them of the decision regarding putting all DSRs in abeyance until submission of replenishment study for each DSR. Further, SEIAA directs that copies of this communication be sent to the Chief Secretary, Government of Uttar Pradesh; the Principal Secretary, Department of Environment, Forest and Climate Change, Government of Uttar Pradesh; the Principal Secretary/Secretary, Department of Geology and Mining. Government of Uttar Pradesh and Director of Geology and Mining for their information and necessary action. It was also decided that suitable instructions shall be sent to the counsel of SEIAA to apprise Hon'ble NGT accordingly.”

¶321

No details of subsequent development have been placed on record, but it appears that subsequently the DSR of District Saharanpur was made operative and further e-auction notices dated 26.05.2025, 05.06.2025 and 07.08.2025 were issued.

¶322

Above analysis reveals that the replenishment study report which forms the basis of DSR was not placed before the SEAC or SEIAA at the stage of examination and approval of the DSR of District Saharanpur.

¶323

In the similar circumstances by the order dated 27.05.2026 passed in OA No. 9/2025 in the matter of Vinay Shrivastav vs. State of Uttar Pradesh Through the Chief Secretary where the District Survey Report of District Hamirpur, Uttar Pradesh was approved by SEAC and SEIAA without placing the full replenishment study report, the Tribunal has directed the reappraisal of the DSR by SEAC and SEIAA by observing as under:

¶324

“49. Once it is settled that proper replenishment study is prerequisite for a valid and tenable DSR and that a detailed study leading to preparation of the replenishment report is an integral part of the DSR, it is mandatory to ensure that replenishment study is done in advance and report forms an integral part of the DSR. It is necessary for the purpose of having full transparency to upload the replenishment study while putting the draft DSR in public domain so that full particulars on the basis of which the DSR was prepared are available to the potential objector to raise objection to the draft DSR.

¶325

¶326

50. The District Survey Report is held to be a document of seminal importance. Therefore, it should be thoroughly examined by the SEAC and SEIAA after due deliberation and proper application of mind. The DSR cannot be approved by SEAC or SEIAA hurriedly in a mechanical manner.

¶327

51. In the present matter, though it has been stated before the Tribunal that the relevant contents of the replenishment study were placed before the SEIAA, but it is apparent that the full replenishment study of District Hamirpur was not placed before SEIAA, UP. Therefore, we are of the view that SEAC and SEIAA, UP should reappraise the impugned DSR after deliberating upon the replenishment study report. We do not deem it proper to set aside the impugned DSR on the ground of not placing the replenishment study before the SEAC and SEIAA at the time of approval of DSR, as it has been pointed out that the relevant contents of the replenishment study were placed before SEIAA and the judgment of the Hon’ble Supreme Court in the matter of Raja Muzaffar Bhat (supra) holding that the replenishment study forms an integral part of the DSR is subsequent to the approval of the impugned DSR by SEAC and SEIAA, UP.”

¶328

The present case also stands on the same footing, therefore, in this matter also the SEAC and SEIAA, UP are required to reappraise the impugned DSR of District Saharanpur after deliberating upon the replenishment study report.

¶329

Directions:

¶330

Hence, we dispose of the OAs directing as under:

¶331

(1). The SEAC and SEIAA, UP will reappraise the District Survey Report of District Saharanpur after deliberating upon the replenishment study report and ascertaining that the DSR has been properly prepared in terms of the Sustainable Sand Mining and Management Guidelines, 2016 and Enforcement and Monitoring Guidelines for Sand Mining, 2020.

¶332

(2). While reappraising the DSR, the SEAC and SEIAA, UP will specifically examine the issue of compliance of the provisions contained in Clause 4.1.1 (b), (c), (d), (e), (g), (h), (j), (k), (n) & (o) of the Enforcement and Monitoring Guidelines for Sand Mining, 2020.

¶333

¶334

(3). The sustainability of the impugned NITs and further action on the basis of the impugned NITs will depend upon the final outcome of the reappraisal of the DSR of District Saharanpur by SEAC and SEIAA, UP.

¶335

(4). The SEIAA, UP at the time of reappraisal of the DSR will apply its mind to each of the above directions and reflect upon it in the minutes of the meeting.

¶336

(5). The above exercise of reappraisal of the DSR will be done by SEAC and SEIAA, UP expeditiously.

¶337

The O.A’s are accordingly disposed of. All the pending I.A’s, if any, also stand disposed of.

¶338

Prakash Shrivastava, CP

¶339

Dr. Afroz Ahmad, EM

¶340

August 31, 2026 Original Application No. 1345/2024 (IA No 624/2024 & IA No 625/2024) and connected matters dv

¶341

Kapil Chauhan v. State of Uttar Pradesh through Its Chief Secretary

Case brief

What is this about?

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Kapil Chauhan v. State of Uttar Pradesh through Its Chief Secretary

Case brief

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