Facts: The Respondent No. 9, a cement company, purchased approximately 47.82 acres of land in Sangrur, Punjab, to establish a cement grinding unit. On 13.12.2021, the Punjab Bureau of Investment Promotion issued a Change of Land Use (CLU) in favor of the company, followed by a No Objection Certificate from the pollution control board. Local agriculturists and a nearby school challenged these approvals, contending that the site was located in a rural agricultural zone under the notified Master Plan, where "red category" industries were prohibited. During the pendency of the appeals, the Central Pollution Control Board (CPCB) reclassified standalone cement grinding units from "Red" to "Orange" category and relaxed siting norms via new notifications, which were subsequently challenged via writ petitions under Article 32.
Procedural Posture: The High Court of Punjab and Haryana dismissed the original writ petitions, holding that a subsequent approval by the Planning Board on 05.01.2022 cured the initial lack of statutory backing for the CLU. The Appellants approached the Supreme Court via Special Leave Petitions. Additionally, independent Writ Petitions were filed in the Supreme Court to challenge the 2025 CPCB reclassification and MoEF&CC notifications.
Issue: 1. Can a CLU be validly granted if it contradicts the operative Master Plan? 2. Can subsequent administrative approval retrospectively cure a jurisdictional defect in a CLU? 3. Can the CPCB reclassify industrial sectors and relax siting safeguards in a manner that dilutes environmental protections under Articles 14 and 21 of the Constitution?
Holding: 1. No, a CLU cannot override the Master Plan. 2. No, minutes of a meeting cannot substitute the statutory procedure for amending a Master Plan. 3. No, regulatory reclassification that dilutes preventive safeguards without scientific justification is unconstitutional.
Reasoning: The Court reasoned that a Master Plan is a statutory instrument with binding force, not a mere policy guide; any alteration must follow the transparent procedure of public notice and gazette publication prescribed under Sections 70, 75, and 76 of the PRTPD Act. A CLU granted in violation of the Plan is a jurisdictional nullity that cannot be "cured" by ex post facto internal approvals. Regarding environmental law, the Court applied the "Precautionary Principle", stating that while technical classification is the domain of experts, any dilution of safeguards affecting life and health attracts constitutional scrutiny. The 2025 reclassification failed to demonstrate that the actual pollution risks had diminished, thus violating the right to a healthy environment under Article 21.