Facts: The State of Tamil Nadu filed a suit against the State of Karnataka and the Union of India, invoking the Supreme Court's original jurisdiction under Article 131 of the Constitution. Tamil Nadu sought a declaration that Karnataka's unilateral construction of check dams and diversion structures across the Pennaiyar River and its tributaries, without Tamil Nadu's prior consent, was illegal and violated the fundamental rights of its inhabitants. Tamil Nadu also sought injunctions to restrain further construction and to ensure the natural flow of water. The dispute arose from Karnataka's decision to undertake five distinct works in the Pennaiyar River Basin, which Tamil Nadu alleged would interfere with the river's natural flow and adversely impact its water requirements. An agreement of 1892 existed between the erstwhile States of Madras and Mysore regarding the use, control, and distribution of waters of the inter-State River.
Procedural Posture: The case originated as an Original Suit in the Supreme Court of India. During the suit's pendency, Tamil Nadu filed an interlocutory application seeking interim directions, which the Court dismissed. Tamil Nadu then lodged a complaint under Section 3 of the Inter-State River Water Disputes Act, 1956, requesting the Central Government to constitute a Tribunal. Negotiations at the ministerial level failed to yield an amicable resolution.
Issue: Given the failure of negotiations between the States of Tamil Nadu and Karnataka regarding the Pennaiyar River water dispute, is the Central Government obligated to constitute a Water Disputes Tribunal for adjudication of the dispute?
Holding: Yes, the Supreme Court held that the Central Government is obligated to constitute a Water Disputes Tribunal for the adjudication of the inter-State water dispute between Tamil Nadu and Karnataka concerning the Pennaiyar River.
Reasoning: The Court noted that multiple efforts to reach an amicable resolution had failed. Referring to its earlier judgment in T.N. Cauvery Neerppasana Vilaiporulgal Vivasayigal Nala Urimai Padhugappa Sangam v. Union of India, the Court reiterated that where statutorily prescribed negotiations under the aegis of the Central Government fail to resolve an inter-State river water dispute, it becomes imperative for the Central Government to constitute a River Water Disputes Tribunal. The Court emphasized that Section 4 of the Inter-State River Water Disputes Act, 1956, mandates the constitution of a Tribunal if the Central Government is of the opinion that the water dispute cannot be settled by negotiation. The Court directed the Central Government to issue a notification in the Official Gazette and constitute a Water Disputes Tribunal within one month. The suit was disposed of, keeping all questions relating to reliefs open for consideration by the Tribunal.