Supreme Court Holds NGT Cannot Abdicate Adjudicatory Functions to Committees and Must Follow Natural Justice
Case Name: Indian Oil Corporation Ltd. v. Deepak Sharma and Others
Citation: 2026 INSC 278
Date of Judgment/Order: 23 March 2026
Bench: Hon’ble Mr. Justice Sanjay Kumar; Hon’ble Mr. Justice K. Vinod Chandran
Held: The Supreme Court held that the National Green Tribunal cannot abdicate its adjudicatory functions by delegating decision-making to expert committees, and that such committees are only to assist the Tribunal; further, any order passed without adherence to principles of natural justice, including absence of notice and opportunity of hearing, is unsustainable.
Summary: The case arose from a challenge to the establishment of a petrol pump, which was stalled for several years due to proceedings initiated before the National Green Tribunal alleging violation of CPCB siting guidelines. The NGT, instead of adjudicating the dispute, constituted committees and directed them to decide compliance issues, while also passing orders without notice in execution proceedings. The appellants contended that all statutory clearances were obtained and that the proceedings were initiated by a person lacking locus standi. The Supreme Court examined the role of the NGT and reiterated that it is an adjudicatory body vested with judicial and expert members, and cannot transfer its decision-making power to committees. It analysed prior precedents emphasizing that expert committees are only for assistance and cannot replace adjudication. The Court further found that the NGT had acted in violation of natural justice by passing orders without hearing affected parties and by mechanically relying on committee reports without independent evaluation. On facts, the Court noted that the proposed site was in a commercial area, complied with CPCB guidelines, and no violation was established.
Decision: The Supreme Court allowed the appeals, set aside the NGT orders dated 01.02.2021 and 11.11.2022, and directed the District Magistrate to consider the matter afresh in accordance with law; it further observed that the petrol pump may be permitted if compliant with applicable regulations, and disposed of all pending applications accordingly.