IN THE HON'BLE HIGH COURT OF ALLAHABAD

In the matter of, Article 226 of the Constitution of India

Civil Writ Petition No. ____ of 2024

IN THE MATTER OF:

Sankat Mochan Foundation ………PETITIONER
VERSUS
The National River Protection Authority (NRPA) ……….RESPONDENT

WRIT PETITION UNDER ARTICLE 226 OF THE CONSTITUTION OF INDIA SEEKING A

WRIT OF MANDAMUS
The humble petition of the Petitioners above-named:
MOST RESPECTFULLY SHOWETH:
1. That the Petitioner is a non-governmental organization advocating for environmental activists
and affected residents from several riverine communities.
2. That the Respondent, the National River Protection Authority (NRPA), is a statutory body
established under the Clean River Initiated Act (CRIA) of 2020, mandated to protect and
improve the water quality of the Ganga River.
3. The Clean River Initiated Act (CRIA) of 2020 was enacted to protect and improve the water
quality of the Ganga River. Section 15 of CRIA 2020 explicitly requires the NRPA to prepare
and execute a River Basin Management Plan within two years i.e. before 2022 of the Act's
enactment.
4. Despite the clear mandate, the NRPA has failed to prepare and implement the River Basin
Management Plan, as mandated by CRIA 2020.
5. Recent reports and studies indicate that the water quality of the Ganga River has significantly
degraded, leading to adverse public health outcomes, including an increase in the incidence of
waterborne diseases in communities along the river.
6. The failure of the NRPA to act as per the mandate of CRIA 2020 constitutes a dereliction of
its statutory duties, adversely affecting the right to live under Article 21 of the Constitution of
India.
7. The inaction of the NRPA has also affected the livelihoods of thousands of individuals who
depend on the river for their daily needs and economic activities.
8. That the respondent's failure to act in accordance with the mandate of CIRA 2020 has resulted
in significant harm to petitioner’s rights and interests, warranting judicial intervention.
9. The Petitioners have approached this Hon'ble Court seeking legal redress and relief on the
following grounds
GROUNDS:
a) Because the inaction of the respondent is contrary to law and good conscience.
 b) Because the respondent’s inaction constitutes a blatant disregard for its statutory
duties and dereliction of duty as it has been 4 years since the enactment of CIRA
2020.
c) Because the respondent has failed to prepare and implement the river basin
management plan within the stipulated time frame despite the clear mandate provided
under Section 15 of CRIA 2020.
d) Because the action of the respondent is arbitrary, unreasonable, irrational and
unconstitutional.
e) Because the inaction of respondent has resulted into the degradation of the Ganga
river's water quality, as evidenced by recent reports and studies, and has led to an
increase in waterborne diseases among communities living along the river. This
constitutes a violation of the fundamental right to health guaranteed under Article
21 of the Constitution.
f) Because the respondent’s inaction has adversely affected the livelihoods of thousands
of individuals who depend on the Ganga River for their daily needs and economic
activities including fishing, agriculture, and tourism, further exacerbating the socio-
economic challenges faced by riverine communities. This constitutes a violation of
the right to livelihood under Article 21 of the Constitution.
g) Because the action of the respondent is bad in law and public interest.
h) That the Petitioner craves, leave of this Honorable Court to add, amend, alter the
grounds raised in this petition
i) That the cause of action in present case arose on 25.02.2024 when the respondent has
blatantly disregarded CRIA 2020 which required its mandate.
j) Because this failure directly impacts the fundamental right to life guaranteed under
Article 21 of the Constitution of India, as it jeopardizes the health and well-being of
individuals residing along the Ganga River.

PRAYER:
In the premises aforesaid, it is most respectfully prayed that this Hon'ble Court may be pleased to:
a. Issue a Writ in the nature of Mandamus or any other appropriate Writ, Order, or Direction, directing
the Respondent, the NRPA, to fulfill its statutory duty by immediately preparing and implementing
the River Basin Management Plan as mandated by the Clean River Initiated Act (CIRA) of 2020.
b. Pass any other or further orders as this Hon'ble Court may deem fit and proper in the facts and
circumstances of the case.
c. Award the costs of this petition to the Petitioners.
AND FOR THIS ACT OF KINDNESS, THE PETITIONERS, AS IN DUTY BOUND, SHALL
EVER PRAY.
Prayagraj PETITIONER
Dated: 23-02-2024 THROUGH ADVOCATE
Vanshika Tomar
 AFFIDAVIT
Affidavit of Affected Resident:
I, Urmila Pawar, aged 48 years, residing at 29B/ 20A, Daraganj, Prayagraj do hereby solemnly affirm
and declare as follows:
1. I am a resident living in close proximity to the Ganga River, which is a lifeline for our
community and a source of livelihood for many.
2. Over the past few years, I have witnessed a significant deterioration in the water quality of the
Ganga River, primarily due to pollution from industrial effluents, untreated sewage, and
agricultural runoff.
3. The foul smell emanating from the river and the visible presence of pollutants have severely
impacted our daily lives and well-being. Many residents, including myself, have experienced
health issues such as skin infections, respiratory problems, and gastrointestinal ailments due
to exposure to contaminated water.
4. The decline in water quality has also adversely affected our livelihoods, particularly those
dependent on fishing, agriculture, and tourism along the river. The dwindling fish population
and the loss of fertile land for cultivation have resulted in economic hardships for our
community.
5. Despite numerous complaints and appeals to the authorities, including the National River
Protection Authority (NRPA), to take urgent measures to mitigate pollution in the Ganga
River, little action has been taken. The inaction of the NRPA has exacerbated the
environmental crisis and deepened our sense of despair and frustration.
6. I hereby affirm that the statements made herein are true and correct to the best of my
knowledge and belief.

Urmila Pawar
Date: 25.02.2024
Place: Prayagraj

Affidavit of Environmental Activist:

I, Jadav Payeng, aged 43 years, residing at Saket Nagar, New Delhi, do hereby solemnly affirm and
declare as follows:
1. I am an environmental activist dedicated to advocating for the protection and conservation of
natural resources, including the Ganga River.
2. Through extensive research and field observations, I have documented the adverse impact of
pollution on the Ganga River ecosystem and the communities dependent on it.
3. The failure of the National River Protection Authority (NRPA) to fulfill its statutory
obligations under the Clean River Initiative Act 2020 has exacerbated the pollution crisis in
the Ganga River. Despite the explicit mandate to prepare and execute a river basin
 management plan within two years of the act's enactment, the NRPA has failed to take
decisive action.
4. The lack of effective regulation and enforcement by the NRPA has emboldened polluting
industries to continue discharging untreated effluents into the river, further deteriorating water
quality and endangering aquatic life.
5. As an activist, I have tirelessly campaigned for the implementation of pollution control
measures and the restoration of the Ganga River to its pristine state. However, the apathy and
negligence of the NRPA have thwarted our efforts and undermined the collective aspirations
of the affected communities.
6. I hereby affirm that the statements made herein are true and correct to the best of my
knowledge and belief.

Jadav Payeng
Date: 20.02.2024
Place: Prayagraj