The Supreme Court of India has issued a landmark ruling that settles a long-standing question about how limitation periods are calculated for appeals filed against Environmental Clearances (ECs) before the National Green Tribunal (NGT). The judgment, delivered on November 19, 2025, in Talli Gram Panchayat vs. Union of India & Ors. (Civil Appeal No. 731 of 2023), confirms that the limitation clock starts from the earliest date on which the EC is made public by any authorized entity.
Under Section 16(h) of the NGT Act, an appeal must be filed within 30 days, which can be extended by a maximum of 60 days. The Court held that this period begins once the EC is communicated “in rem,” meaning its disclosure must serve public interest rather than individual notice. This responsibility rests with several duty holders, including the Ministry of Environment, Forest and Climate Change (MoEF&CC), the project proponent, and Pollution Control Boards.
The Court adopted the “first accrual” principle. If multiple authorities release the information, the limitation period will run from the earliest date on which the EC becomes publicly accessible. This prevents litigants from relying on later disclosures to extend the deadline.
Talli Gram Panchayat challenged an EC granted on January 5, 2017, arguing that time should run from February 14, 2017, when it received information through an RTI reply. The Court rejected this argument.
The record showed that:
- The MoEF&CC uploaded the EC on its website on January 5, 2017.
- The project proponent submitted the EC to local Panchayats, acknowledged on January 9, 2017.
- A notice was published in a local newspaper on January 11, 2017.
Given these disclosures, the Court held that communication was complete on January 5, 2017, the earliest public release.
The Panchayat argued that the project proponent should have published the entire EC in two local newspapers. The Court rejected this as overly technical and held that a notice containing the grant and essential conditions satisfies the requirement. The law does not mandate publication of the whole clearance document.
Since the EC was uploaded on January 5, 2017, the 30-day limitation started on that date. Even with the maximum extension, the outer limit expired before the Panchayat filed its appeal on April 19, 2017. The Supreme Court upheld the NGT’s dismissal of the appeal as time-barred.
Title: Talli Gram Panchayat vs. Union of India & Ors.
Case Number: Civil Appeal No. 731 of 2023
Bench: Justice Pamidighantam Sri Narasimha and Justice Atul S. Chandurkar
Date of Judgment: November 19, 2025
Appellant’s Counsel: Mr. Sanjay Parikh, Senior Counsel, with Mr. Abhimanue Shrestha
Respondent’s Counsel: Mr. Pinaki Mishra, Senior Counsel