Letter to the SC-Appointed High-Powered Committee for the Aravalli Hills presented at the Ajmer Consultation
By PUCL Rajasthan
To
The Chairperson, SC-Appointed High-Powered Committee for the Aravalli Hills,
Dr. Kanchan Devi, Director General, Indian Council of Forestry Research and Education (ICFRE),
Members:
Dr. Subhash Ashutosh, Ex-Director General, Forest Survey of India;
Dr. Rajendra Kumar Sharma, Director (Retd.), Geological Survey of India;
Brij Mohan Singh Rathore, Former Joint Secretary, MoEFCC
Prof. Ashok K. Bhatnagar, Former Professor and Head of Botany at Delhi University.
Special Invitees,
Professor Jagdish Krishnaswamy, Dean, School of Environment and Sustainability, Indian Institute for Human Settlements
Professor (Dr.) Laxmikant Sharma, Professor, Central University of Rajasthan,
Amit Anand, Dy Inspector General of Forests, Member Secretary of the HPC. (GOI nominee)
Dear Madam and Sir(s),
We have come to you with a lot of hope. We hope that your committee would be instrumental in getting quashed the death warrant pronounced by the SC judgement of 2025 of reducing the Aravallis to just a range of hills above 100 metres height. Which according to the FSI would reduce the hills to a miniscule number of only 1048 totally. leaving 1.20,000 to be chewed up by the mining companies.
This would be the end of all forms of life in Rajasthan, the death of not only a mountain, but of a whole civilisation, a people, cultures and the biodiversity causing genocide of all, the animals, birds, trees, shrubs, bushes, grasses, fileds and the finishing of all the water sources and water bodies, polluting the air and making our mountain areas unliveable and denying these upright hills which stand as the Aravalli range, to exist as a mountain range.
The job given to you is humungous, but the methodology adopted by you is not compliant to the task you need to undertake. This has deeply disappointed us. Why is the HPC, doing a skeletal road trip from Delhi to Udaipur, covering just two states and 9 districts, whereas the Aravalli, stands through 63/64 districts of five states, including Delhi, Haryana, Rajasthan, Gujarat and UP. (Acording to the FSI mapping in report, given to the MOEFF in 2025, reduced by the MOEFF to 37 districts).
Holding consultations in just a few of the Aravalli districts and that too at the district head quarter does not fulfil the criteria of a meaningful and effective consultation, which was expected of the committee. The committee must visit all the districts where the people are affected and visit the affected areas, not like what you undertook on the 7th and 8th August, where affected people including a large number of women and children, kept waiting for you from 8/9 am till late evening, waiting for atleast one member to see their doom, but none reached. This rushed trip just does not serve the purpose of meeting and listening to affected people.
Secondly, We would also like to record our disagreement with the manner in which these consultations are happening, it is far from being a two-way process, where committee members engage with us, instead this is just a one-way process of the public speaking to you in less that two to three minutes, the key issues, which may make or break the Aravallis. The committee cannot do a hurried job.
We would also like to know why no meetings have been fixed with the patients, activists and most importantly the doctors and hospitals to understand the extent of silicosis and other occupational diseases, caused by the reckless manner in which mining is happening;
Now let us get to the crux of the discussion:
The key issue is not between legal and illegal mining, but between mining and NO mining. All reports have stated that the so-called legal mining are also operating in an illegal manner. You have to hear the people and visit the actual mining areas, to understand this in its entirety and deduce how mining licenses have been given, without meeting the parametres provided in law.
We are appalled by the damaging and destructive nature of mining in the Aravallis of Rajasthan and Haryana and its impact on the natural environment and human health. Remember that the Honble Supreme Court of India was constrained to put a ban on mining way back in 2002-2004, about 20/25 yearrs ago. It was only thereafter, that the Rajasthan mining department floated the 100 metre approach – claiming only that the portions of hills above 100 m would be classified as Aravallis – in a brazen effort to undercut the supreme court ban.
This attempt of the Government of Rajasthan to subvert the ban, was noted by the SC in its order of 19.02.20210, when it directed the Forest Survey of India to identify the Aravallis, including the complete hills, and not just the peaks or parts that are above 100 m. Based on the 3 degree approach, with a buffer , the FSI delineated 41,481 km2 as aravallis in (then) 15 districts of Rajasthan.
Subsequent to this the Central Empowered Committee in its report No. 3 of 2024, also recommended that the FSI approach should be used across all Aravalli states to delineate the Aravallis. We therefore insist that the 3 degree approach of the FSI has been verified on the ground and is a tried and tested approach to delineate the Aravallis in Rajasthan. This 3 degree approach should be the baseline approach to delineate the Aravallis in all Aravalli states.
The CEC further stated that the Aravalli notification of 1992 – applicable in Rajasthan (Alwar) and Haryana (Gurgaon and Nuh), uses revenue record land type terms of gair mumkin pahar etc to determine the Aravalli areas. This approach has been tested on the ground and has worked over the last 34 years and should not be abandoned in favour of any new definition.
The 100 m approach recommended by the Committee of Secretaries and accepted in the 20.11.2025 order of the SC was subsequently stayed by the order dated 29.12.2025.
It is worth noting that the SC too only accepted the 100 m after the MoEF counsel – ASG Ashwariya Bhati claimed that more area would be covered by the 100 m approach – in a claim that defined both commonsense and mathematical logic. This was noted in the order dated 20.11.2025 of the SC, that the definition as suggested by the Committee is adopted, since a larger area would be included as part of the Aravali Hills and Ranges.
The new High Powered Committee must lay to rest – once and for all – the exclusionary and disastrous 100 m approach that originated from the mining department of Rajasthan, was rejected by the SC on 19.02.2010, but resurrected by the Committee of Secretaries and peddled to the SC, which was misled into believing that the 100 m approach would include larger areas of the Aravalli Hills and Ranges.
It is also imperative that the HPC examine the extent of Aravalli in the states of Gujarat, Rajasthan, Haryana and Delhi, and in Uttarpradesh (such as Govardhan etc) and in Madhya Pradesh, to get a comprehensive assessment of the total areas of the Aravallis across the 64 or more districts identified in the Forest Survey of India report of September 2025.
We also wish to emphatically state that till these discussions do not include liability fixed on mine owners for every harm caused to humans including deaths and also the widespread environmental damages leading to health issues, the loss of biodiversity, water sources and livelihoods of communities, unless such firm decisions are taken, there can be no honest discussion on mining or sustainable mining. There can be nothing sustainable if the result is killing people and other inhabitants and the water bodies and rivers of the region.
The myth of the revenue mining generates is also important to expose, as the total revenue from mining (as percent of total revenue receipt) is only 4.25%, (total revenue from mining – Rs. 13,875 crores Total revenue receipts – Rs. 325,740), making mining the fifth largest contributor of the total revenue generated by the State of Rajasthan. The top revenue contributors being 1. State Goods and Services Tax – Rs. 72,500 crores. 2. Value Added Tax – Rs. 33,800 crores . 3. Stamp and Registration Registration – Rs. 18,750 crores. 4. State Excise: Rs. 21,000 crores. This pushes Mining to fifth position. 5. Non-ferrous Mining and Metallurgical Industries – Rs. 13,725 crores, followed by Transportation Tax – Rs. 11,000 crores, which Is the 6th largest contributor.
We need to ask ourselves as to what is mining adding to, even if revenue be the main focus, then too it is not coming to the state and the people, as by design, it never gets collected as the stakes of doing mining without giving royalty is much higher. The State is compliant in this model of loss of revenue to the state exchequer.
We hope that you will come back soon and engage with us more meaningfully, so that we can then address how to save whatever of the Aravalli is left today, and hand over this mountain legacy that we inherited safely to the next generation.
Yours sincerely,
Kavita Srivastava, National President, PUCL
Anant Bhatnagar, President, PUCL Rajasthan