PUCL's Note on the Interim Aravalli Definition Report submitted by the HPC to the Supreme Court

Sep 06, 2026
By PUCL Rajasthan, PUCL National

On 9th August, 2026, PUCL made a presentation before the High Powered Committee. Click here to read the representation submitted then.

After taking five months to form the committee for defining the Aravallis and giving it three months to give a report, on 31st August, 2026, the SC received an interim compliance report from the High Powered Committee (HPC). The PUCL response to this report as follows:

1. Interim report – work in progress – no final or even indicative results shared.

Despite 10 meetings, and 6 days of fieldwork and public hearings,  the compliance report is a work in progress. It is silent on the key issues that it was tasked by the court to address  – whether the 100 m elevation approach proposed by the MoEFCC secretary chaired Committee covered more hills and area than the three degree slope approach developed by the Forest Survey of India.

The report starts promisingly, stating that the, “feasibility  of the methodology for assessing the implications of terrain/elevation-based delineation for the coverage of Aravalli hills, forest cover and aquifers has been demonstrated in three sample districts – Alwar, Ajmer and Udaipur”

Despite undertaking the analysis in three districts, the committee has not shared the outcome in terms of number of hills or areas. Even the broad direction of the analysis whether 100 m or 3 degree approach covers more hills and Aravalli area is not shared.

Instead, the committee has taken a cautious approach, that the “quantitative outputs with potentially significant regulatory and socio-economic implications should be reported only after the underlying methodology, datasets and analytical parameters have been sufficiently tested and the results have undergone appropriate technical validation and cross-comparison.”

The committee has stated that they will fine tune and vet their results before placing them before the court. The report states that, “The committee’s present work is directed towards establishing a scientifically robust, transparent and reproducible basis for such outputs rather than placing before the Honble Court numerical estimates that may subsequently require revisions following further methodological  examination.”

2. Existing approaches applicable in Delhi and the NCR not reflected

The interim report does not reflect any recognition of the existing approaches to delineate the aravallis in Delhi, Haryana and the NCR districts of Rajasthan.

  1. Delhi has a developed a process of identifying the extended aravallis – based on their geomorphological extent, fine-tuned through several judgements of the Delhi High Court and Supreme Court since 2011.  The SC has also directed to delineate the entire aravallis in Delhi based on this approach.
  2. Similarly the MoEFCCs Aravalli notification of 1992 used the landuse/land form categories of the revenue record to delineate the aravallis in Gurgaon and Nuh districts of Haryana and Alwar district of the NCR.
  3. These approaches must be considered and grandfathered into the process of defining and delineating the aravallis – the  allure of developing a  de novo/ /new approach should not sweep away existing approaches that have evolved over time.

3. Field visits and public hearings.

PUCL notes that unlike the earlier MoEF Secretary led committee, the current committee has undertaken some fieldwork and public hearings, however exploratory. However 5-6 days of visits to just two states is inadequate and does a grave injustice to the issue.

Given the experience with the public hearings in Alwar, Ajmer, Udaipur and Gurgaon some concerns are being shared so that the future hearings can be more fruitful:

    1. Hearings of one to two hours – are insufficient for citizens to convey the depth of their issues, these should be at least half to one day long.
    2. The field visits and hearings should be done in phases and devote at least three to four weeks – and try to cover most of the Aravalli districts.
    3. The Forest department should be the nodal department.  In Rajasthan, the mining dept. was made the nodal dept. and this resulted in domination by mining industry stakeholders at the cost of the mining-impacted communities and ordinary citizens.  In Ajmer, the public hearing was virtually converted into a show of strength by the mining lobby.  Impartial moderation of proceedings is essential.
    4. PUCL representatives were physically threatened by the mining interests and had to be protected by police personnel in Ajmer.
    5. In Gurgaon, some citizens were not allowed to record the proceedings.  Civil society was shepherded out of the room when the mining interest stakeholders  started addressing the HPC, leaving them unaware of the claims made by the mining lobby – and whether they were accurate or not.
    6. No hearings were undertaken in Delhi or Gujarat – these must be covered in the future.
    7. The committee should  review the concerns under adjudication related to the Aravallis to understand the issues involved, by asking state governments to provide a list and judgement of ongoing and settled court cases related to mining, real-estate, ownership etc in the aravallis,  to analyse the same. They may then visit a sub-set of the identified sites, to understand the key concerns that communitites have raised about the mining and real estate impacts.    Merely visiting a few sites vetted by the mining department will not provide a realistic appreciation of the hazards of mining etc.

4. Word soup of adjectives and nouns

On a lighter note, PUCL could not help but note that the committee has provided a veritable word soup of adjectives and nouns to describe its approach. The framework they are proposing is:

    1. emerging,
    2. multidisciplinary,
    3. tiered,
    4. nested,
    5. hierarchical and
    6. ecosystem-based.

“Accordingly, the Committee is considering an emerging multidisciplinary tiered nested hierarchical ecosystem-based framework encompassing, inter alia, geological and geomorphological foundations, terrain and landforms, watersheds and hydrological systems, forests and biodiversity, ecological connectivity and ecosystem services to downstream areas, communities and human settlements among various other parameters to address the mandates assigned to the Committee.”

We hope that the committee gives clear recommendations that delineate the Aravallis comprehensively, that help keep real estate and mining out of the Aravallis, highlight mining impacts so that they can be put under more effective regulatory control, stop mining for exports, and keep it away from good forest cover and from habitation.

We demand disclosure of the assessment made by the HPC on the methodology for definition of Aravallis, and its conclusions on the 100 metre approach which raised such outrage amongst the people.

PUCL hopes the committee will stop tokenism and in the next three months of extension given will:

  • Hear the ordinary people express their suffering due to mining and real estate
  • Visit areas and see for themselves the devastating impact of mining
  • And makes a clear call for closure of mining and real estate activities in its final recommendations
  • In the context of the recent disaster in Nepal, recognize the much higher human cost of rampant mining

It requests that the Supreme Court must save the Aravallis, the ecosystem and the people and not sacrifice it at the alter of mining, real estate and profits.

Kavita Srivastava, President, PUCL
V. Suresh, General Secretary, PUCL

Bhanwar Meghwanshi, Secretary, PUCL Rajasthan
Anant Bhatnagar, President, PUCL Rajasthan