Environmental clearance is mandatory for minor mineral leases where cumulative mining impacts may harm rivers and ecology.

Minor mineral mining, including riverbed sand extraction, must be regulated under sustainable development and ecological protection principles, because even leases below five hectares can have significant cumulative environmental impacts on rivers, biodiversity, groundwater and riparian ecology. The regulatory framework under the Mines and Minerals (Development and Regulation) Act, 1957 requires proper mine planning, cluster-based management, reclamation, rehabilitation, depth restrictions and river-stretch-wise control. States and Union Territories were directed to implement the expert recommendations and model guidelines, and leases or renewals for areas below five hectares were to be granted only after environmental clearance from the MoEF.

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Issues: Whether minor mineral leases and renewals for areas of less than five hectares could be permitted without environmental clearance and whether the States and Union Territories were bound to implement the environmental safeguards and model guidelines for minor mineral mining.

Analysis: The auction notices permitted extraction of minor minerals, including riverbed sand mining, without any prior study of the environmental impact. The record showed that even small individual leases could have a significant collective effect on rivers, riverbeds, biodiversity, groundwater and riparian ecology. The regulatory framework under the Mines and Minerals (Development and Regulation) Act, 1957 and the environmental regime required mining to be aligned with sustainable development, ecological protection and proper mine planning. The recommendations of the expert report and the model guidelines emphasized minimum lease size, lease planning, cluster-based management, reclamation, rehabilitation, depth restrictions and river-stretch-wise regulation for riverbed mining.

Conclusion: The States and Union Territories were directed to give effect to the expert recommendations and model guidelines, and leases of minor minerals, including renewals for areas below five hectares, were ordered to be granted only after obtaining environmental clearance from the MoEF.

Ratio Decidendi: Even where a mining lease individually falls below the statutory threshold, environmental clearance and regulatory safeguards are mandatory if the activity may cumulatively cause material environmental degradation, and mining of minor minerals must be subjected to a strict, scientifically planned regulatory regime.

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