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Issues: Whether the National Green Tribunal could dispose of an application concerning implementation of the Solid Waste Management Rules, 2016 by relegating the parties to an administrative committee instead of adjudicating the pending proceedings itself.
Analysis: The application before the Tribunal raised a substantial environmental dispute within its jurisdiction under Sections 14 and 15 of the National Green Tribunal Act, 2010. The reliefs sought, including restitution of the environment and compensation for environmental harm, were within the Tribunal's statutory powers. Expert committees appointed by courts or tribunals may assist in fact-finding and provide technical inputs, but they do not replace the adjudicatory role of the forum that appointed them. The Tribunal, being an expert adjudicatory body, cannot abdicate its statutory responsibility by transferring core adjudicatory functions to an administrative committee. The earlier proceedings had already resulted in extensive monitoring and interim directions, and the impugned order had the effect of displacing that adjudicatory process without deciding the dispute on merits.
Conclusion: The Tribunal could not lawfully delegate its adjudicatory function to the committee. The impugned order was unsustainable and had to be set aside, with the proceedings restored to the Tribunal for adjudication.
Ratio Decidendi: Statutory adjudicatory functions conferred on the National Green Tribunal under the Act cannot be abdicated or delegated to administrative expert committees, which may assist in fact-finding but cannot substitute the Tribunal's decision-making role.