The Rajasthan High Court has invoked its suo motu public interest litigation jurisdiction to address the alarming environmental degradation, unregulated commercialization, and structural failures plaguing the interconnected lake ecosystem and canal network of Udaipur.

The division bench comprising Justice Pushpendra Singh Bhati and Justice Rekha Borana observed, "Certain lakes and water bodies of ecological and hydrological significance are allegedly facing pressures arising from encroachments, unregulated developmental activities and uncertainty regarding their boundaries and extent...Certain water bodies, particularly Roop Sagar lake has serious concerns regarding identification, demarcation and protection of lake beds, and its catchment areas...Continuous developmental and commercial activities in proximity to ecologically sensitive lake areas and the further encroachments, pollution and alteration of natural drainage systems have adversely impacted the ecological character and long-term sustainability of water bodies within the city. The same has further adversely affected the groundwater recharge, water conservation, biodiversity, ecological sustainability and environmental security."


"Recurring failures in the maintenance and structural integrity of canal infrastructure forming part of the larger water management system of the region, have occurred which has endangered public safety and environmental management", it added.

The Bench initiated the order by recalling the cultural and aesthetic identity of Udaipur, citing the celebrated verses of poet and scholar Shri JaiKrishn Chaudhry 'Habeeb'. In his nazm "Udaipur", the poet described the city as a place whose "gorgeous reflection shimmers in its pleasant lakes" and referred to it as the envy of paradise itself.

However, the Court emphasized that this poetic description was not merely an expression of aesthetic admiration; it underscored the inseparable relationship between Udaipur’s identity and its water bodies. The Bench observed that these lakes constitute a living natural and cultural heritage crucial for groundwater recharge, water security, biodiversity, and climate resilience.

The Court firmly grounded its intervention within the Indian constitutional framework, re-affirming that the right to a clean and healthy environment is an integral component of the Right to Life under Article 21. It said that Article 48A casts a duty upon the State to protect and improve the environment and to safeguard forests, lakes, rivers and wildlife, while Article 51A(g) recognizes a corresponding duty of every citizen to protect and improve the natural environment. The Public Trust Doctrine mandates that natural resources of vital public importance are held by the State as a trust, for the benefit of the public and the future generations, and cannot be permitted to suffer degradation through inaction or unsustainable use, the Court added.

The Court took cognizance of certain newspaper reports published in the Udaipur Edition of Rajasthan Patrika, which raised serious concerns regarding the deteriorating condition of lakes, canals, wetlands, and water bodies situated in Udaipur. The reports collectively highlighted issues relating to alleged encroachments, unresolved boundary disputes, structural deficiencies in public water infrastructure, and developmental activities being undertaken in close proximity to ecologically sensitive areas.

Specifically, the first report highlighted concerns regarding the Rupsagar Talab, indicating that despite prolonged administrative proceedings, the local authorities failed to determine the actual extent and boundaries of the lake bed, which led to continuous construction activities and competing land claims. The second report drew attention to recurring structural failures in portions of the Madar Canal walls despite repeated repairs, which posed an imminent threat of flooding and danger to public safety.

The third report referred to proposed urban and commercial development activities in the immediate vicinity of Fatehsagar Lake, emphasizing the critical need to balance tourism and economic growth with environmental safeguards and ecological carrying capacity.

The Court observed that these issues were not isolated incidents but disclosed broader systemic concerns affecting the urban water bodies within the city. It was opined that the continuous commercial pressures, unregulated developmental activities, pollution, sewage discharge, and inadequate maintenance of water infrastructure had adversely impacted groundwater recharge, water conservation, and the ecological integrity of the entire interconnected lake network.

In view of the larger public interest involved, and considering the urgent need for judicial scrutiny to protect the environment and conserve natural resources, the Court deemed it appropriate to invoke its suo motu jurisdiction under Article 226 of the Constitution of India.

Notices were issued to all the named respondents, including the Chief Secretary to the State Government, the Principal Secretaries of the concerned departments, the Rajasthan State Pollution Control Board, and the local municipal and development authorities. The respondents were directed to file detailed affidavits and status reports covering various aspects, including the geographical extent and ecological status of the major lakes, details of boundary demarcations, actions taken against illegal encroachments, sewage discharge prevention measures, and structural audits of the canal infrastructure. They were also required to submit a comprehensive short-term, medium-term, and long-term action plan for the restoration and sustainable management of the water bodies.

By way of an interim measure, the Court directed the State Government and the concerned authorities to ensure that no further encroachment, reclamation, land-filling, or unauthorized construction activity was permitted within the boundaries of any identified lake, canal, or catchment area.

The authorities were directed to maintain status quo regarding the physical extent of the water bodies and to ensure that no untreated sewage or municipal waste was discharged into them. The Rajasthan State Pollution Control Board was specifically directed to conduct water quality assessments and submit a report indicating contamination levels and remedial actions.

"As an interim measure, the State Government and all concerned authorities shall: (i) ensure that no further encroachment, reclamation, filling, dumping, construction activity or alteration of the physical boundaries of any identified lake, water body, canal, feeder channel or catchment area is permitted except in accordance with law and after obtaining all requisite permissions from the competent authorities;...(ii) undertake inspection of Pichola Lake, Fateh Sagar Lake, Swaroop Sagar Lake, Rang Sagar Lake, Roop Sagar Talab, Doodh Talai, Goverdhan Sagar Lake, Badi Lake (Jiyan Sagar), Udai Sagar Lake, Madar Lake, Bada Madar Lake, Chhota Madar Lake and Kumharia Talab and other interconnected lakes and water bodies situated within Udaipur and submit reports regarding their present ecological condition, water quality status, catchment condition, encroachment status and conservation requirements", the Court ordered.

The District Collector of Udaipur was designated to coordinate with all departments to collect the necessary information and place a consolidated status report before the Court. Furthermore, several advocates were appointed as Amici Curiae to assist the Court in the conduct of the present proceedings.

The Court ordered the matter to be listed for further hearing on a subsequent date, and directed that the relevant newspaper reports be treated as part of the formal record.

Cause Title: Suo Motu : In Re: Protection and Conservation of Lakes and Water Bodies in Udaipur versus State of Rajasthan & Others [CW/12630/2026]

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