There is no direct “Article 24” in the Indian Constitution relating to biodiversity obligations. However, in academic and legal usage, “Article 24 biodiversity obligations” is often used mistakenly to refer to the constitutional environmental obligation framework, which actually comes from:

• Article 48A (Directive Principle of State Policy)
• Article 51A(g) (Fundamental Duty)
• Article 21 (Right to Life – environmental interpretation)
• Article 253 (International environmental treaties)
• Judicial doctrines like Public Trust Doctrine + Sustainable Development

Together, these create India’s constitutional biodiversity governance framework.

1. Constitutional Basis of Biodiversity Obligations in India

(A) Article 48A (State Duty)

State must:

• protect and improve environment
• safeguard forests and wildlife
• conserve ecological balance (includes biodiversity)

(B) Article 51A(g) (Citizen Duty)

Every citizen must:

• protect natural environment
• conserve forests, lakes, rivers, wildlife
• show compassion for living creatures

(C) Article 21 (Right to Life)

Supreme Court has interpreted it to include:

• right to clean environment
• ecological balance
• sustainable biodiversity

(D) Article 253

Parliament can enact laws like:

• Biological Diversity Act, 2002
• to implement international treaties (CBD 1992)

2. Core Biodiversity Principles Adopted by Courts

Indian judiciary has expanded constitutional biodiversity obligations using:

• Public Trust Doctrine
• Sustainable Development
• Precautionary Principle
• Polluter Pays Principle
• Inter-generational equity

3. Important Case Laws (At least 6)

1. M.C. Mehta v. Union of India (Oleum Gas Leak Case, 1987)

• Established absolute liability for hazardous industries
• Expanded Article 21 protection
• Strengthened State duty to protect environment and biodiversity

Significance: Biodiversity protection linked to human survival.

2. M.C. Mehta v. Kamal Nath (1997)

• Introduced Public Trust Doctrine in India
• State cannot destroy natural resources for private gain

Significance: Land, forests, rivers = public trust assets.

3. T.N. Godavarman Thirumulpad v. Union of India (Forest Conservation case series)

• Expanded definition of “forest”
• Continuous monitoring of forest biodiversity
• Strict protection against deforestation

Significance: Landmark biodiversity conservation supervision case.

4. Vellore Citizens Welfare Forum v. Union of India (1996)

• Recognized Sustainable Development as law
• Applied precautionary and polluter pays principles

Significance: Environmental protection became enforceable constitutional principle.

5. M.C. Mehta v. Union of India (Taj Trapezium Case) (1996)

• Ordered closure/relocation of polluting industries near Taj Mahal
• Protected ecological and cultural environment

Significance: Industrial activity restricted to protect environmental heritage.

6. Indian Council for Enviro-Legal Action v. Union of India (1996)

• Applied Polluter Pays Principle
• Directed industries to pay for environmental damage

Significance: Restoration of damaged ecosystems made mandatory.

7. A.P. Pollution Control Board v. Prof. M.V. Nayudu (1999)

• Strengthened role of environmental expertise in adjudication
• Emphasized precautionary principle in biodiversity risk

Significance: Scientific decision-making in environmental governance.

8. Lafarge Umiam Mining v. Union of India (2011)

• Balanced development with ecological protection
• Emphasized inter-generational equity

Significance: Sustainable mining and biodiversity balance.

4. Biodiversity Governance Structure (Judicial View)

Courts recognize biodiversity protection through:

(A) State Responsibility

• protect ecosystems
• regulate industrial exploitation
• enforce environmental laws

(B) Citizen Responsibility

• conservation duty under Article 51A(g)

(C) Judicial Responsibility

• enforce constitutional environmental rights
• stop ecological destruction
• apply international biodiversity principles

5. Judicial Expansion of Biodiversity Obligations

The Supreme Court has consistently held:

• Biodiversity = part of Article 21 life protection
• Forests, rivers, wildlife = constitutional assets
• Development must be ecologically sustainable

Conclusion

Although “Article 24 biodiversity obligations” is not an actual constitutional provision, India’s biodiversity framework is strongly rooted in:

• Articles 48A, 51A(g), 21, 253
• Supreme Court environmental jurisprudence
• International Convention on Biological Diversity (1992)

The judiciary has transformed biodiversity protection into a constitutional obligation of the State, citizens, and courts, ensuring that natural wealth is preserved for future generations.