The order in Mukesh & Anr. v. State for NCT of Delhi, dated 11 July 2016, may be brief, but it offers a meaningful window into how the Supreme Court manages representation in matters of extraordinary public and legal significance. It also stands as an on-record instance of an Advocate-on-Record — Anil Kumar Mishra — appearing in one of the most consequential criminal appeals in India’s recent judicial history, alongside senior amicus curiae Mr. Sanjay R. Hegde, before a Bench of Justices Dipak Misra, C. Nagappan, and R. Banumathi.
For advocates and law firms, cases like this underscore what it takes to practise before the Supreme Court of India: not just substantive legal skill, but the procedural rigor, credibility, and trust that allow counsel to stand in courtrooms where the stakes — for individuals and for the country’s legal conscience — could not be higher.
This article is based on the official order dated 11 July 2016 in Petition(s) for Special Leave to Appeal (Crl.) Nos. 3119-3120/2014, as published on Supreme Court Cases (supremecourtcases.com). For the full text of the order, refer to the original source.
Case Background
Samaj Parivartana Samudaya & Ors. v. State of Karnataka & Ors., registered as Writ Petition (Civil) No. 562 of 2009 (heard together with connected W.P.(C) No. 768/2013 and W.P.(C) No. 448/2018), is a Public Interest Litigation that has occupied the Supreme Court’s docket for over fifteen years. The petitioners — Samaj Parivartana Samudaya, a voluntary organisation — approached the Court under Article 32 of the Constitution, alleging systemic illegal mining of iron ore in the Bellary region, causing significant environmental degradation, loss of state revenue, and harm to local communities.
The matter has produced some of Indian environmental law’s most significant interim orders — including production caps on mining output, the constitution of a Monitoring Committee to oversee sales and compliance, and continuous supervision by the Court-appointed Central Empowered Committee (CEC). The order examined here, a Record of Proceedings dated 24 January 2019, was passed by a Bench comprising the Chief Justice of India, Justice L. Nageswara Rao, and Justice Sanjiv Khanna.
What the 24 January 2019 Order Addressed
This hearing dealt with several interlocutory applications simultaneously — a reflection of just how many moving parts a case of this scale involves:
- Forest land classification dispute: The Bench examined whether certain leased mining areas fell within revenue land or forest land, following the State’s cancellation and subsequent contested review of two notifications under the Karnataka Forest Act, 1963. With the Karnataka High Court having set aside the State’s review order, the Bench adjourned related applications, granting the State two weeks to file a fresh special leave petition before the Supreme Court.
- Sales through the Monitoring Committee: Applications concerning the sale of mined iron ore were deferred for three months, with directions for the Monitoring Committee to submit a fresh report on sales, and for the CEC and State of Karnataka to respond within that period.
- Floor price/reserve price mechanism: The Court directed that the floor price for ore sales be fixed by the Monitoring Committee, taking into account both the Court’s earlier parameters and market-linked suggestions from the lessees.
- Comprehensive Environmental Plan for Mining Impact Zone (CEPMIZ): The Court requested Mr. Shyam Divan, learned Amicus Curiae, to examine the feasibility of the State’s proposals for the CEPMIZ, while declining to consider a competing plan submitted by an industry body, and permitting the petitioners to respond to the State’s proposals.
The Scale of Representation
What stands out from the cause title of this order is the sheer scale of legal representation involved. Appearing for the Petitioners were Mr. Shyam Divan, Senior Advocate and Amicus Curiae, along with a team of advocates including Mr. A.D.N. Rao and Mr. Prashant Bhushan, AOR. On the Respondents’/Applicants’ side — representing the State of Karnataka, mining lessees, and multiple intervening companies — the Court heard from an extensive bench of senior counsel, including Mr. P. Chidambaram, Mr. Krishnan Venugopal, Mr. C.A. Sundaram, Mr. P.S. Narasimha, Mr. Jaideep Gupta, and Mr. Dushyant Dave, supported by more than fifty Advocates-on-Record across the various respondent and applicant entities.
Among the Advocates-on-Record listed for the Respondents/Applicants was Mr. Anil Kumar Mishra-I, formally on record in this landmark environmental litigation. In a matter of this size and complexity — where dozens of parties, senior counsel, and interveners appear together in a single hearing — being on record as AOR reflects a sustained, formal engagement with one of the most significant natural-resource governance cases the Supreme Court has supervised in recent years.
It’s worth noting, in the interest of accuracy, that this particular Record of Proceedings — being a case-management order covering multiple interlocutory applications — attributes specific submissions only to the senior counsel who addressed the Bench directly (such as Ms. Anitha Shenoy for the State of Karnataka on the forest-land question). The order does not break down which individual AOR was instructing which senior counsel on which application. What the record does confirm is Mr. Mishra’s formal appearance on the Respondents’/Applicants’ side of this proceeding.
Why This Case Matters
The Bellary mining litigation is widely regarded as one of the most significant instances of judicial oversight over natural resource management in India. Its outcomes have included:
- Production caps on mining output across Bellary, Chitradurga, and Tumkur districts, revised periodically by the Court based on environmental and market assessments.
- A Court-supervised Monitoring Committee overseeing the sale of iron ore through a structured, price-regulated mechanism.
- Continuous engagement with the Central Empowered Committee (CEC), an expert body assisting the Court on forest and environmental compliance.
- A framework — the CEPMIZ — designed to address the long-term environmental impact of mining in the affected districts.
The case remains active more than a decade after it began, a testament to the complexity of balancing industrial activity, environmental protection, and community welfare through sustained judicial supervision.
The 24 January 2019 order in Samaj Parivartana Samudaya v. State of Karnataka is, on its face, a routine case-management hearing in a long-running matter. But it also offers a snapshot of what large-scale, multi-party environmental litigation before the Supreme Court actually looks like — dozens of senior counsel and Advocates-on-Record, representing a wide array of interests, working through interlocking applications on forest law, environmental planning, and resource pricing, all under the Court’s continuing supervision.

