The Supreme Court held that the doctrine of public trust applies to artificially created waterbodies, in addition to natural ones.
A three-judge bench, comprising Chief Justice of India B R Gavai, and Justices K Vinod Chandran and N V Anjaria, made this ruling on October 7, 2025.
The doctrine of public trust is not confined only to natural waterbodies such as rivers, lakes, and wetlands but also extends to man-made or artificially created waterbodies that serve ecological or environmental purposes.
The court noted that all artificial or man-made waterbodies created from natural resources and contributing to environmental balance fall within the ambit of the doctrine of public trust.
The case in question concerned Futala Lake, a man-made waterbody in Nagpur, which the court ruled does not fall within the statutory definition of a ‘wetland’.
Author's summary: Supreme Court expands public trust doctrine to man-made waterbodies.