Many coal and other mineral block allocations are non-transparent and violate the Doctrine of Public Trust

The Teck Mining Co open pit Elk River Valley coal mines


Shri Rajiv Gauba

Cabinet Secretary

Govt of India

Dear Shri  Gauba,

Subject:- Many coal and other mineral block allocations are non-transparent and violate the Doctrine of Public Trust, raising concerns about propriety as they circumvent the laws and regulations in force.

I write this in continuation of my earlier letter dated 6-4-2023 on the subject ( Apparently, in the allocation of coal blocks, and several other matters, transparency has got severely compromised during the last few years, raising questions of propriety. The government should come clean on this at the earliest.

I have since come across yet another investigative report published today by Scroll ( about the highly questionable manner in which the Ministry of Environment, Forests & Climate Research (MEFCC) accorded approval on 2-2-2022 for diversion of 1898.328 ha of forest land in Villages Parsa and Kete, Tehsil Udaipur, District Surguja for the expansion of Parsa East and Kete Basan Coal Blocks, being mined by the Adani Group. These are the same coal blocks for which mining by the Adani Group had been irregularly allowed to continue in violation of the judgement of the Hon’ble Supreme Court in the case on “coalgate” in 2014, which I referred in my letter dated 6-4-2023.

Apparently, MEFCC issued clearance for the diversion of the forest land vide its communication No. File No.8-31/2010-FC dated 2-2-2023, despite, between May 2019 and February 2021, two government institutes, namely, the Indian Council of Forestry Research and Education, and the Wildlife Institute of India  conducted a biodiversity study in the Hasdeo Arand coalfield (where the above two coal blocks are located) and came to the finding that there was enough coal which could be extracted readily from Parsa East and Kete Basan Coal Blocks even for expansion of mining and it is neither desirable nor necessary for diverting any additional forest land in the Hasdeo Anand forest area.

Hasdeo Anand is one of the last unfragmented forest landscapes in Central India and the economic value of its forest resources can far exceed the value of coal mined. Moreover, this is a part of the catchment of important rivers and the adverse impact of coal mining in the heart of such a rich forest catchment will have long-term adverse implications for the rest of the country. Apparently, MEFCC, under undue pressure, affixed its rubber stamp on the proposal for diversion of such a huge forest land for coal mining, ignoring the expert views of its own institutes.

According to a study, ( India has lost 668,400 hectares of forest land on average between 2015 and 2020, becoming the second largest loser of forests after Brazil, an unenviable distinction indeed! That such a loss of forest should happen under the oversight of MEFCC speaks volumes of the casual manner in which MEFCC has been dealing with India’s precious forests, violating its own obligation under Article 48A of the Constitution.

As I mentioned in my earlier letter dated 6-4-2023, the interests of the local Adivasi communities have been brazenly ignored by the government, as the prior consent of the Adivasi Gram Sabhas had not been taken, violating the requirements under the PESA and the Forest Rights Act.

This case, I am afraid, represents multiple favours granted to the Adani Group, as the government, in the first instance, tweaked the coal block allocation rules in violation of the apex court’s directions and more recently, allowed diversion of such a large forest area for coal mining, though it could have straightaway rejected the Adani Group’s proposal to expand mining in an additional forest area, based on the scientific findings of its own expert institutes.

Apart from the glaring improprieties involved, this is a case of the country losing a large chunk of its no-go forest area that provides rich biodiversity, sustains the rivers that flow down into the plains and affects the local adivasi communities.

The Ministry of Coal and the MEFCC had not cared to consult the Constitutional authority, the NCST, nor the local Adivasi communities whose interests such diversion of forest land would affect on a long-term basis.

I would demand that the decision to divert forest land for coal mining be revoked forthwith and an independent enquiry instituted into the improprieties involved.


Yours sincerely,

E A S Sarma
Former Secretary to the Government of India


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