Indian Oil Corporation Ltd. v. Deepak Sharma & Ors

 The NGT cannot abdicate its adjudicatory function to expert committees, and orders passed without hearing affected parties violate principles of natural justice.

Background

Challenge to NGT orders stalling petrol pump establishment.
A third party challenged the setting up of a petrol pump alleging violation of CPCB siting guidelines. The NGT referred the matter to committees and kept approvals in abeyance without final adjudication, later issuing directions without hearing affected parties.

Issues Framed

  1. Whether the NGT can delegate adjudicatory functions to expert committees.
  2. Whether orders passed without notice and hearing violate principles of natural justice.
  3. Whether the proposed petrol pump violated CPCB siting guidelines.

Court’s Reasoning

1. NGT Cannot Abdicate Adjudicatory Function

  • The Court held that the NGT is a statutory adjudicatory body under the NGT Act and must decide disputes itself.
  • Expert committees are only assistive, not decision-making authorities.
  • Delegating final decision-making amounts to abdication of jurisdiction.

2. Role of Expert Committees

  • Committees can:
    • gather facts,
    • provide technical inputs.
  • But final adjudication must be by the NGT after hearing parties.

3. Violation of Natural Justice

  • The NGT passed orders:
    • without issuing notice,
    • without allowing objections to reports.
  • This violates s. 19(1) NGT Act, 2010 and foundational principles of natural justice.

4. Improper Reliance on Committee Reports

  • The NGT failed to independently evaluate the reports.
  • Blind acceptance of committee conclusions without reasoning is impermissible.

5. Application of CPCB Guidelines

  • No violation of siting criteria was established:
    • Area classified as commercial, not designated residential zone.
    • Distance requirements not shown to be breached.

6. Locus Standi Concerns

  • The applicant failed to demonstrate any direct grievance or proximity, raising doubts on locus.

Decision / Disposition

  • Appeals allowed.
  • NGT orders set aside.
  • Matter directed to be reconsidered by District Magistrate; petrol pump to be permitted if compliant with law.

Ratio

An adjudicatory authority like the NGT cannot delegate its decision-making function to expert committees, and any order passed without affording parties an opportunity of hearing violates principles of natural justice and is liable to be set aside.

Case Details

Citation: 2026 INSC 278
Decided on: 23 March 2026
Case Title: Indian Oil Corporation Ltd. v. Deepak Sharma & Ors.
Court: Supreme Court of India
Bench: Sanjay Kumar, K. Vinod Chandran, JJ.


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