The petitioner filed a public interest litigation claim against two iron and steel companies, because they allegedly created health risks to the public by dumping waste from their factories into the nearby Bokaro river. The petitioner also claimed that the State Pollution Control Board had failed to take appropriate measures for preventing this pollution.

As part of his claim, the asked the Curt to take legal action against the company based on the Water (Prevention and Control of Pollution) Act of 1974 and furthermore requested permission to collect waste in the form of sludge and slurry by himself as interim relief. The State Pollution and Control Board claimed that it had sufficiently monitored the quality of effluent waste entering the river and the respondent companies claimed that they had adhered to the Board’s instructions concerning the prevention of pollution.

The Court found that the Board had indeed taken effective steps to prevent the waste discharge from the factories into the river and thus dismissed the petition. Furthermore, it was held that the petition did not qualify as a public interest litigation, because it was filed by the petitioner’s own interest in obtaining larger quantities of waste in the form of slurry from one of the respondent companies from which he started to purchase slurry several years prior to the petition.