Environment protection as it exists today is more in the nature of response to a public outcry over government apathy. When the Indian law makers fashioned the constitution, little did they envisage the need for environmental legislation. The adoption of the great political document in 1950 was, therefore, sans any specific provision relating to environment protection or nature conservation. But, with the next few decades witnessing a growing public outcry about the intensifying problem, efforts were made to address some of these concerns in principle. Consequently, certain aspects relating to environment were broadly incorporated in the framework of the Constitution in 1970s and 1980s. Two major developments in this connection deserve mention. The first was the enactment of 42nd Amendment to the Constitution in 1976 which provided for certain special provisions to address environmental concerns. Issues relating to certain aspects, particulary for the protection of forest and wild life, finally found a niche in the Directive Principles of State Policy, the Fundamental Duties and in the Concurrent List. While the state was expected to make endeavours to protect and improve the environment and to safeguard the forests and wildlife in the country, it was regarded as a fundamental duty of every Indian citizen to protect and improve the natural environment, including forests, lakes, rivers and wildlife and to have compassion for the living creatures. Also, protection of forests and wildlife became a part of the Concurrent List.

Though these constitutional safeguards marked a new beginning in the realm of environment protection, the key word