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Urbanisation has grown at an exponential rate over the last three decades. As a result, big cities and centres saw exponential population growth. However, this urbanisation has come at a cost, which is the destruction of the environment and the depletion of natural resources. This imbalanced growth in metropolitan cities needs the implementation of an urban policy as well as sustainable real estate practises. The concept of sustainable real estate was broken down in great detail in the first portion, and in the second section, the author follows the analytic history from the inception of sustainable development to the introduction of sustainable real estate. In the third segment, we examine the National Urban Policy Framework and its impact on society. Finally, the fourth section discusses the relationship between urban policy and other types of policy. Overall, the findings of this extensive study shed light on the complex relationship that exists between urban policy and sustainable development.

The study’s primary aim is to examine the Indian Urban Policy approach in the context of Sustainable Real Estate. The climate is changing and is affecting the quality of life on Earth. The effect of climate change on developing countries like India is unprecedented. Urbanisation already led to lopsided growth. Therefore, the aim of the study to examine the existing legal framework in the context of Sustainable Real Estate and work on the issues attached to it so that appropriate solutions can be applied.

This research paper is based on the latest cases and is updated statutes. So a separate review of the literature is not required.

1. From ‘Sustainable Development’ to ‘Sustainable Development Goals’ (SDGs): Long Road Ahead

The concept of sustainable development came to the international stage in the Stockholm Declaration, 1972. Subsequently, World Commission on Environment and Development in its report called “Our Common Future” gave a new dimension to this concept. Thereafter, United Nations Conference on Environment and Development (UNCED) was held in Rio de Janeiro in the year 1992 which was followed by Earth Summit wherein 105 countries exhibited their dedication towards sustainable development[7]. Since then, the concept of sustainable development has gathered immense confidence and support from all over the world. In fact, it is noteworthy that the principle of sustainable development is embodied in Section 20 of The National Green Tribunal Act, 2010 in India which clearly proves that encouraging sustainable development is the law of the land. In furtherance of building a sustainable society, 195 countries in the world had entered into a commitment in the year 2015 to improve the face of the world within 15 years from then i.e., till the year 2030. Keeping in mind the global scenario, these countries kept their eyes on essentially 17 core issues which required immediate attention, which are termed as SDGs. These SDGs are integrated and indivisible and balance the three dimensions of sustainable development: the economic, social and environmental.[8] All the countries have been making best efforts to achieve these goals, however, each country has its own unique to way to tackle the challenges faced by it depending upon the gravity of the situation. One of these goals is to build, ‘Sustainable Cities and Communities’ (SCC).

Therefore, India soon initiated the process of building a comprehensive policy to meticulously execute Goal No. 11, which provides for developing sustainable cities and communities, by putting its best foot forward. India is a developing economy and supports around 17.7% of the world population. As per the available statistics, in the year 2020, the Indian cities sustained 34.9% of the Indian population.[9] Needless to mention, this trend is on a constant increase. It is thus imperative that Sustainable Cities and Communities are developed to support the increasing urban population. NUPF 2018 is a step in the right direction, whose objective is to draft a comprehensive urban policy which shall work towards building of sustainable cities.

1.1 Right to live in a City

We live in an era, where too much political energy is involved in the protection and preservation of Human Rights and therefore, in protecting and securing a better world. In this regard, building a City, is one of the most successful and consistent efforts on the part of mankind. This is nothing but remaking the world in a particular and definite zone called as the ‘City’. The ‘Right to City’ for some is a cry and for others is a response.[10] City primarily is the by-product of Colonialism and was established to have all the necessary facilities at one place, right from drinking clear water to electricity, sanitation, pollution free environment etc. A city was primarily situated in an urban setup, where a person could live with dignity and where the necessary means of livelihood are available within the close vicinity. But, to upkeep with the urban facilities, good number of resources are used by the Cities which affects its sustainability and future growth.

1.2 Understanding ‘Sustainable Cities’ and ‘Sustainable Real Estate’: Integrational Issues and Concerns

The word ‘sustainable’ means ‘that can continue or be continued for a long time[11]. Sustainable development is a development that meets the needs of the present without compromising the ability of future generations to meet their own needs. It aims at assuring the on-going productivity of exploitable natural resources and conserving all species of fauna and flora.[12] What does the term ‘Sustainable City’ imply? A Sustainable City ensures clean water and food, clean air and optimum utilization of resources to generate energy. Thus, a healthy environment to grow and prosper, forms the essence of a sustainable city. The population in a sustainable city is in a position to contribute to the society and thus, drives the economic growth of a country. This clearly implies that sustainable city is a sine qua non for sustainable development. And, it is essential to know, that there cannot be a possibility to have a sustainable world, without having sustainable cities. It is the Cities only, where on one hand, the human race would survive and on the other hand, the future of the biosphere would be determined.

‘Ecologically Sound Infrastructure’ (ESI) coupled with modern and innovative technology has given birth to Sustainable development in real estate sector, which has gained immense popularity in the present times. This has given more worth to the investment since it has long lasting benefits. Energy demands are reduced with better and limited utilization of available resources. Sustainable Real Estate (SRE) as a policy works effectively towards providing ‘sustainable infrastructural support’ to both, the existing and the future infrastructural demands of the sustainable cities. And, towards this goal, the promotion of ‘Sustainable Buildings’ is been done, so as to improve water and energy efficiency. Along with energy efficient sustainable buildings, the ‘Urban Coordinated policy’ has also covered Affordable Housing for all so as to not only make sustainable cities but also to build an inclusive society which implies a city, where people from every walk of life would live and sustain.

2. National Urban Policy Framework (NUPF) 2018: Coordinating with Other Schemes

The second comprehensive report on ‘Global State of Urban Policy (GSUP) 2020: Achieving Sustainable Development Goals’ prepared jointly by the Organisation for Economic Co-operation and Development, United Nations-Habitat and Cities Alliance, as a part of National Urban Policy Programme (NUPP) 2016, was an eye opener. The whole world has been facing the issue of building sustainable cities.[13] Indian response to the same was NUPF 2018, which was drafted keeping in mind ten pertinent guiding principles being (i) Building Cities as the clusters of ‘human capital’, which require (ii) a ‘sense of place’ (iii) Paradigm shift in making Master Plans from being static to evolving ecosystems. Similarly (iv) The modern cities would be planned keeping in mind the density of the population and (v) Necessity for ‘Public spaces’ which would eventually encourage the ‘social interactions’ among the people (vi)  Building ‘Multi-modal public transport’, based on popular model of mass public transport system which has the potential to be the backbone of the Contemporary Sustainable Cities (vii) Making ‘Environmental sustainability’ polices for the Cities (viii) Developing ‘Financially self-reliant’ cities along with (ix) Clear and ‘Unified Leadership’ and (x) Developing modern Cities as ‘Engines of regional growth’.[14] These are the core principles based on which, NUPF 2018 was crafted and therefore, it works like a umbrella policy to look after both (a) the planning aspects of the cities, which eventually would cover, both the existing and prospective infrastructure, keeping in mind the factors of economic growth, which is also inclusive of, building sustainable inclusive cities and (b) financing these sustainable cities and therefore, it simultaneously works on developing a new cooperative and competitive federalism, within the constitutional framework. The NUPF 2018 is divided into Ten sections addressing various functional areas, which are being discussed hereinbelow:

i. Urban Planning

The action taken in regard to Urban planning is comprehensive unlike earlier detailed Master Plans, which were rigid and completely unadaptable to the development and had therefore, caused congestion and environmental degradation in the cities. This led to the unplanned urbanisation, which was lacking the link between the spatial and function aspects. Therefore, it is proposed to have planning at all the three levels i.e., at City, State and Centre levels for taking well organized steps.  

ii. Urban Economy

To secure an Urban Economy and to make it more inclusive, social protection of the informal work force is proposed under NUPF, 2018. In fact, NUPF, 2018 proposes balanced network of settlements, which will bring the much necessary coordination between the rural and urban sustainable planning. It will help in connecting the rural infrastructure with the urban for better results. 

iii. Physical Infrastructure

The unplanned growth of the urban cities has led to various infrastructural issues such as, inadequate sewerage system and because of which, high density of population lives either in slums or in unauthorised colonies and therefore, a high percentage of population is dependent on public toilets. The list of infrastructural issues is very big which includes the problem of waste management and mass transport concerns for high price apartments and affordable housing policy. NUPF, 2018 at city level is proposing to prepare a City Comprehensive Urban Plan (CCUP) which will include all the functional areas in a holistic manner.  

iv. Social Infrastructure

The pandemic (Covid 19) has already posed a huge challenge to the government to build a better social structure so that the persons living at the margins do not face the brunt. It is therefore necessary to have sustainable infrastructure to provide better facilities for education especially for primary and higher secondary education. Health is the other key area which requires an urgent attention so as to check the spread of pandemics, especially, access to medicines and other health services. Setting up of Mohalla Clinics in Delhi[15] has been one such pertinent step.

v. Housing and Affordability

SREP plays a key role in fulfilling the aims of this indicator. To carry the goal of building sustainable and affordable cities, the government had launched Pradhan Mantri Awas Yojana (Urban) – PMAY (U) in 2015 whose purpose was to provide affordable housing in urban areas. Though the scheme primarily aims to fulfil the shortage of housing facility but there are various other ways also to protect housing such as (i) by protecting forced evictions by securing tenancy (ii) building effective rules for buying and selling of the housing units and (iii) securing persons from market induced evictions. The rules to protect tenancy rights were bent largely due to the unprecedented pandemic when the threat of spreading of virus has panicked the whole nation and therefore, working on providing sustainable housing with affordability is a crucial area which needs to be worked upon.

vi. Transportation and Mobility

Increased traffic and congestion on the roads create havoc both for the environment and the human beings. There is a strong need to search for feasible alternatives to this problem or else human beings would be subject to serious health hazards. Building mass transport infrastructure is no doubt, the alternative but it is a daunting task, because of the already existent infrastructure, which was not created keeping in the mind the present rising population and its changing needs.

vii. Urban Finance

Prior to proceeding with the development process, one has to be mindful of the economics involved. Thus, one of the important questions to be answered is as to what will be the cost incurred towards operation and maintenance of any project? After answering this question to a reasonable satisfaction, raising finance becomes an area of concern. The Municipal bodies ought to be self-reliant and should be able to generate funds on an independent basis instead of borrowing from the State Government. These Municipal bodies are often asset rich and therefore, can utilize these assets to have a rich capital base. Further, the future cost is also to be deliberated upon. Therefore, ‘Outcome based budgeting’ to strengthen the ‘own source revenue’ is put into the framework.   

viii. Urban Governance

Without good governance, neither proper planning can be done nor responsible and transparent governance can be achieved. 73^rd and 74^th Amendments to the Constitution of India were done to add a Chapter on Municipalities and Panchayats in order to govern the rural and urban setup in the country in a better and phased manner. In fact, Resident Welfare Associations (RWAs) also play a huge role in urban planning and governance. The streamlining of the provisions related to property registration is also put under the framework for better urban governance.

ix.  Urbanisation and Information System

Development of a single window information system is long due where one can easily access all relevant information in reference to Urbanisation including handling of complaints against various types of services. Almost all the cities are carrying multiple layers of overlapping system of governance, where sometimes, it is difficult to identify the exact department for addressing the governance related concerns. Though in past many years, the government has used digital technology in a number of ways to address governance issues such as (a) Single application based technology to address urgent problems including filing of online complaints in different departments which are independent and not inter-connected with each other (b) The use of technology after the creation of new infrastructure such as building electric grids and later developing mobile or electricity applications to pay online bills or register online complaints. Though, these measures seem contemporary but, they lack the necessary inter-connectedness with the other existing or future infrastructures, for instance, lack of interconnectedness of water and electricity body etc. and (c) Many web and mobile based Applications have also been launched but without any effective vision. Thus, contemporary and more coherent use of technology is necessary for better results. The definitive use of artificial intelligence certainly would increase the governance quotient of the City. 

x. Environmental Sustainability

Focussing on the sustainability of the environment should be at priority since without the same, sooner there will be no place to live and actually, the concept of city will not exist. By making SRE policy, the issues and concerns regarding the environment protection would be automatically taken care of. 

Above discussed ten principles primarily have a definitive positive role to play in the context of environmental sustainability. However, achieving SDG No.11 can be a possibility only if Government comes up with a comprehensive Sustainable Real Estate Policy (SREP), whose focus would be to work in coordination with the other ministries and schemes.  This will create cohesive SREP planning, which would comprehensively cover all the issues related to ‘Urbanisation’.

3. Implementing NUPF, 2018: Sustainable Real Estate in Actual Practice

3.1  Integrated Nature of Operation

NUPF, 2018 lays stress on integrated and consolidated approach to develop smart cities. This involves a single program with a single mechanism for operation. This will avoid any confusion or inconvenience faced by the States who would have been otherwise compelled to adhere to multiple programs and instructions.

3.2 Inclusive approach

NUPF, 2018 encourages inclusive approach wherein all the States and Cities are permitted to participate even if they have less capacity to face challenges. This helps in developing a coordinated policy for better governance.

3.3 NUPF, 2018 is Public centric

One of the core features which drives NUPF, 2018 is it being ‘people centric’. This implies that the policy aims to revolve around the needs of the people which shall ultimately occupy the smart cities. The changing necessities have to be carefully analysed and assessed. Only subsequent thereto, efforts can be made to realise them through a channelised approach which will ensure positive results.

3.4 Collaboration between Central, State and Local Governments

It is well said that no man ever steps in the same river twice. Similarly, the society can never remain static and the needs of the people dwelling in the society keep changing. In fact, the needs keep increasing with the rise in population and also with the advent of new technology. NUPF, 2018, also emphasizes on the collaboration between the Central, State and Local Governments to realize the changing needs of the citizens with optimum utilization of available resources and funds. Further, several local bodies can work jointly and generate more funds. The collaboration also reduces risk factor and helps in sharing of expenditure. Further, the skill and knowledge at one level can be harnessed by the other level to ensure that the citizens are exposed to better facilities and infrastructure.

3.5 NUPF, 2018 and Good Governance: Transparency

Another distinct feature of NUPF, 2018 is transparency. The policy ensures that the work done by the Government body, at each step, shall be within the explicit knowledge of the citizens and open for comments and criticism. The people, who are the best persons to know their needs, can accordingly judge and also extend their views on the steps taken by the government for their sustenance.  This shall promote accountability of the government and also encourage participation of the citizens in the decision-making process which shall in turn assist in uprooting the problems prevailing in the society.

3.6 Innovation: Key to Attain more output with less Input

As the term ‘smart city’ is itself illustrative, one has to act smart. The available resources of energy are depleting fast and the depletion has to be checked with immediate attention. NUPF, 2018, thus focuses on attaining more and better facilities by investing less time, money and energy. This is only possible with change in the thought process resulting in innovation in the obsolete and stereotyped technology. This shall ensure that the scanty resources are used in a most advantageous manner. Safe communities, better transportation, access to modern technology, well-developed infrastructure along with healthy environment to work and live, can be easily achieved by carrying out innovation right from the grassroot level till the peak.

3.7 Demand at Priority

NUPF, 2018, intends to keep the demands and the requirements of the people at top priority. This will enable to keep an eye, clearly on the aim and the end result, without any digression towards undesirable areas or issues which can also be resolved at a later stage. This shall also save time and energy which is the essence and a pre-requisite for developing a smart city.

3.8 Utilization of funds

Availability of funds is an important area of concern for nurturing a dream of building a smart city. However, after the requisite funds have been arranged, the next pertinent issue which is to be addressed is the utilization of funds. NUPF, 2018 secures a maximum fund which can be drawn by each State, which will in turn be derived on the basis of a formula considering the urban population of a State alongwith the growth rate of population calculated annually. This formula shall also take into account the per capita income of the State. However, the maximum funds which shall be made available to a State can also be decided by any other method which has a consensus between the Centre and State.

3.9 Self-dependence

Building a smart city should not be a faraway dream for any State. To achieve this dream, the States should be self-dependent and self-reliant as far as the drawing and generation of funds is concerned. This is in view of the fact that the Government may not be able to cater all the rising needs of the States to develop smart cities. The smart cities apart from giving a progressive and healthy environment to the people to live, require huge investments which in turn, can prove to be fruitful in future. The States should be thus in a position to raise funds for themselves. NUPF, 2018 suggests appropriate incentives for the States which take such initiatives.

3.10 Autonomy

NUPF, 2018 grants liberty to the States to take their own decisions independently. Various crucial decisions such as source of funds, utilization of funds, adequate infrastructure, developing blueprints of the smart city, engaging appropriate work force etc. are to be taken by the States keeping in mind the aim and objective of the project in hand. Therefore, a holistic approach needs to be adopted to channelise all the available services and resources. This is important to inculcate a sense of responsibility and shall also develop confidence in the States to accomplish the task of building a smart city.   

3.11 The Importance of Database

The idea of building a smart city involves a mammoth task. It has to be borne in mind that building a smart city is a step by step process wherein the performance at each level of the hierarchy is significant and cannot be lost sight of.  Therefore, to convert this idea into a reality, NUPF, 2018 emphasises on the importance of data which is the foundation for developing any project.  An appropriate data base is imperative to ensure better performance at every level. This data shall include all the necessary and core features of the smart city such as number of households, number of members in each household, number of school going children, number of working people, number of people falling in the aged category, provision for adequate number of schools, hospitals, markets, parks etc. Thus, it is right to say that a specialised and advanced data base should be the paramount consideration to achieve the goal of smart cities.    

3.12 Performance

NUPF, 2018 lays stress on performance. The essence lies in performing a task which in turn inculcates learning at every step. In this way, the Cities devise their own procedure to work and come up with their own ways and means to remove any stumble block which comes in their way and causes hindrance in the path of growth and development.    

4. The role adopted by Government of India

It is evident that the States and Cities form the centre stage of action under NUPF, 2018. However, to make this a reality, the Government acts as a facilitator which creates appropriate mechanism for the States and Cities so that they are in a position to generate funds and utilize them properly. This will help them in becoming self-reliant and realize the goal of a smart city.

4.1 Judiciary and Sustainable Cities
The Judiciary in India has always played a vital role and passed protective orders to make sure that the environment is not sacrificed at the cost of increasing human demands and necessities.[16] The judiciary has taken a proactive stand while fulfilling the ideals of a sustainable city.[17] With the population escalating in the cities at an unbelievable pace, the Courts are expecting the States to focus more on developing sustainable infrastructure for the urban cities. Technology and Innovation are the most important policy initiatives of SREP since the whole concept of building future Smart cities is dependent upon the twin pillars of technology and innovation, which are also the symbols of sustainable development. However, while keeping in mind the aim and target to develop smart cities and ensuring sustainable development, we cannot lose sight of the fact that the development should sing in rhythm with the environment. The impact of sustainable development on the environment and ecosystem needs to be carefully and vigilantly assessed and analysed so that the mankind does not pay the cost of this development at a later stage. The Apex Court has laid stress on the repercussions of development on the environment and took note of importance of sustainable development which is nothing but development which does not impair the ability of the generations to come to meet their needs, while meeting the needs of the present generation. The Court also categorically directed the acquisition of only those lands which did not have a negative impact on the ecological system. It was reiterated that the process of development and environment move together.[18] The judicial approach though is inconsistent and lacks uniform applicability.[19]

‘Urbanisation’ is inevitable and NUPF, 2018, clearly map lines, as to how India is planning to achieve the SDGs by 2030. However, the NUPF, 2018, visions, the future urban India as a place where people will (i) live with ease and dignity in the presence of (ii) a responsive governance which will (ii) continuously work towards achieving sustainable environment along with (iv) economic growth with rapidity where people would have (v) better livelihood opportunities. Though NUPF, 2018 is proposing a framework with very ease and comfort but the fact remains that a number of policy issues which have been addressed are either very expansive in implementation or are expensive and therefore, run out of budget and scope of NUPF, 2018. However, one has to appreciate that there is a huge difference at the level of planning and execution of such a policy, which has not been drafted while keeping in mind the practical problems which crop up due to the existing infrastructure. Similarly, though the Global State of National Urban Policy (GSNUP) was adopted in consonance with the Sustainable Development Goals Model but unfortunately, attaining Goal No. 11 requires a tailormade SRE policy. And, when it comes to the policy of ‘Inclusion’, the SRE policy still holds water. However, the execution at policy level, still needs clarity. Though the question which still haunts is as to whether a ‘sustainable city’ will ever be a possibility?[20] The answer to this question probably lies in formulating a comprehensive SRE Policy which shall be able to deal with all the issues appropriately.

Endnotes 1. It is a multi-disciplinary approach to address the broader issues of planning cities into an evolving system. 2. The Chapters on justiciable ‘Fundamental Rights’ (FR) and non-justiciable Directive Principles of State Policy (DPSP) in the Constitution of India, committed to build a healthy and sustainable environment, where everyone would have the right to live with dignity. 3. It is estimated that there will be a huge demographic shift from 2011 to 2031 in terms of urban population (from 377 million people to 558.8 million people) which would certainly affect the demand of sustainable housing in the Indian cities. See National Urban Policy Framework (NUPF): Strategic Intent, Ministry of Housing and Urban Affairs, Government of India (GOI), (2018) p. 7 for further discussion on the demographic shift of population towards ‘Urban Settlements’ and its overall impact on the Urban Cities. 4. See Sustainable Development Goal (SDG) No. 11, which provides for building an inclusive, safe, resilient and sustainable cities and human settlements. 5. See Sherif Goubran, Tristan Masson, and Margarita Caycedo, “Evolutions in Sustainability and Sustainable Real Estate” in Thomas Walker, Cary Krosinsky, Lisa N Hasan, and Stefanie D. Kibsey, “Sustainable Real Estate: Multidisciplinary Approaches to an Evolving System, 1st edition, (Palgrave, 2019)”, pp. 11 – 12. 6. See G. Ofori, “The Environment: The Fourth Construction Project Objective?”, Construction Management and Economics, (1992). 7. See Karnataka Industrial Areas Development Board v. C. Kenchappa and Others, (2006) 3 SCC 371. 8. See Preamble to the Resolution adopted by the General Assembly on 25 September 2015, “Transforming our world: the 2030 Agenda for Sustainable Development”, Seventh session Agenda items 15 and 16. 9. See United Nations Population Division, World Urbanisation Prospects, 2018 revisions, (Last accessed on 11.04.2022, 01:10 PM), https://data.worldbank.org/indicator/SP.URB.TOTL.IN.ZS?locations=IN). 10. See Henri Lefbvre, Writings on Cities, 1st edition (Blackwell Publishers, Oxford, UK, 1996) p. 147. Also see David Harvey, Rebel Cities: From the Right to the City to the Urban Revolution, 1st edition (Verso, New York, USA, 2012) pp. 2 – 26. 11. See Cambridge English Dictionary (Last accessed on 10.04.2022 at 10:00 PM https://dictionary.cambridge.org/dictionary/english/sustainable). 12. See Report of the World Commission on Environment and Development Our Common Future, Brundtland Commission, United Nations, transmitted to the General Assembly as an Annex to document A/42/427 - Development and International Cooperation: Environment, 1987. This Report at Point No. II (Common Challenges), topic 9 had covered the urban challenge of growth of the Cities. 13. See Nina Jatana and Alistair Currie, “Hitting the targets: The case for ethical and empowering population policies to accelerate progress towards the Sustainable Development Goals”, 1st Report (2020, Population Matters, p. 15) (last accessed on 10.04.2022 at 06:45 PM). Nina and Alistair are informing that it is necessary to know that almost half of the world’s population in the present times is living in urban cities. And as per one estimation, by 2050 it will rise to 68%. The increase in urban population is outpacing the infrastructural facilities provided in the urban cities such as clean drinking water, access to health, jobs and education for a dignified life and sanitation, etc. Since, 1992, the pace of urbanisation has doubled which has led to habitat loss as the land use has shifted for human habitation. The house demands in the Cities has led to evaporation of ‘green spaces’ which were necessary for the healthy ‘physical and mental health’. 14. See Solution Exchange for the Urban Transformation of India, Ministry of Housing and Urban Affairs, Government of India, (Last accessed on 10.04.2022, at 07:30 PM) https://smartnet.niua.org/nupf). 15. Mohalla Clinic is a small community clinic which provides free selective heath services including medicines and tests. 16. See Vellore Citizens’ Welfare Forum v. Union of India, (1996) 5 SCC 647 and Intellectuals Forum, Tirupathi vs. State of A.P. and Ors. (2006) 3 SCC 549. 17. See N.D. Jayal And Anr v. Union of India And Ors, 2003 Supp (3) SCR 152. Also see State of Himachal Pradesh v. Ganesh Wood Products, [1995] 6 SCC 363 for understanding ‘inter-generational equity’ and M C Mehta v. Kamal Nath, [1997] 1 SCC 388 for ‘public trust doctrine’. Both can be read in the context of sustainable development. 18. Karnataka Industrial Areas Development Board v. C. Kenchappa and Others, (2006) 3 SCC 371. 19. See Shalini Iyengar, Nives Dolšak and Aseem Prakash, “Selectively Assertive Intervention of Indian Supreme Court to Enforce Environmental Laws”, Sustainability 2019, 11, 7234 (doi:10.3390/su11247234) p. 1 20. Hisham Moustafa, HUsam AIWaer, and Tamer Gado, “Sustainable Cities Possible or Impossible: A critical Review”, Sustainable Architecture and Urban Development (Last accessed on 11.04.2022 at 09:45 PM, https://www.irbnet.de/daten/iconda/CIB_DC22730.pdf) p. 447 – 448.