Madras High Court: In an appeal filed by the State challenging the interim order of “Status Quo” granted in a suit instituted by Madras Race Club (‘Race Club’), which restrained it from carrying out developmental works on government land, a Single Judge Bench of Mohammed Shaffiq, J., held that the order of “Status Quo” hindered and impeded the State from executing projects conceived in larger public interest, namely the strengthening and development of ponds and the creation of an Eco Park. The Court, accordingly, modified the interim order and permitted the State to proceed with the works, emphasising that such projects were environmental and infrastructural measures intended to mitigate floods, promote tourism, improve air quality, and serve as a natural habitat.
Background:
A government order dated 06-09-2024 terminated a lease granted in 1946 over 160.86 acres of land in Venkatapuram, Adyar and Velachery Villages of erstwhile Chengalpattu District, now in Chennai District, which had been leased to the Race Club. A suit was filed by the Race Club seeking to declare the termination of the lease and related government communications as null and void. In that suit, an interim order of “Status Quo” was granted, preventing dispossession of the Race Club from the property.
The State filed an appeal, compelled by impending rains, arguing that continuation of the “Status Quo” order in favour of the Race Club would adversely impact works already commenced. These works included the development and strengthening of four ponds and the creation of an Eco Park, both conceived in larger public interest.
It was submitted that the projects on the land earlier leased to the Race Club were part of flood mitigation measures, intended to store excess rainwater, reduce inundation in surrounding areas, and promote tourism and ecological balance. The respondents, including the Race Club, however, contended that by virtue of the Supreme Court’s order dated 30-10-2025, the remedy sought in the appeal had effectively worked itself out, and raised objections regarding the scope of adjudication.
Analysis and Decision:
The Court emphasised that the order of “Status Quo” impeded the State from carrying out works related to strengthening and development of ponds and the Eco Park. The Court highlighted studies and reports documenting the devastation caused by floods in Chennai, underscoring the urgent necessity for planned ecological buffers, sustainable land-use measures and flood resilient infrastructure.
It was noted that four ponds had already been excavated and required strengthening, and that the proposed Eco Park was intended to act as water storage structures, promote tourism, maintain ecological balance, improve air quality, and reduce pollution. The Court further emphasised that it is necessary to reiterate the grave concerns surrounding air pollution and AQI levels, the reduction of which forms a central part of the rationale behind the Eco Park, since air pollution today is not merely an environmental issue, it has become a public health emergency.
The Court observed that recent episodes of torrential rainfall and severe flooding formed part of a recurring pattern of extreme weather attributable to climate change. The Court relied on Article 21 of the Constitution and its international obligations, stressing that State bears a non-delegable duty to adopt preventive, infrastructural, and regulatory measures to safeguard citizens from foreseeable climate-related harms. The Court further relied on Reliance Natural Resources Ltd. v. Reliance Industries Ltd., (2010) 7 SCC 1, wherein the Supreme Court while explaining the scope of Article 39(b) of the Constitution and the constitutional command regarding distribution of material resources contained therein emphasised that State must act to secure common good
The Court observed that it is relevant to bear in mind that, in terms of Article 39(b) of the Constitution, the State shall frame policies directed towards securing ownership and control of the material resources of the community and ensure that they are distributed so as to best sub-serve the common good.
The Court underscored that public interest is a key consideration in granting interim injunctions. The Court further reiterated that the Eco Park and ponds were firmly rooted in larger public interest, necessary to mitigate flooding, reduce pollution, promote tourism, and serve as a natural habitat.
Accordingly, the Court allowed the appeal, modified the order of “Status Quo,” and permitted the State to proceed unhindered with the projects.
[State of T.N. v. Madras Race Club, O.S.A. No. 335 of 2025, decided on 25-11-2025]
Advocates who appeared in this case:
For the Appellant: P. Wilson, Senior Counsel for D. Ravichander, Special Government Pleader
For the Respondents: Vaibhav R. Venkatesh
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