2012.06.17 citizens objection letter mangar ddp 2031 to dgtcp haryana secy mo ef and ncrpb
Lt Col(Retd) Sarvadaman Singh Oberoi
and other concerned citizens &
Mission Gurgaon Development
and other NGOs
1102/Tower 1, Uniworld Garden
Sector 47, Gurgaon 122018
Date: 12th June 2012
Director General, Town & Country Planning
Directorate of Town & Country Planning, Haryana
Government of Haryana,
Sector 18, Chandigarh 160018
Subject: Objections to the Mangar DDP 2031 with the purpose of
affording Protection of Faridabad Aravallis hilly areas and deemed
forests including Mangar Bani Sacred Grove from real estate pressures/
mega recreational zones including agricultural zoning in the Mangar
1. Please find attached my Objections/ Suggestions for Draft Development
Plan-2031 AD, Mangar, released for objection by the said government
on 17 May 2012/ 21 May 2012.
a. We are filing (rendering and/or making available) objections and
suggestions in the form of electronic record(s) as per Information
technology Act 2000. My filing is in form of an email.
b. As per provision of Sections 6A & 87 Information Technology
Act 2000 and Rule 5 of Information Technology (Electronic
Service Delivery) Rules 2011 you are requested to keep my filed
electronic records accessible to me and others on your website
and/or computer resources immediately.
2. We, the undersigned, residents of southern Haryana and Delhi, are
deeply concerned about the future of Gurgaon, Faridabad and Delhi,
whose groundwater and forest ecological security is critically dependent
on the Aravalli hill ranges of southern Haryana, which are already
devastated by past mining.
3. We are dismayed, that, instead of identifying and protecting the last
remaining patches of natural forests and wilderness which are also
critical groundwater recharge zones as identified by Central Ground
Water Board, as a forest zone, or sanctuaries or national parks, the state
government of Haryana is making provisions for and therefore directing
for the use of deemed forest lands for non-forest purposes. This is
being effected by including 1000s of hectares of Faridabad Aravalli
hilly areas into an agricultural zone which allows Mega Tourism projects
and other uses under a new master plan – Mangar DDP 2031, in prima
facie violation of section 2(ii) of the Forest Conservation Act (FCA) and
also planning huge highways through the Aravalli hills.
4. The Ministry of Environment and Forest has also requested the state
government to identify its deemed forests and make a geo-referenced
map vide a letter F.No.11-09/2012-PC dated 18th May 2012 addressed to
Chief Secretary, Haryana. The MoEF has further advised that Mangar
DDP 2031, containing provision for non-forest activities, within the
areas, which (as per the said petitioners) may be defined as “forest”
for the purpose of the Forest (Conservation) Act, 1980 be kept in
abeyance till such time geo-referenced map is prepared and submitted to
5. We have grave objections to the hilly area zone in the DDP being
conflated into the agriculture zone resulting in a combined said
‘agricultural’ zone under this proposed development plan, which is not
in consonance with the ground reality of hilly zone being the Aravalli
Range, that cannot be interchangeably called an agricultural zone. In fact
the hilly zone of the Aravalli Range:
i. Is scrub, open, or moderately dense forests as identified by forest
cover in the State of Forest Report 2011, and earlier reports of the
Forest Survey of India.
ii. Includes Northern Dry Deciduous Forest (Group 5/Subgroup 5B) and
Northern Tropical Thorn Forest (Group 6/Subgroup 6B) types of
forest as per the definitive classification of Forests in India by
Champion HG & SK Seth, entitled, “A revised survey of the forest
types of India” published in 1968 by Manager of Publications,
Government of India, Delhi.
iii. Is deemed forest as per Godavarman and Lafarge judgements of the
Hon’ble Supreme Court, irrespective of notification, ownership or
condition of forest.
iv. includes over 30% of the total forest cover of the district of
v. that has been used for grazing, fuelwood and timber collection for
hundreds of years by the local gujjar pastoral community and is
therefore forest by ‘context’
vi. is classified as gair mumkin pahar – which refers to it not being
suitable for agriculture as per revenue record land type classifications
includes several water bodies and johars
includes the mangar bani sacred grove,
amongst the largest collection of aravalli native vegetation, which has
vanished in the rest of Delhi, Faridabad and Gurgaon belt.
ix. includes the catchment area of the Dhauj lake which is under stress
and has turned seasonal like Badhkhal and Surajkund lakesand whose
catchment therefore needs to be protected.
x. a critical ground water recharge zone (as identified by the Central
Ground Water Board) that is key to the groundwater security of
Faridabad and Gurgaon (which are 100% and 70% dependent on
groundwater for domestic supplies)
xi. where infiltration of rainfall has been valued at Rs 24.9 lakhs / ha.
is an important wildlife habitat for the district
is a wildlife corridor connecting Asola Bhatti wildlife
sanctuaries in Delhi with the Aravalli hills of Gurgaon.
has been identified as a significant bird habitat,
xv.where the Hon’ble Supreme Court has ordered a “ban on mining
activity and pumping of groundwater imposed in an area upto 5 km
from Delhi-Haryana border on the Haryana side of ridge and Aravalli
hills.” (order dated 6.5.2002 in WPC 4677 of 1985).
Is a barrier against desertification
Has been devastated by legal and illegal mining and needing
long term restoration and rehabilitation as per the Hon’ble Supreme
6. However all of the items (i) to (xxiii) in Appendix B of the Mangar DDP
2031 proposed for the agriculture zone in the zoning regulations are
incompatible with the eco-sensitive nature of the hilly Aravalli zone.
a. The Mangar DDP 2031 itself states in the section on Topography,
that “Apart from the Aravalli ranges, the rest of the area is
plain and is being used for agricultural purposes”. This implies
that the Aravalli hills are not being used for agricultural purposes
and this, in fact, is the case on the ground.
b. Indeed, the revenue records for these villages clearly state the hill
land to be gair mumkin pahar, i.e. not suitable for agriculture.
c. Further, apart from mining, virtually all of these activities in
Appendix B the master of the Mangar DDP 2031 are non-site
specific activities, which intrinsically have nothing in their nature
that requires them to be undertaken in the Aravalli hills, indeed
they can easily be allowed outside the Aravallis in the remaining
80-90% of the district. In fact allowing these activities in the
Aravalli hills will lead to permanent damage to the eco-sensitive
nature of the hills. Of these various proposals, the proposal for a
500 ha mega tourism zone is particularly problematic.
7. Accordingly, we object to the inclusion of the hilly zone into the
agriculture zone and DEMAND that, in keeping with the Hon’ble
Supreme Court of India’s judgements that “the Aravallis must be
protected at any cost” (xx.5.2004), and various other judgements relating
to mining, groundwater, construction, and for all the reasons 5.i to 5.xvii,
and 6.a to 6.c mentioned above and dealt in detail in the note below, the
Aravalli hill areas zone be delineated clearly in the existing landuse map
and the DDP Mangar 2031 drawing/map. Once delineated we strongly
urge the Aravalli hills be a separate zoning category in the Mangar DDP
2031, and that none of the 23 activities (numbered (i) to (xiii)) proposed
for the agricultural zone in Appendix B of the Mangar DDP 2031, are
allowed in the hilly zone.
8. Instead the Aravalli hill zone should be separately identified and zoned
as a natural conservation area, in consonance with the Aravalli hills
being already zoned as a natural conservation area in the Regional Plan
2021 prepared by the NCR Planning Board, which all NCR states are
mandated to follow under the NCR Planning Board Act of 1985. We
propose a revised Appendix B, with the following activities allowed and
not allowed for the Aravalli Natural conservation zone.
Wildlife protection and management
Afforestation with indigenous species
Identification of natural water recharge zones
Augmentation of natural recharge
Protected Forest /Reserved Forest/ Conservation Reserve /
Community Reserve/ Sanctuary/ National Park / Biodiversity
Heritage Site / Hill Resource Management Society / Joint Forest
No change of land use permission
No construction of boundary walls, buildings, sheds, etc
No drilling of borewells and pumping of water and no
transportation of water from plain areas to the aravallis, except for
public purpose – like supply to schools
No fencing (except by the Forest department)
No demarcation and possession of land
No cutting of trees, except for subsistence fuelwood and fodder
use by village communities, and as per a management plan.
9. The Regional Plan 2021 of the NCR Planning Board (NCRPB) includes
the following provisions related to environment:
a. Refers to industry, mining, construction, cutting of trees and
electrification and states that “No such activities should be
undertaken in the Aravalli range in NCR” (14.2.ix).
b. Land is the most crucial and critical environment resource (14.2)
c. The land use allocation has to be carefully carried out in order to
protect and conserve both surface and ground water resources
d. Master/Development Plans for the towns in the region should
incorporate land suitability analysis for land use allocations
e. While carrying out activities for the development of the region,
provisions under Environmental Protection Act, 1986 and Rules
thereof should be followed, and environmental sensitivity of the
region and existing quality of the environment should be
a. Including the Aravalli hill range gair mumkin pahar area in the
agricultural zone, with its 23 landuse proposals, is contrary to
these mandates of the Regional Plan 2021 stated above.
Accordingly we demand that the the Mangar DDP2031 should
state whether it is in compliance with the Regional Plan 2021
prepared by the NCRPB, particularly the landuse provisions and
provisions relating to environment including the ones specified
above. If not, we object to this non-compliance in Mangar DDP
2031 and demand that the Regional Plan 2021 be fully compliant
particularly the landuse provisions and provisions relating to
environment including those specified above.
10. The areas/zones mentioned below located in NCR should be conserved/
protected as per the Regional Plan 2021, section 14.2.viii, Their
applicability in the Aravalli Range areas including in the Mangar DDP
2031 is analysed in the table below and these categories should be
protected or created as the case may be in the Aravalli Range areas.
The areas/zones mentioned below located
in NCR should be conserved/protected:
Applicability in the Aravalli Range areas
included in the Mangar DDP 2031
These should be declared
Forests other than reserved and protected
Entire aravalli range is included in this
Monuments-National, State, Local
Ballu Raja’s rock fort, Old Sarai’s, Ancient
Several archeological sites. Including rock
paintings, ancient pottery shards etc
Mangar Bani sacred grove is a natural heritage
The Mangar Bani sacred grove, the Dhauj Rock
climbing area, the Dhauj lake are well known
Aravalli range including Mangar Bani should
be made a national park
Aravalli range including Mangar Bani could
also be made a sanctuary
Areas with endangered species-flora and
Inter-state Aravalli Biosphere Reserve proposed
to be studies by UNESCO
Includes the Dhauj lake,
Resorts/areas of tourist interest
Mangar Bani, Dhauj lake and their
buffer/environs. Aravalli plateau
Dhauj lake and various johars (local water
bodies) in the Aravalli hills
Springs/water recharge areas
Entire Aravalli hills identified as a water
recharge area by the Central Ground Water
Other environmental resource areas
Wild life habitat and corridor
11. Existing and Proposed Landuse. The Mangar DDP 2031 does not
discuss the existing land-use in the text of the plan. The proposed
landuse is also partially stated in the section on Major Land Use
a. The total area of the plan is not mentioned.
b. The area under Aravalli hill ranges is not mentioned.
c. There is no mention of the existing landuse - the extent of forest
cover, the groundwater recharge zones, the wildlife habitat and
corridors etc, the wet and dry mining pits that need long term
restoration etc, areas under agriculture, the water bodies and
johar’s etc that need protection, the commonlands that cannot be
d. As per section (14.2.iii) of the Regional Plan 2021 , Development
Plans should incorporate land suitability analysis for land use
e. Accordingly, we urge and suggest the TCP dept. assess the
existing landuse especially aravalli hill range, forest cover and
water bodies, mining pits area, and make a quantitative and map
presentation of the existing landuse – in terms of total actual and
proportional area, in the text of the plan.
f. Even the proposed landuse is partially described at only 529.47 ha
and only covers open space and transport. Rest of the landuse is
not described in the major landuse proposal, so that the
proportionate impact of each proposal cannot be ascertained.
g. The landuse and zoning proposal are floating in nature. The
mega tourism zones are not displayed on the map, neither is the
university. Given the large scale of these mega tourism zone
activities, they are more suitably categorized as major land-uses
and need to be clearly identified in the map, so that citizens and
the various committees of the TCP dept. can assess whether they
fall in the Aravalli hills and make informed choices about the trade
offs that are involved in these proposals.
h. The full proposed landuse of the entire area covered by the
Mangar DDP 2031 should be quantified and described, especially
the aravalli range and plain agricultural lands.
i. The date on the Existing Land Use Plan bearing drawing no. D.T.P
(F) 2676/12 dated 2nd May, 2012 suggests that it was prepared
after the DDP Manger has been prepared first on 15th July 2010,
and subsequently finalized on 10th April 2012.
j. This implies that neither the existing landuse drawing, nor the area
under different existing landuses, especially for the eco-sensitive
aravalli ranges, was made available for perusal or comment
throughout the statutory clearance process at the meetings of the
District Level Committee in July 2011, the Metropolitan Planning
Committee in August 2011 and the State Level Committee,
chaired by the Chief Minister of Haryana, himself in January
k. Therefore, we object to this faulty clearance of the Mangar DDP
2031 with sharing of partial and incomplete information with the
members of the committees involved and recommend and assert
that the clearance process is null and void.
l. We recommend, that once the existing and proposed landuses are
ascertained and quantified and located on the map, then the
clearances from the three committees – at district, division, and
state level, and citizen comment should be sought afresh.
12. The Draft Development Plan of Mangar, has wrongly classified the
Aravalli hills as agricultural zone, therefore in the same contention this
Development Plan is not valid. It is our contention that the agriculture
zone and the Aravalli hills should be correctly mapped as per existing
13. Aravalli in Natural Conservation Zone.
a. The Regional Plan 2021 mandates a Natural Conservation Zone
that includes the major natural features, identified as
environmentally sensitive areas, such as the extension of Aravalli
ridge, forest areas, rivers, lakes and water bodies (17.4.3).
b. It states that , “The extension of the Aravalli ridge, sanctuaries and
other ecologically sensitive areas be conserved with utmost care
and afforested with suitable species” (17.4.3.i).
c. It also requires that “Detailed Conservation Plans be prepared for
the areas shown as Natural Area Conversation Zone in the Land
Use Plan 2021” (17.4.3.v).
d. Accordingly, we recommend that, given the eco-sensitive nature
of the hilly area/zone falling in the Mangar DDP 2021, as
mandated by the Regional Plan 2021, and given the strategic
location of the area between Delhi, Gurgaon and Faridabad, a
committee of subject matter experts that includes town planners,
foresters, groundwater experts from the CGWB, etc, ecologists,
naturalists, wildlife scientists, environmental economists etc be set
up. The said committee should assess the ecological significance
of the area and undertake a strategic environmental assessment
and develop a Detailed Conservation Plan for the area.
e. This strategic environmental assessment and develop a Detailed
Conservation Plan may be the basis for developing a Mangar DDP
f. Any development plan on a ecologically sensitive area calls for a
vulnerability mapping and land suitability analysis to determine
developable and non-developable zones.
g. It is pointed out that the Delhi Master Plan prepared by DDA has a
chapter on environment based on an environmental assessment.
An environmental assessment by an independent group of experts
should accordingly be undertaken.
14. Zoning protection for Mangar Bani.
a. We object strongly to the lack of zoning protection to the
b. The Faridabad Aravallis include regions such as the Mangar Bani
sacred grove. Just outside Delhi, the Mangar Bani sacred grove is
a micro-habitat of high conservation value and scientific interest.
It contains a unique assemblage of northern Aravalli plants that
has been conserved by local village communities as a protected,
sacred grove. In the entire area of the NCR, this is the last
surviving (relict) undisturbed patch of Anogeissus pendula forest
which has a limited range and distribution and also possibly
includes hundreds of other species of flora. This could attract
provisions for ‘entities of incomparable value’ and is certainly
worthy of special protection as mentioned earlier (Times of India
24 Jan 2012, Mega tourism nod pushes sacred woods to the brink)
c. The Bani should be shown in the existing landuse map and the
proposed landuse map (irrespective of its zoning) so that citizens
and investors are aware of its location.
d. We recommend that in the Mangar DDP 2031 the Mangar Bani
and a suitable buffer area of 400-500 ha around it be included in a
new zoning – natural conservation zone, or forest zone or
sanctuary zone or failing that in the existing open space zone and
steps be taken to notify it as a conservation reserve / wildlife
15. Mega 1000% road upgrade.
a. We object strongly to the proposal to upgrade the village link
road from Faridabad-Gurgaon road to village Mangar-SilakhariDhauj-Alawalpur-Fatehpur Tagga and beyond, from its current 3-6
metres to a proposed 60 meters – an increase of a whopping
1000% or more.
b. Upgrading the road to 60 metres right through the Aravalli hills
will further fragment habitat and restrict movement of wildlife in
an important Aravalli wildlife corridor between Delhi and
c. The purpose of village link roads is to link villages, not provide a
d. As Pali-Dhauj Sohna Road is already being upgraded, and that
will already join up at the start of the Faridabad Gurgaon Road.
Therefore no purpose is served by an additional new road,
unless the objective is to open up currently roadless Aravalli
areas for development, real estate, and mega tourism.
e. Further, prior to proposing the road, forest and environmental
clearance should also be taken, as the road will pass through a
deemed forest area and a sensitive groundwater recharge zone.
f. The master plan should clarified if this road is in compliance with
the Faridabad Mobility plan and the Transportation plans of the
NCR Planning Board.
16. Mega Tourism Zones or Wildlife Sanctuary
a. The Regional Plan 2021 states that “Regional recreational
activities with no construction exceeding 0.5% of the area with the
permission of the competent authority.” (17.5.3.iv).
b. It also states that “The extension of the Aravalli ridge, sanctuaries
and other ecologically sensitive areas be conserved with utmost
care and afforested with suitable species” (17.4.3.i).
c. Accordingly, we recommend that the Mangar DDP 2021 should
clarify that there are no Mega Tourism zone activities in the
Aravalli hill areas, the zones should be specified in the map, and
restricted to 0.5% of the area, as above.
d. Instead the mandate of the The Regional Plan 2021 “Regional
recreational uses such as, regional parks, wildlife sanctuary etc.
(17.5.4.iii)”, may be followed for the Aravalli hill zones in the
Mangar DDP 2021.
17. Forest cover in Haryana is amongst the lowest levels in the country
and needs to be increased by the Mangar DDP 2031.
a. The Haryana Forest Policy 2006 prepared on the basis of
National Forest Policy 1988, which has been held by the Apex
Court in the Lafarge judgement (2011) to have the force of law,
has stipulated that forest cover in Haryana shall be 10 percent
by 2010 and 20 percent by 2020.
b. The Regional Plan 2021 states “In view of the very low existing
forest cover (4.02%), it is imperative to bring more areas under
forest so as to maintain the ecological balance in this region”
a. Whereas the Forest Survey of India Report 2011 has pegged
forest cover in Haryana at a low level of 3.64 percent with
undivided Faridabad at 4.32 percent, which is far below the levels
mandated in both the state Forest Policy.
b. Whereas, on the other hand, the capital of Haryana and Punjab –
the planned city of Chandigarh, has a recorded forest land of 34
km2, which is a full 29.82% of the total area of the city and
includes two sanctuaries covering 26.02 km2 (and 22.8%) of the
c. Similarly, forest cover in Delhi, of South Delhi district (adjacent
to Faridabad district) is 31.33% and New Delhi district is 46.6%.
d. In this context it may also be mentioned that the extensions of the
southern Haryana Aravalli hills, are protected in adjacent areas of
Delhi and Rajasthan as forests.
i. The Northern ridge and central ridge in Delhi were
notified as reserve forests in 1914/1915.
ii. The Asola Bhatti Wildlife sanctuary was notified in
1986 and 1991.
iii. Similarly, extensive areas of Aravalli hills in
Rajasthan are also protected as government forests
and sanctuaries and National Parks.
e. In such a scenario, it is critical and mandated by law (cited above)
that state and district planning activities should be in conformity
with these forest policy objectives and should support expansion
rather than diversion of forest cover areas and deemed forest
areas. This would hold especially true for zoning plans and
development control plans which control and guide land use
change – in which areas to preserve existing landuse and where to
f. Accordingly, given the terribly low forest cover in Haryana and
Faridabad, we object that the Mangar DDP 2031 is not zoning the
entire Aravalli hills as forest zone. We recommend that the
Mangar DDP 2031:
i. identify the little existing forest cover there is in the
district and area under planning,
ii. provide un-assailable and permanent zoning protection
for the little existing forest cover there is in the district
and the plan area, and
iii. identify wildlife habitat and corridors, and
iv. make provisions for zoning non-forest areas as open
space and for afforestation, so that forest cover can be
expanded over time rather than depleted.
18. The entire Faridabad district has been declared an urban zone. The
Aravallis cover less than 5% of the undivided Faridabad district – the
state government still has over 80-90% left to develop and urbanize.
a. The entire hilly zone is recommended to be delineated as a
groundwater recharge and forest conservation zone as per the
letter number 2117-22/ DA, dated 10th December, 2011 send by
the DC Faridabad. The State Level Committee Minutes simply
state that this letter and recommendation has been received, but
does not state why the nature of discussion, why it was not
accepted, and where Faridabad would get its water supply if its
water recharge zones are habitated.
b. Given the small proportion of area of Aravalli hills in the
district and also the small proportion of area of forest cover,
the entire Aravalli range area falling in the Mangar DDP 2031
should be zoned as a permanent natural conservation area/
forest zone /groundwater recharge zone.
19. Gurgaon and Faridabad cities are 70% to 100% dependent on
groundwater for domestic water supply.
Already Gurgaon is
overdrawing groundwater by about 300% of the annual recharge.
Goundwater levels in Faridabad area are also dropping. Given this high
dependence on ground water, the importance of the Aravalli hills for
groundwater recharge and water security and which include the
catchments of several lakes, is heightened.
Due to groundwater flow in all directions (see map attached),
this area has been identified as a recharge zone for groundwater
for Delhi, Faridabad and Gurgaon by the Central Ground Water
Board (CGWB, 2008). “Groundwater outflows from this area
towards all the directions. This area primarily forms recharge
zones for the downstream areas.” (Central Ground Water
Board, 2008. Hydrological investigations in mining areas of
Delhi and Faridabad, Chandigarh: Government of India.,
submitted to the Hon’ble Supreme Court (report attached)
Fractures, joints and cracks lead to high secondary
porosity.“The hard rock formations comprising of hills form
recharge zone for the downstream areas (pg 18)” (CGWB,
2008 cited above).
Groundwater recharge is to the tune of 20,00,000 litres per
hectare per year (1/3 of rainfall of 600 mm) which is worth
approximately Rs 2 lakh per year (@ of Rs 0.10/litre) and has a
Net Present Value of Rs 24.9 Lakhs (5%, 20 years – same as
NPV calculations for CAMPA) and a higher NPV upto Rs 1.5
crores per hectare (Rs 2 lakhs/ha/year x 100 years (4
generations) at 0.1% discounting ( on the lines adopted by
Stern Review – privileging inter-generational equity) (Agarwal
Source: Central Ground Water Board, 2008. Hydrological investigations
in mining areas of Delhi and Faridabad, Chandigarh: Government of
20. The master plan, does not identify or provide any zoning protection to
the catchment of Dhauj Lake, which falls completely within the Mangar
DDP 2031 area and has turned seasonal in the last decade.
a. Faridabad aravallis includes the catchments of several lakes including Badhkal lake, Surajkund lake, Peacock Lake, and Dhauj
lake (which falls within the Mangar DDP 2031), which are critical
for recharge of groundwater for drinking water supply
downstream of city and village areas. All these lakes including
Dhauj lake have turned seasonal in the last decade. Specifically,
the master plan, does not identify or provide any zoning protection
to the catchment of Dhauj Lake, which falls completely within the
Mangar DDP 2031 area and has turned seasonal in the last decade.
b. The Regional Plan (17.4.3.iii) states that, “The areas under water
bodies, ox-bow lakes and paleo-channels and their surrounding
areas as shownin the Ground Water Rechargeable Areas in Map
8.1/Land Use Plan 2021 in Map 17.2 be kept free from any
encroachment/development to allow free flow of water.
Construction activities for human habitation or for any other
ancillary purpose thereto not be permitted. Suitable measures be
taken to maintain the water bodies with the minimal flow/water
c. Just as the Hon’ble Punjab and Haryana High Court has ordered
the catchment of Sukhna Lake be delineated and protected from
construction, in 2012, the Mangar DDP 2031, should similarly
identify the catchment of the Dhauj lake, and the lake catchment
should be zoned as a no-construction zone.
21. Flood Prone Areas. The Mangar village valley and hilly nullahs have
been identified as flood prone in the district gazetteer. The Regional Plan
2021 states that “In the flood prone areas/river beds/banks, no
construction or habitation activities be permitted”. Accordingly water
pathways and flood prone areas may be identified in the Mangar DDP
2021 and zoned as recommended in the Regional Plan 2021.
22. Archeological sites. The region also contains sites of archeological
importance from the late Harappan era (Hindustan Times 6.2.2012 –
Hold Fast to the Past by Nayanjot Lahiri). These sites should be
identified and protected by zoning as natural conservation zone.
23. Wilderness habitat and corridor and micro-climatic benefits.
a. The Faridabad Aravallis (including Mangar Bani forest patch) are
an important wilderness and wildlife habitat adjoining Delhi,
and, contiguous with the Asola Bhatti Sanctuaries in the Delhi
ridge, thus forming a natural buffer to them.
b. Due to their geographic location, the Faridabad Aravallis are a
critical link in the Aravalli forest and wildlife corridor between
Delhi (esp. Asola Bhatti sanctuary) and Gurgaon-Mewat-Alwar
Aravalli hills extending to Sariska National Park and form a large
and still relatively unfragmented habitat. A leopard reported from
Asola Bhatti sanctuary, is likely to have reached via the Faridabad
aravallis. Times of India 3.3.2012 – Bhatti Mines spring to life.
c. The forested Aravallis are recognized as a barrier against
desertification of the Delhi NCR region. They also provide
micro-climatic benefits – reducing dust and temperatures,
mitigating the heat island effect of builtup city areas thus helping
adapt to climate change.
24. Forest conservation and groundwater recharge considerations have
been ignored in decision making. The Forest Department of Haryana
State was reportedly not consulted in preparing the initial draft of the
Mangar DDP 2031, and was apparently not invited to the meeting to
clear it at the State level. Neither apparently was the Hydrology
department or the Central Groundwater Board, which has a regional
office in Chandigarh itself. This points to a broader systemic flaw in
decision making at the state level, wherein groundwater recharge and
forest and wildlife ecosystem service concerns are not represented in
mdecision-making regarding masterplans, which, by deciding zoning,
have enormous influence on landuse decisions and landuse outcomes and
on the protection or destruction of the ecological assets of the area. These
should be rectified.
25. The Deputy Commissioner, Faridabad had organized a field visit to
the Aravallis and has subsequently written to Town & Country
Planning and Forest Departments ,
a. highlighting the deemed forest nature of the Aravallis
b. drawing attention to Mangar Bani sacred grove
c. proposing to protect the entire Aravalli hills under section 4
and 5 of the Punjab Land Preservation Act (PLPA), thereby
restricting landuse change
d. and suggesting zoning the Aravallis for water recharge zone
and forest conservation in the Mangar DDP 2031 “in which
no fencing, groundwater exploitation and construction
activity is permitted.” (letter and minutes of field visit are
e. None of these suggestions have apparently been accepted at the
time of writing.
f. We recommend, that these recommendations be reviewed by
competent independent experts including the CGWB and acted
26. District administration decision to cover all remaining Aravalli hills
under section 4 & 5 of the Punjab Forest Preservation Act (PLPA) is on
hold. The Mangar PLPA proposal is pending with the state govt.
a. Based on the decisions recorded in the field visit minutes on
2.12.2011 (attached as above), and a meeting on 6.12.2011, the
state forest department has moved a case to the state government
of Haryana to notify under section 4 and 5 of the Punjab Land
Preservation Act (PLPA), the remaining gair mumkin pahar areas
(Aravalli hills) of Mangar village in the first instance, (about 2/3
of the hills, only about 1/3 were notified before) and thus provide
them additional protection. However the state Government has
not yet taken a decision to notify the same.
27. District Town Planner’s letter to increase forest zoning from 1800 to
3800 ha (approx.) ignored. The District Town Planner, Faridabad, had
written to his superiors in Chandigarh in December 2012, to increase the
area zoned as forest in the Mangar DDP 2031 proposal from
approximately 1800 ha to about 3800 ha, but this too was not
28. The residents of Mangar village of Faridabad district and the
neighbouring Bandhwari village (Gurgaon district) had also written to
district officials to protect the Mangar Bani and a buffer area of about
400-500 ha. These letters reflect the sentiments of these two villages as
well as that of many villages in the region. The Mangar bani,
remarkably, has been protected locally by the same pastoral gujjar and
other villagers who normally graze their cattle in the hill forests. The
patron saint of the Mangar Bani is said to be Gudhariya Baba who lived
there in times unknown and his spirit is still said to afford protection to
the sacred zone. Given this history of the grove, we recommend that the
Mangar DDP acknowledge the sacred grove in the map and afford it
strict zoning protection.
29. Restrain speculation in land dealings in Eco-sensitive Aravalli areas.
a. The Master Plan for the Faridabad-Ballabhgarh Complex 2011
specifically recognizes the force of speculation in land dealings
along the Gurgaon-Faridabad Road.
b. The Mangar DDP 2031 by proposing Mega Tourism Zone, large
highways thru aravalli areas etc seems to be playing into the hands
of such speculative forces.
c. We recommend that the Mangar DDP 2031 should recognize that
such speculative activities are inappropriate in eco-sensitive areas
such as the aravallis, and that its zoning proposals should aim to
protect the aravalli hill ranges and restrain speculative forces.
d. However on the ground, it seems that a fait accompli situation is
fast arising in the Faridabad Aravallis and may spread to the whole
of the Southern Haryana Aravallis.
Endst No. 1 By Email only to:
1. Ms. Jayanthi Natarajan
Hon'ble Minister of State Environment and Forests
Paryavaran Bhawan, CGO Complex
Lodhi Road, New Delhi 110003
2. The Secretary National Capital Region Planning Board
Ministry of Urban Development, Core-IV B, First Floor,
India Habitat Centre, Lodhi Road
New Delhi- 110003
3. Central Empowered Committee (Supreme Court)
through the Chairman, II Floor, Chanakya Bhawan, Chanakyapuri
4. The Secretary, Ministry of Environment and Forests
Paryavaran Bhawan, CGO Complex
Lodhi Road, New Delhi 110003
5. The Chief Secretary Haryana
Haryana Secretariat, Sector 1
Kindly direct the competent authority to cancel Mangar DDP 2031 because:
1. Grave objection to inclusion of 1000s of hectares of Faridabad Aravalli
hilly areas in prima facie violation of section 2(ii) of the Forest Conservation
Act (FCA) and also planning huge highways through the Aravalli hills in
prima facie violation of National Biological Diversity Act, 2002. (Paras 2,
5(xii) to (xiv), 15 & 16)
2. Grave objection to the hilly area zone in the DDP being conflated into the
agriculture zone resulting in a combined said ‘agricultural’ zone by use of
misleading words "Major Land Use Proposals..proposed to be reserved for
maintenance and preservation of existing activities and is being termed as
agricultural/Hilly zones in the meaning of Act 41 of 1963" whereas Act 41
of 1963 only defines the term "agriculture" and nowhere mentions hilly
zones. (Paras 5, 6 & 12)
3. Hilly area zone of Southern Haryana Aravallis is deemed forest as per
Godavarman and Lafarge judgements of the Hon’ble Supreme Court,
irrespective of notification, ownership or condition of forest. (Para 5(iii))
4. Hilly area zone is classified as gair mumkin pahar – which refers to it not
being suitable for agriculture as per revenue record land type classifications.
5. Hilly area zone includes several water bodies and johars. (Para 5(vii))
6. Hilly area zone includes the mangar bani sacred grove, which includes
amongst the largest collection of aravalli native vegetation, which has
vanished in the rest of Delhi, Faridabad and Gurgaon belt. (Para 5(viii))
7. Hilly area zone includes the catchment area of the Dhauj lake which is
under stress and has turned seasonal like Badhkhal and Surajkund lakes and
whose catchment therefore needs to be protected. (Para 5(ix))
8. Entire Southern Haryana Aravallis, nearly half of which has undergone
creeping urban development in contravention of Supreme Court judgements
over last two decades, is a critical ground water recharge zone (as identified
by the Central Ground Water Board in 2008) that is key to the groundwater
security of Faridabad, Gurgaon and South Delhi. (Paras 5(x) & 19)
9. Irreparable damage was caused to the ecology of Southern Haryana
Aravallis by mining which continues, albeit illegally on a smaller scale,
which can be controlled if kept under satellite survellance. (Para 5(xvii))
10. Hilly area zone of Southern Haryana Aravallis is deemed forest and
hence it be be a separate zoning category which should be separately
identified and zoned as a natural conservation area, in consonance with the
Aravalli hills being already zoned as a natural conservation area in the
Regional Plan 2021 prepared by the NCR Planning Board, which all NCR
states are mandated to follow under the NCR Planning Board Act of 1985.
(Paras 5(iii), 7, 8, 9, 13, 15 & 16)
11. Fatal flaws in Existing and Proposed Land Use Plan. (Para 11)
12. Existing major shortfall in mandated forest cover. (Para 17 & 18)
13. No provision of zoning protection to the catchment of Dhauj Lake,
which falls completely within the Mangar DDP 2031. (Para 20)
14. No provision of zoning protection to Flood Prone Areas and
Archeological sites. (Paras 21 & 22)
15. Wilderness habitat and corridor and micro-climatic benefits against
desertification of Delhi NCR would be lost for ever. (Para 23)
16. Systemic flaw - Forest Department of Haryana State was reportedly not
consulted. (Para 24)
17. Advise of district authorities and requests of local people ignored by
State Level Committee which had no representation of forest or wildlife
officers. (Paras 25 to 28)
18. Fait accompli situation in hilly area zone of Southern Haryana Aravallis
caused by speculative land dealings in violation of laws on disposal of
common user land as laid down by Apex Court in 2011. (Para 29)
Kindly direct the competent authority to cancel Mangar DDP 2031, all
other similar plans and demolish all similar activity earlier carried out in
Southern Haryana Aravallis because of the disastrous ecological
consequences that have been explained in detail in paragraphs 1 to 18 above.
Date: 17 June 2012
Lt Col(Retd) Sarvadaman Singh Oberoi
1102/Tower 1, Uniworld Garden
Sector 47, Gurgaon 122018