Supreme Court Relaxes TTZ Industrial Ban, Clearing Path for IMC Agra

What was decided

The Supreme Court on Thursday relaxed its earlier order that had effectively barred fresh industrial activity in the Taj Trapezium Zone (TTZ) without its prior approval, allowing the TTZ Authority to process around 410 pending applications, most of them filed by micro, small and medium enterprises (MSMEs) seeking permission to set up, expand or relocate industries, with a Bench comprising Chief Justice of India Surya Kant and Justices Joymalya Bagchi and V Mohan modifying its October 14, 2024 order in the suo motu case, In Re Regulation of Industries in Taj Trapezium Zone. The Bench modified paragraph 27 of the Court's October 14, 2024 order to the extent of the revised approval mechanism.

While the Court retained strict environmental safeguards, it held that delays in completing key studies and policy documents should not indefinitely stall industrial applications, noting broad agreement that only non-polluting industries should be permitted in the TTZ.

Why the case came back to court

The modification came on an application filed by the TTZ Authority, which informed the Court that around 410 applications relating to MSMEs had remained pending because of the blanket prohibition imposed by the Court's earlier order, and the Authority submitted that the embargo had completely halted the processing of applications for small-scale enterprises seeking to establish, relocate or expand their operations within the TTZ.

Attorney General R Venkataramani argued that the Court's October 2024 order had brought many small-scale industries to a "grinding halt," saying the pending applications largely involved small businesses such as atta chakki units and paper product manufacturers. Additional Solicitor General Aishwarya Bhati submitted that the complete moratorium had severely affected local livelihoods and brought small-scale operations, such as flour mills, footwear units, and paper manufacturing, to a standstill across six districts.

Senior Advocate Aparna Bhat opposed the plea, contending that the TTZ Authority had previously granted arbitrary approvals to metal, chemical and glass industries in the Firozabad region despite environmental objections, and cautioned the Court against permitting a mechanism that could dilute environmental safeguards.

Operative mechanism and safeguards

A Bench comprising Chief Justice of India Surya Kant and Justices Joymalya Bagchi and V Mohan directed that the applications may be considered subject to a scrutiny mechanism involving experts from NEERI and the CEC, ordering: "We, therefore, direct that the TTZ Authority may process the pending applications," and clarifying that applications may be approved without seeking the Court's permission where the TTZ Authority, NEERI and the CEC experts are unanimous that the proposed unit is non-polluting.

• In every meeting convened to consider such applications, one expert nominated by the Central Empowered Committee (CEC) and one expert representative of NEERI must participate, and no meeting can be held unless both experts are present.
• Where the experts disagree on whether an industry qualifies as non-polluting, the proposal must be placed before the Supreme Court itself.
• Every approval granted by the TTZ Authority must be uploaded on the CEC's website, allowing the public to submit objections before it is finalised.

Referring to an interim report submitted by NEERI on April 21, 2025, the Court noted the institute had advised against a rigid definition of non-polluting industries, instead recommending that factors such as Agra's heritage, legacy and Geographical Indication status also be considered.

Effect on the Agra Integrated Manufacturing Cluster (IMC)

The Agra IMC sits inside the Taj Trapezium Zone, so any new industrial unit proposed for the cluster fell under the same October 2024 moratorium that this order modifies. The Integrated Manufacturing Cluster (IMC) in Agra is strategically located across 1,058 acres along the city's Inner Ring Road, with connectivity to Delhi NCR and the Agra-Lucknow Expressway. The project is anticipated to bring in over INR 3,400 crore in investments, boosting the region's industrial growth and economic development.

UPSIDA is anchoring the Agra IMC, which will be focused on promoting non-polluting industries — the leather and footwear segments traditionally associated with the city will also be promoted but with the condition that green technologies are adopted, with agro-based products as another focus area. The cluster was formalised through a State Support Agreement (SSA) and Shareholder Agreement (SHA) signed between NICDC, the Government of Uttar Pradesh, and UPSIDA under the Amritsar-Kolkata Industrial Corridor (AKIC) initiative.

By allowing the TTZ Authority to process pending non-polluting industrial applications instead of every case requiring separate Supreme Court clearance, the 23 July 2026 order removes the main procedural bottleneck that had stalled fresh unit approvals inside the TTZ, including at IMC Agra, since the October 2024 moratorium took effect.

Background: the wider TTZ legal history

The bench's order referred to its December 30, 1996 order by which it had prohibited the use of coal and coke in the TTZ and directed 293 industries around Agra to switch to natural gas to reduce pollution while allowing industrial development. The original MC Mehta case was closed earlier this year, following which separate suo motu proceedings were registered to deal with issues concerning industries in the protected zone.

By an earlier order dated 22 April 2025, the Court had already clarified its 14 October 2024 order and permitted the relocation of 16 existing industries within the TTZ, subject to compliance with applicable conditions. The TTZ itself is a 10,400 sq km area spread across the districts of Agra, Firozabad, Mathura, Hathras and Etah in Uttar Pradesh and Bharatpur district of Rajasthan.