Daily Prelims Notes 14 April 2024

Daily Prelims Notes

14 April 2024

1. How did the law on disclosure of assets evolve?

Subject: Polity

Section: Elections

Context:

• Two recent events have highlighted issues related to the disclosure requirements for election candidates.
  • Firstly, Rajeev Chandrasekhar, a BJP candidate in Thiruvananthapuram, reportedly did not declare all his assets in the required affidavit with his nomination papers.
  • Secondly, the Supreme Court has indicated that candidates do not need to disclose every minor detail, acknowledging their right to privacy.
• These developments raise questions about balancing transparency and privacy in election laws.

What is the law related to disclosure?

• The law related to disclosure for election candidates in India stems from a landmark Supreme Court judgment on May 2, 2002, which established that voters have the right to know about a candidate’s criminal history, educational qualifications, and financial information, including that of their spouses and dependents.
• This was based on the principle that the right to information is essential for voters to make informed decisions, thus forming a part of their right to express their opinions through voting.
• Following the Supreme Court’s decision, the Election Commission of India (ECI) issued rules in June 2002 to enforce this judgment.
• However, the Central government attempted to limit these disclosure requirements through an ordinance in August 2002 that amended the Representation of the People Act, 1951.
  • This ordinance introduced sections that restricted disclosures to only those specified in the Act and set penalties for nondisclosure or false disclosure.
• These amendments were challenged in court, and on March 13, 2003, the Supreme Court invalidated Section 33B of the ordinance, thus upholding the original disclosure norms.
• Consequently, the ECI reissued revised guidelines and formats for candidates’ disclosures in line with the Supreme Court’s ruling.

What are the consequences of any omission?

• Under Section 125A of the Representation of the People Act, 1951, any candidate who fails to disclose required information, or provides false information, or conceals information, may face up to six months in prison, a fine, or both.
• Additionally, such omissions or misinformation can serve as grounds for challenging the validity of a candidate’s election in the High Court.
• Specifically, an election can be declared void if there is improper acceptance of a nomination or non-compliance with the legal provisions, rules, or orders under the act.
• This allows an unsuccessful candidate to contest the legitimacy of a winning candidate’s nomination based on allegations of concealed or false information, as well as any breaches of mandatory disclosure requirements.

What is the latest court ruling?

• The latest court ruling involved the election of Karikho Kri, an independent candidate who won a seat in the Arunachal Pradesh Assembly in 2019. His election was challenged by a Congress candidate on the basis that Kri had failed to disclose certain movable assets and issues related to government accommodation.
• The Itanagar Bench of the High Court declared his election void, finding faults in his nomination over non-disclosure of three vehicles and a missing ‘No Dues’ certificate from his previous term as MLA.
• However, the Supreme Court overturned this decision, ruling that the non-disclosures by Kri were not substantial enough to affect the election outcome.
  • It found that the vehicles had been disposed of well before the election, and although the ‘No Dues’ certificate was from 2014, it was still valid as there were no new dues and Kri had not held any government accommodation since.
• Thus, the non-compliance did not materially affect the integrity of the electoral process, leading to the reinstatement of Kri’s election.

What is the takeaway from the verdict?

• The Supreme Court’s verdict emphasizes that while the voter’s right to know is important, it is not absolute.
• Candidates are not required to disclose every detail of their lives or every minor possession.
• Disclosure is necessary only for items of significant value or those that could influence a voter’s perception of the candidate’s lifestyle.
• However, the court also highlighted that there is no uniform rule for determining the significance of an omission; the impact of each nondisclosure must be assessed based on the specific circumstances of each case.
• This implies a need for balance in disclosure requirements, ensuring transparency while respecting a candidate’s privacy.

Source: TH

2. Reservoirs in Andhra Pradesh and Telangana face major shortage

Subject: Geography

Section: Indian physical

Context: The water levels in the reservoirs in the southern states of Andhra Pradesh and Telangana have witnessed a significant drop over the past few months

Reservoirs in Andhra Pradesh and Telangana

Srisailam Reservoir (Andhra Pradesh and Telangana)

The total percentage of water storage, as of January 4, in Srisailam Reservoir, is 21%. The percentage of the water level in the corresponding period last year was 43%

Nagarjuna Sagar Reservoir (Andhra Pradesh and Telangana)

It is one of the most impacted water reservoirs. The current year’s water storage percentage stands at 13% which is way low in comparison to last year’s 82%.

Somasila Reservoir (Andhra Pradesh)

This year’s total water storage in Somasila Reservoir has shown a significant drop. As per the CWC data, the reservoir has recorded at 36%. Last year, the storage percentage was 91%.

Yeleru Reservoir (Andhra Pradesh)

The Yeleru Reservoir has seen a significant drop in water level. The percentage for the current year is 34%. Whereas, the authorities recorded 74% water during this time in 2023.

Kandaleru Reservoir (Andhra Pradesh)

The water storage level stands at 13% in comparison to last year’s 78% in 2023.

3. Germany to send additional Patriot system to Ukraine

Subject: Science and tech

Section: Defence

Context:

• Germany will provide Ukraine with an additional Patriot air defense system to bolster its defences against increasing Russian airstrikes.

Details:

• This decision reflects ongoing efforts to strengthen Ukrainian air defence capabilities, which have previously included deliveries of the US-made Patriot systems designed to counteract Russian drone and cruise missile attacks.
• The US has committed to selling Ukraine equipment worth up to $138 million to maintain and upgrade its HAWK air defence systems, following the previous deployment of HAWK interceptor missiles as an enhancement over the smaller, shorter-range Stinger systems.

Patriot Air Defence System:

• The Patriot (MIM-104), which stands for Phased Array Tracking Radar for Intercept on Target, is the U.S. Army’s most advanced air defense system.
• It is an all-weather surface-to-air missile defence system to counter tactical ballistic missiles, cruise missiles, and advanced aircraft.
• It was developed by Raytheon, an American multinational aerospace and defense conglomerate.
• The system was first used in combat during the 1991 Gulf War, with batteries protecting Saudi Arabia, Kuwait, and Israel, and was later used during the U.S. invasion of Iraq in 2003.
• It is in service with the US and allied countries, including Germany, Greece, Israel, Japan, Kuwait, the Netherlands, Saudi Arabia, South Korea, Poland, Sweden, Qatar, the United Arab Emirates, Romania, Spain, and Taiwan.
• Features:
  • It is a mobile system that usually includes powerful radar, a control station, a power generator, launch stations, and other support vehicles.
  • Depending on the version in use, the interceptor missiles can reach an altitude of more than 24 kilometres and hit targets up to 160 kilometres away.
  • Its radar can track up to 50 targets and engage five of them at once.
  • It is equipped with a track-via-missile (TVM) guidance system. Midcourse correction commands are transmitted to the guidance system from the mobile engagement control centre.
  • A Patriot battery can need as many as 90 troops to operate and maintain it.

Other Air Defence Systems in the news:

4. Geroscience: the science related to ageing

Subject: Science and tech

Section: Health

• ‘Geroscience’ describes a field focused on aging-related studies. He has developed a blood test that can measure the rate of ageing by analyzing DNA methylation through an enzyme called ‘gerozyme.’
• Research groups are exploring medications and techniques to manipulate this enzyme to potentially slow ageing.
• Notably, studies suggest drugs like metformin and inhibitors of the enzyme TORC1 may enhance immunity and reduce infections in the elderly, with ongoing research into rapamycin’s potential benefits for longevity and disease management.
• Additionally, Dr. Belsky’s research indicates that socioeconomic factors can influence DNA methylation rates, affecting ageing.
• Complementary to these findings, the Columbia Aging Centre highlights the importance of a balanced diet in supporting brain health and reducing age-related decline, emphasizing proteins, healthy fats, and antioxidants.
• This is particularly relevant in India, where a significant portion of the population is elderly, and such dietary components are readily available for diverse dietary preferences.

Inhibited by exercise:

• Researchers at Stanford University have discovered a drug that enhances muscle strength in ageing or injured mice by blocking the action of an age-related enzyme, 15-PGDH, which increases in muscles with age and in neuromuscular diseases. This inhibition rejuvenates physical activity in aging mice.
• Additionally, the Mayo Clinic enumerates seven benefits of regular physical activity, particularly for seniors, such as weight control, disease prevention, mood improvement, increased energy, better sleep, improved sexual health, and social interaction benefits.
• Furthermore, research from Spain suggests that music may influence the same ageing-associated enzyme, offering potential as a treatment for dementia.
• A 2020 study found that music could be a significant therapeutic strategy for dementia, and more recent research proposes that music can modulate gene expression related to age-related cognitive disorders.
• This indicates a promising intersection of music therapy and neurology in managing ageing processes and related diseases.

Source: TH

5. Why is there a WHO alert on viral hepatitis?

Subject: Science and tech

Section: Health

Context:

• India accounted for 11.6% of the total viral hepatitis disease burden globally in 2022, making it the country with the second highest disease load after China, according to the World Health Organization’s (WHO) Global Hepatitis Report 2024 released recently.
• Bangladesh, China, Ethiopia, India, Indonesia, Nigeria, Pakistan, the Philippines, the Russian Federation and Vietnam, collectively shoulder nearly two-thirds of the global burden of hepatitis B and C.

What does the report highlight?

• The disease is the second leading infectious cause of death globally — with 1.3 million deaths per year, the same as tuberculosis, a top infectious killer.
• New data from 187 countries show that the estimated number of deaths from viral hepatitis increased from 1.1 million in 2019 to 1.3 million in 2022. Of these, 83% were caused by hepatitis B, and 17% by hepatitis C.
• Every day, there are 3,500 people dying globally due to hepatitis B and C infections. 
• Half the burden of chronic hepatitis B and C infections is among people aged 30-54 years old, with 12% among children under 18 years of age. Men account for 58% of all cases.

Why is the report significant?

• The report is significant as it is the first comprehensive WHO document consolidating global data on viral hepatitis, covering epidemiology, service coverage, and product access.
• It provides the most recent estimates of disease burden and examines the coverage of essential services for viral hepatitis across 187 countries.
• Key findings reveal low diagnosis and treatment rates: only 13% of those with chronic hepatitis B are diagnosed, with about 3% receiving antiviral therapy; for hepatitis C, 36% are diagnosed and 20% have received curative treatment.
• These figures are substantially below the global targets of treating 80% of those with chronic hepatitis B and C by 2030.
• Nonetheless, the report notes a modest but steady improvement in both diagnosis and treatment rates since the last estimation in 2019, marking some progress toward global hepatitis eradication goals.

What is Hepatitis?

• Hepatitis is an inflammation of the liver that can be caused by various infectious viruses and non-infectious agents, leading to potentially fatal health issues.
• There are five main types of the hepatitis virus—A, B, C, D, and E.
• Each type causes liver disease but varies in transmission modes, illness severity, and geographic prevalence.
• Types B and C are particularly significant as they often lead to chronic conditions and are the major causes of liver cirrhosis, liver cancer, and deaths related to viral hepatitis.

Why is India vulnerable?

• India is particularly vulnerable to hepatitis due to multiple factors, including high population density, lack of awareness about the disease, insufficient screening and treatment options, and poor hygiene practices.
• Mother to child transmission is responsible for most new infections.
• The rise in non-viral hepatitis cases, such as alcoholic liver disease (ALD) and non-alcoholic fatty liver disease (NAFLD), exacerbates the situation.
• Urban lifestyles with higher alcohol consumption have increased ALD cases, while obesity, metabolic disorders, and sedentary habits have led to a surge in NAFLD cases across both urban and rural India.
• These conditions can progress to severe liver diseases, adding to the hepatitis challenge. 
• Other risks include: infections from intravenous drug use, sharing injections, and risky sexual practices, contributing to higher transmission rates of hepatitis B and C among this group.

How can it be prevented?

• Hepatitis B prevention is achievable through vaccination, which is emphasized for coverage enhancement.
• Unlike Hepatitis B, Hepatitis C can be cured using specific medications.
• Despite the severity of viral hepatitis, the mortality rates in India are not as high as those from tuberculosis, partly because the cost of hepatitis treatment is relatively low due to the availability of generic drugs in India.
• The government’s viral hepatitis control program provides vaccines to high-risk adults, including healthcare workers, and offers treatment options for both hepatitis B and C.
• Initially, the hepatitis B vaccine was rolled out in select cities and districts in 2002-2003, and by 2011-2012, the vaccine for Chronic Hepatitis B infection (HBV) was integrated into the childhood immunization program, expanding its reach and effectiveness in preventing the disease.

Source: TH

6. Kodaikanal | The hills are (barely) alive

Subject: Geography

Section: Mapping

Context:

• Kodaikanal, a hill station, is facing severe tourist footfall, leading to the problem of waste management, overcrowding, illegal construction and pollution of all forms.

Kodaikanal- Dindigul district in the state of Tamil Nadu.

• Situated in the Palani hills  of Western Ghats.
• Also known as “Princess of Hill stations”
• The earliest references to Kodaikanal and the Palani hills are found in Tamil Sangam literature.
• It has an irregular basin as its heartland, the center of which is now Kodaikanal Lake. The lake is a man-made lake of circumference 5 kilometres (3.1 mi), formed by blocking three water streams in 1863.
• Guna caves- A tourism spot in Kodaikanal hills.

Carrying Capacity:

• Excessive tourism is a pan-India problem.
• ‘Carrying capacity’ is a broad term that covers many aspects and features of a region, indicating the maximum number of visitors to a destination at a given time, with least damage to the environment and cultural landscape.
• The Madras High Court has now recommended similar carrying capacity studies for the hill stations of Udhagamandalam and Kodaikanal in South India, with the aim of regulating tourist entries.
• In 2023, the Ministry of Environment, Forest and Climate Change asked the Supreme Court to direct 13 Himalayan States to conduct surveys to assess the ‘carrying capacities’ of towns in these fragile ecosystems.
  • It recommended a detailed study by a panel of experts in the fields of hydrology, environment and climate studies, as per the guidelines of the GB Pant National Institute of Himalayan Environment.
• Earlier, in 2018, the National Green Tribunal had directed the Union Ministry of Urban Development and Union Environment Ministry to undertake similar studies in all States and Union Territories.

Too many homestays:

• The 2022 guidelines introduced by Tamil Nadu Tourism for homestays and B&Bs have led to a significant increase in such establishments in the Nilgiris. While some view this trend as sustainable- leveraging existing properties to avoid building new hotels which could strain local resources– environmental concerns have also been raised.
• Many homestays are operating illegally in ecologically sensitive areas, potentially with official complicity. This has prompted legal action and a halt in issuing new homestay licenses, with significant involvement from local tourism associations recognizing the environmental and regulatory challenges.

Sky Island under threat:

• The shola forests in the Western Ghats, recognized as part of a “sky-island” system due to their unique highland isolation, are facing severe threats.
• Over the past four decades, the Palani Hills region, spanning Tamil Nadu and Kerala, has seen a drastic reduction in its grasslands and shola forests, with about 80% loss attributed initially to invasive species and more recently to agriculture and tourism pressures.
• While the forest lands are relatively protected, the buffer zones where forest meets agricultural and commercial land are poorly defined, leading to widespread encroachments.
• Efforts to restore the ecosystem have been primarily led by forest guards in the Kodaikanal Wildlife Sanctuary.

Source: TH

7. Caught in Maharashtra, Telangana border row, 14 villages grapple with ‘privilege’ of voting twice

Subject: Geography

Section: Mapping

Context:

• About 4,000 voters from 14 villages along the border between Maharashtra and Telangana could be the only ones in India to have the “privilege” to vote twice in the 2024 Lok Sabha elections — in Maharashtra for the Chandrapur constituency in the first phase on April 19, and then in Telangana for the Adilabad constituency in the fourth phase on May 13.

More on news:

• With their villages under two panchayats in both Maharashtra’s Chandrapur and Telangana’s Adilabad, each resident has two voter IDs, Aadhaar cards etc.

Boundary Dispute:

• The territorial dispute over the 14 villages (called Sade Bara Gaon in Maharashtra) that fall in the Kerameri tehsil of Adilabad in Telangana and Jivati tehsil of Chandrapur in Maharashtra, dates back to 1956, when the state of Andhra Pradesh was formed.
• The 14 villages come under two gram panchayats — Parandoli and Antapur — which are over 30 km apart.
• The villagers have two voter ID cards each with their names listed in the constituencies of both the states.
• Each of the villagers also have two ration cards, Aadhaar cards, MNREGA cards, caste certificates and other documents — one each from Maharashtra and Telangana, based on their respective classifications — which enable them to avail benefits of social welfare schemes from both states.
• As the villagers, who mostly belong to the Scheduled Castes (SCs) and Scheduled Tribes (STs) communities, have ration cards from both states, they can also avail ration benefits as well as other schemes being implemented by both states.

8. Why text of amended tax treaty with Mauritius triggered stock sell-offs

Subject: Economy

Section: External Sector

Context:

• The text of the amended tax treaty with Mauritius has raised concerns of greater scrutiny on investments, and led to a sell-off in stock markets by Foreign Portfolio Investors (FPIs) on Friday.

More on news:

• India has signed a protocol amending its tax treaty with Mauritius with an aim to plug treaty abuse for tax evasion and avoidance.
• India and Mauritius,signed a protocol at Port Louis, amending the Double Taxation Avoidance Agreement (DTAA) between the two nations.
• The amended treaty introduces the Principal Purpose Test , essentially implying that the tax benefits under the treaty will not be applicable if it is established that obtaining that duty benefit was the principal purpose of any transaction or arrangement.

Introduction of the Principal Purpose Test

• The amended pact includes the Principal Purpose Test (PPT), which is in line with the global efforts against treaty abuse, particularly under the BEPS (Base Erosion and Profit Shifting) framework. 
• The PPT essentially implies that the tax benefits under the treaty will not be applicable if it is established that obtaining that duty benefit was the principal purpose of any transaction or arrangement.
• The two nations have also amended the preamble of the treaty to incorporate the thrust on tax avoidance and evasion.
• The earlier objective of “mutual trade and investment” has now been replaced with an intent to “eliminate double taxation” without creating opportunities for non-taxation or reduced taxation through tax evasion or avoidance including through “treaty shopping arrangements” aimed at obtaining relief provided under this treaty for the indirect benefit of residents of third jurisdictions.
• The recent amendment reflects India’s intent to align with global efforts against treaty abuse, under the BEPS framework.

Impact of the amended treaty

• The text of the protocol amending the treaty states that the provisions of the protocol shall have effect from the date of entry into force of the protocol, without regard to the date on which the taxes are levied or the taxable years to which the taxes relate.
• This suggests that the PPT will apply to all transactions after the treaty gets notified, irrespective of the date of the investment itself.
• Investors are apprehensive that this will result in greater scrutiny of the capital gains tax levy and exemption, as the PPT will be applicable to past investments where investors have not made an exit yet.
• The DTAA was a major reason for a large number of FPIs and foreign entities to route their investments in India through Mauritius, as there was no capital gains tax on sale/transfer of shares.

India and Mauritius:

• Mauritius remains India’s fourth largest source of FPI investments, after the US, Singapore, and Luxembourg.
• FPI investment from Mauritius stood at Rs 4.19 lakh crore at the end of March 2024, which is 6 per cent of the total FPI investment of Rs 69.54 lakh crore in India.
• FPI investment from Mauritius had stood at Rs 3.25 lakh crore, out of total FPI investment of Rs 48.71 lakh crore at the end of March 2023.

9. Islamic Revolutionary Guard Corps: Role, organisation

Subject: IR

Section: Places in news

Context:

Iran launched hundreds of aerial drones and missiles at Israel, on Saturday night, in what is being called first direct clash between the two enemy nations engaged in a shadow war for years. Until now, Iran had been involved in the war through its proxies.

Iran’s Islamic Revolution Guard Corps (IRGC) said the attack was aimed at specific targets.’ Earlier, country’s supreme leader Ayatollah Ali Khamenei had vowed to ‘retaliate’ after an alleged Israeli strike on April 1 on its consulate in Damascus, Syria killed seven IRGC officers, including a top commander Mohammad Reza Zahedi.

What is IRGC?

IRGC is a multi-service primary branch of the Iranian Armed Forces different from country’s traditional Army. While the Iranian Army protects the country’s sovereignty, IRGC is largely aimed at defending the Islamic Republic of Iran against internal and external threats.

Over the years, the corps has gained an outsize role in executing Iran’s foreign policy and it wields control over vast segments of the country’s economy, according to US think tank, Council on Foreign Relations (CFR). 

Over the years, the corps has gained an outsize role in executing Iran’s foreign policy and it wields control over vast segments of the country’s economy, according to US think tank, Council on Foreign Relations (CFR). 

In 2019, the then US President Donald Trump designated the IRGC a terrorist organization. This was for the first time that the US had ever designated another government’s department as a Foreign Terrorist Organization.

When was IRGC formed?

The IRGC, or the Sepah-e-Pasdaran, was set up by by Ruhollah Khomeini soon after the 1979 Islamic Revolution of Iran largely to protect the the Shia Muslim clerical ruling system of Iran and provide a counterweight to the regular armed forces, according to a report in Reuters.

IRGC reports directly to the country’s supreme leader.

How big is IRGC?

The IRGC is today considered one of the most powerful paramilitary organisations in the Middle East. In the past, the force is known to have aided Afghanistan, Iraq, Lebanon, the Palestinian territories, Syria, and Yemen.

Today, IRGC has an estimated strength between 125,000- 190,000 personnel with army, navy and air units, according to the many reports.

To explain how big the numbers are, for an area of 3.287 million sq km, India has 1,237,117 active army personnel. But for 1.648 million sq km area, Iran has 125,000 strong IRGC personnel. And remember, this is apart from the traditional Iranian army.

The Israeli military has about 170,000 active personnel and 465,000 reservists.

IRGC also comprises of Basij militia, a volunteer paramilitary force loyal to the clerical establishment of the country. This militia is often used to crack down on anti-government protests.

What is Quds Force?

IRGC’s ties with region’s armed groups such as the Hezbollah in Lebanon and the Hamas in the Palestinian territories, has helped Iran project influence and power.

Quds Force, the secret wing of IRGC, is responsible for its international operations.  Mohammad Reza Zahedi, killed in Damascus on April was a senior commander in the Quds Force.

All eight units of IRGC operate under the leadership of the IRGC commander-in-chief Major General Hossein Salami and his deputy, Ali Fadavi. But the Quds Force’s commander effectively operates within a parallel structure and reports directly to the Supreme Leader of Iran, Ayatollah Khamenei

10. Environmental Jurisprudence in India

Subject: Polity

Section: Constitution

Polluter Pays Principle

• The Polluter Pays Principle was first adopted at international level in the 1972 OECD Council Recommendation on Guiding Principles concerning the International Aspects of Environmental Policies. The 1974 principle experienced revival by OECD Council in 1989 in its Recommendation on the Application of the Polluter Pays Principle to Accidental Pollution, and the principle was not to be restricted to chronic polluter. In 1991, the OECD Council reiterated the Principle in its Recommendations on the Uses of Economic Instruments in Environmental Policy. This principle was first stated in the Brundtland Report in 1987. This principle was also adverted to in Indian Council for Enviro-legal Action vs. Union of India. In this case this was held that once any activity is inherently dangerous or hazardous dangerous, the person carrying on such activity is liable to make good the loss caused to any other person by his activity irrespective of the fact whether he took reasonable care while carrying on his activity.
• In the Oleum Gas Leak case (M.C. Mehta v. Union of India) the Supreme Court laid down that an enterprise which is engaged in a hazardous or inherently dangerous industry which poses a potential threat to the health and safety of persons working in the factory and to those residing in the surrounding areas, owes an absolute and non delegable duty to the community to ensure that no harm results to any one on account of hazardous or inherently dangerous nature of the activity which it has undertaken. The enterprise must be absolutely liable to compensate for such harm and it should be no answer to the enterprise to say that it had taken all reasonable care and that the harm occurred without negligence on its part.

Precautionary Principle and Principle of New Burden of Proof

• The precautionary principle had its origin in the mid-1980s from the German Vorsorgeprinzip. The Supreme Court of India, in the case of Vellore Citizens’ Welfare Forum v. Union of India22 referred to the precautionary principle and declared it to be part of the customary law in our country. In the Vellore Case23, Kuldip Singh J observed as follows: “The ‘onus of proof’ is on the actor or the developer/industrialist to show that his action is environmentally benign”

Sustainable Development

• In the international arena ‘Sustainable Development’ came to be known as a concept for the first time in the Stockholm Declaration of 1972. Justice P.N. Bhagawati once made a insightful observation: ‘We need judges who are alive to the socio-economic realities of Indian life’ This statement explains the gradual shift in the judicial approach while dealing with the issues of sustainable development

Public Trust Doctrine

• The ‘public trust’ doctrine was referred to by the Supreme Court in M.C. Mehta v. Kamal Nath27. The doctrine extends to natural resources such as rivers, forests, sea shores, air etc., for the purpose of protecting the eco-system. The State is holding the natural resources as a trustee and cannot commit breach of trust.

Inter-Generational Equity

Principles 1 and 2 of the 1972 Stockholm Declaration refer to this concept. Principle 1 states that Man bears solemn responsibility to protect and improve the environment for the present and future generations. Principle 2 states that the national resources of the Earth must be safeguarded for the ‘benefit of the present and future generations through careful planning or management, as appropriate’. Principle 3 of the Rio Declaration, 1992 also states that the right to development must be fulfilled so as to equitably meet developmental and environmental needs of present and future generations.