Public Interest Prevails Over Status Quo Injunctions in Infrastructure Projects

The Hon’ble High Court of Madras, in the case of State of Tamil Nadu v. Madras Race Club & Ors., (2025 MHC 2729), decided on November 25, 2025, reiterated that interim judicial orders cannot be allowed to impede infrastructure and environmental projects conceived in the overriding public interest.

The dispute arose out of the termination of a long-standing lease granted in 1946 to the Madras Race Club (MRC). Through a Government Order, the State of Tamil Nadu terminated the lease, citing violations of lease conditions and resumed the land for public purposes, including the development and strengthening of water bodies and the creation of an Eco Park as part of flood-mitigation and climate-resilience measures. Challenging the termination, the MRC instituted a civil suit seeking a declaration that the Government Order and consequential notices were null and void and obtained an interim order of ‘status quo’ restraining dispossession.

Aggrieved by the continuance of the status quo order, the State appealed, contending that the interim restraint/status quo order was impeding the implementation of urgent public works, including the strengthening of four ponds already excavated on the land and preparatory works for an Eco Park intended to function as a water-storage and ecological buffer. The State submitted that these projects were conceived to mitigate the adverse effects of extreme rainfall, flooding, climate change, and rapid urbanization affecting the inhabitants of the city of Chennai.

In the light of the submission of the State, the Division Bench observed that the continuation of the status quo order directly hindered projects rooted in larger public interest. Relying on Section 41(ha) of the Specific Relief Act, 1963, the Court held that injunctions ought not to be granted where they impede or delay infrastructure projects. The Bench underscored that flood-mitigation infrastructure, including ponds and ecological parks, squarely falls within the ambit of public infrastructure, particularly in a city repeatedly ravaged by floods.

The Court placed reliance on constitutional principles, noting that under Article 21 of the Constitution of India, 1950, the State bears a positive and non-delegable duty to safeguard the right to a clean, healthy and pollution-free environment. The Bench held that preventive and adaptive measures against foreseeable climate-related harms are an integral part of the State’s constitutional responsibilities. The proposed ponds and Eco Park were found to further improve the ecological balance, groundwater recharge, air-quality improvement and flood resilience, thereby advancing both fundamental rights and Directive Principles of State Policy.

The Court also invoked Article 39(b) of the Constitution, observing that Government land constitutes a material resource of the community and must be utilised to best subserve the common good. While refraining from conclusively ruling on the legality of the lease termination at the interim stage, the Bench noted that continued private control over scarce urban land, particularly where public interest projects are envisaged, raises concerns under the doctrine of public trust. Accordingly, the Madras High Court allowed the Original Side Appeal, modified the interim status quo order, and permitted the State to proceed with all works relating to the strengthening and development of ponds and the Eco Park, subject to the final outcome of the case.

The judgment reinforces the key issue that interim judicial protection cannot impede the implementation of public infrastructure and environmental projects, particularly in the context of climate resilience and flood mitigation.