WEEK 1 | 1–7 June 2026
CONSTITUTIONAL LAW • HUMAN RIGHTS • TRAFFICKING
Prajwala v. Union of India — Supreme Court Frames Victim Protection Plan for Trafficking Survivors
Citation: 2026 SCC OnLine SC 1053 Court: Supreme Court of India Bench: JJ. J.B. Pardiwala & R. Mahadevan Decided: 29 May 2026
In a landmark judgment arising from a 2004 PIL filed by the Hyderabad-based anti-trafficking NGO Prajwala, the Supreme Court moved decisively from a rescue-centric to a rights-centric approach to human trafficking. The Division Bench held that rehabilitation of victims of commercial sexual exploitation (CSE) is not a matter of executive policy or administrative discretion; it is a constitutionally enforceable fundamental right, flowing directly from Articles 21 (right to life and dignity) and 23 (prohibition on trafficking and forced labour). The Court designed, in granular detail, a binding “Victim Protection Plan” spanning six operational stages: pre-rescue intelligence, rescue protocols, immediate post-rescue care, rehabilitation, prosecution with witness protection, and prevention with mandatory official training. Invoking powers under Articles 32 and 142 and drawing on the Palermo Protocol, the bench held that victim consent is legally irrelevant where force, deception, or coercion is proved. Critically, the Court directed that no law shall treat a victim as a criminal. Compliance is to be reported to the Court in September 2026.
Key Points:
- Rehabilitation = a fundamental right under Articles 21 and 23.
- Articles 32 and 142 are invoked together to create binding nationwide obligations.
- The Palermo Protocol is applied as an interpretive tool.
- The victim cannot be treated as a criminal at any stage.
ENVIRONMENTAL LAW • WILDLIFE PROTECTION • ARTICLE 142
In re: Illegal Sand Mining in the National Chambal Sanctuary — SC Issues Sweeping Directions to Three States
Citation: 2026 SCC OnLine SC 947 Court: Supreme Court of India (Suo Motu) Bench: JJ. Vikram Nath & Sandeep Mehta Decided: June 2026
Hearing a suo motu writ petition regarding the ongoing ecological destruction of the National Chambal Gharial Sanctuary – a critical habitat for the endangered gharial and the Gangetic river dolphin – the Supreme Court invoked Article 142 to issue binding directions to Rajasthan, Madhya Pradesh, and Uttar Pradesh. The Court held that protection of ecologically sensitive regions is a continuing constitutional obligation of the State under Articles 21, 48-A, and 51-A(g), and that compliance affidavits cannot substitute for on-ground enforcement. The bench directed: immediate installation of CCTV surveillance and night-vision cameras on the NH-44 Morena–Dholpur bridge; strict seizure of unregistered and false-plated vehicles; expedited recruitment of frontline forest guards; prosecution of cross-state organised mining networks; and active participation of NHAI in preventing excavation near bridge foundations. The Court also impleaded the Union Ministry of Jal Shakti and the Central Water Commission to file affidavits on ecological flows. Significantly, the bench linked enforcement with livelihood creation, directing the three States to prioritise employment for local communities in conservation, eco-tourism, and surveillance activities.
Key Points:
- Articles 21, 48-A and 51-A(g) read together: continuing State obligation to protect wildlife.
- Article 142 is invoked to ensure complete justice in environmental superintendence.
- De-notification of any wildlife sanctuary requires prior approval from the Supreme Court.
- Community-based livelihood generation is directed alongside punitive enforcement.
DIGITAL RIGHTS • PRIVACY • CONSTITUTIONAL LAW
Laksh Vir Singh Yadav v. Union of India – Delhi HC Recognises Right to Be Forgotten under Article 21
Citation: 2026:DHC:4891 Court: Delhi High Court Bench: Justice Sachin Datta Decided: 1 June 2026
In a 144-page judgment consolidating more than 30 petitions filed from 2016 onwards, Justice Sachin Datta held that the right to be forgotten, understood as the right to seek removal or de-indexing of personal information from digital judicial records, is an integral facet of the fundamental right to privacy under Article 21. Drawing on Justice K.S. Puttaswamy v. Union of India (2017) and the European Court of Human Rights’ Grand Chamber decision in Hurbain v. Belgium, the Court held that perpetual online searchability of personal identifiers in judicial records constitutes ongoing harm to dignity and informational self-determination. Two remedies were distinguished: de-indexing (removing a name from search engine results while the judgment remains accessible by case number or citation) and masking (replacing personal identifiers in publicly accessible digital versions while preserving the unredacted record in official court archives). De-indexing directions were ordered to operate globally across all domains and versions of the relevant search engine. MEITY was directed to ensure compliance by intermediary platforms and file a compliance affidavit.
Key Points:
- Right to be forgotten = facet of right to privacy under Article 21.
- De-indexing ≠ erasure: judgment remains accessible by citation or case number.
- Masking: names/identifiers removed; legal reasoning and conclusions remain public.
Global de-indexing directions issued; not limited to national domains.
Disclaimer: This roundup is for educational purposes only and does not constitute legal advice. All judgments cited are sourced from authoritative Indian legal databases.