As per case facts the Ministry of Environment Forest and Climate Change issued a new notification that was challenged for allegedly diluting environmental clearance requirements for certain projects The petitioner ... argued that this notification effectively nullified adverse judgments against previous dilution attempts and improperly exempted large building projects like industrial sheds and educational institutions from rigorous environmental scrutiny by the State Environment Impact Assessment Authority SEIAA The new notification was defended as an effort to bring clarity and ensure development projects proceed through the competent SEIAA which is an expert body The question arose whether the notification dated January is valid and specifically whether the exemption granted to certain construction projects like industrial sheds and educational institutions from the general environmental management guidelines under Note of Entry a is legally sound Finally the Supreme Court upheld the main notification agreeing that the literal interpretation of the notification did not subject Entry projects to General Conditions and that the expert SEIAA is the appropriate body for project appraisal However the Court struck down Note to Entry a which exempted industrial sheds schools colleges and hostels from the notification's applicability holding this exemption was arbitrary because large construction activities in these categories would still significantly affect the environment and ecology