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8) In the meantime, the 1991 CRZ Notification was superseded by CRZ Notification issued on 6 January 2011 (2011 CRZ Notification), under which the distance from HTL for applicability of CRZ restrictions was changed in respect of tidal influenced water bodies such as bays and creeks. The 2011 CRZ Notification provided for CRZ area in resepct of land alongside bays and creeks upto the distance of 100 meters from HTL. In the year 2014, the water body at Mahim was classified as 'Bay' and applicability of CRZ restrictions became applicable only in resepct of lands situated upto the distance of 100 mtrs from HTL. The 2011 CRZ Notification was superseded by another Notification issued by MoEF on 18 January 2019 (2019 CRZ Notification), which envisaged preparation of Coastal Zone Management Plan (CZMP). Accordingly, CZMP for Mumbai City was prepared and the same was approved by MoEF on 29 September 2021. 

D.1.2            2011 CRZ NOTIFICATION



37)              In supersession of 1991 CRZ Notification, MoEF issued

2011 CRZ Notification. While various other changes were bought into effect by 2011 CRZ Notification, the major change included the declaration of areas as CRZs. While land area from HTL of 500 meters on landward side along sea front continued to be declared as CRZ, major change was bought about in respect of land area alongside tidal influenced water bodies. The land area between HTL upto distance of 100 meters on landward side along tidal influenced water bodies was declared as CRZ by 2011 CRZ Notification. The relevant part of 2011 CRZ Notification reads thus :- 


                                     26 August 2025


 Neeta Sawant                                     PILs-22-2024 and 8224-2024-FC

67)              As observed above, 2011 CRZ Notification was issued in

supersession of 1991 CRZ Notification, on account of which, it became necessary to protect the things done in pursuance of 1991 CRZ Notification which was being superseded. Thus, what is protected and not superseded are i) things done and ii) things omitted to be done. This essentially means that if any activity is performed as a permissible activity under 1991 CRZ Notification, such activity would remain protected under 2011 CRZ Notification, notwithstanding the fact that the said activity may be prohibited under 2011 Notification. This also means that a clearance already secured for an activity under 1991 CRZ Notification need not be again secured under 2011 Notification. To illustrate, if a port was constructed after securing permission under 1991 CRZ Notification, construction of such port would not be rendered illegal after coming into effect of 2011 CRZ Notification nor fresh permission is necessary under the 2011 CRZ Notification. This is the true purport of the words 'things done' used in 2011 CRZ Notification.

68) Similarly, the words "things omitted to be done" used in 2011 CRZ notification means that if any act was not required to be performed under 1991 CRZ Notification, non-performance of such act does not per se become illegal after coming into effect of 2011 CRZ Notification.

69) This is all that the saving clause "except as respects things done or omitted to be done before such supersession" used in 2011 CRZ Notification would mean.

70) The 2019 CRZ Notification, issued in supersession of 2011 CRZ Notification uses the similar expression and protects 'things done or omitted to be done before such supersession' .