To,
The Member Secretary
State Environment Impact Assessment Authority (SEIAA), Karnataka
Room No. 706, 7TH Floor, 4th Gate, M.S Building,
Bangalore-560001, Karnataka
Email: msseiaakarnataka@gmail.com
7th October 2025
Sub: Representation pursuant to the Hon’ble Supreme Court order in Civil Appeal No. 11021/2025 dated 8th September 2025 on M/s Honnavar Port Pvt Ltd
Reference:
1. Representation dated 18th December 2024 to your office by ‘Karvali Menugarar Karmika Sanga’ & 3 others;
2. The Hon’ble Supreme Court order in Civil Appeal No. 11021/2025 dated 8th September 2025
Respected Sir,
It is respectfully submitted that on 8th September 2025, the Hon’ble Supreme Court, in Civil Appeal No. 11021/2025 (Karvali Menugarar Karmika Sanga v. SEIAA & Anr), was pleased to hold that “it is well open to the appellant to approach the State Environment Impact Assessment Authority, as law so provides”, when hearing the claim of the Appellant that they have not been recognised as stakeholders and hence their grievances have not been heard, or factored in. A copy of the Hon’ble SC order is annexed as Annexure–1.
It is pertinent to state that, owing to the decision of your office to exempt the requirement of public hearing at the stage of issuance of the Terms of Reference (ToR) on 12th August 2024, the fisherfolk community has been denied its rightful opportunity to raise objections and concerns with respect to the proposed Honnavar Port. This denial was further compounded when a fresh public hearing was not conducted at the stage of issuance of the Environmental Clearance dated 31st December 2024.
It may be recalled that the affected fisherfolk along with civil society representatives had, by way of a representation dated 18th December 2024, already placed on record their specific concerns regarding the impacts of the port and its allied infrastructure. However, till date, no response has been received to the said representation. A copy of the 18th December 2024 representation is annexed as Annexure-2.
Be that as it may, and in continuation of our earlier submissions, and in compliance of the Order of the Hon’ble Supreme Court , we now seek to place before your office serious concerns and material discrepancies relating to the port project and its allied infrastructure, which directly affect the lives and livelihood of the Kasarkod fisherfolk community.
Misrepresentation of Kasarkod Fishing Port as ‘Fish Landing Centre’ in CZMP Map No. 25: It is submitted that the existing Kasarkod Fishing Port, situated in Kasarkod village on the left banks of the Sharavathi river, has been erroneously shown as a ‘Fish Landing Centre’ in the Coastal Zone Management Plan (CZMP) Map No. 25. A copy of CZMP Map No. 25 is annexed as Annexure-3.
In contrast, the small fish landing area at Honnavar side (on the right bank of Sharavathi river) has been incorrectly demarcated as a ‘Fishing Port’.
Information obtained under RTI confirms that, by Government Order No. AHF 51 SFS 2015, Bangalore, dated 15th September 2016, the Department of Animal Husbandry and Fisheries, in exercise of its powers under Section 2(g) of the Karnataka Marine Fisheries (Regulation) Act, 1986, has formally declared Kasarkod Harbour, Honnavar, as a ‘Fishing Port’.
Furthermore, the Government Order dated 15th September 2016 clarifies that no ‘Fish Landing Centre’ exists in Honnavar Taluk. Therefore, the current CZMP demarcation is factually inaccurate and contrary to the official Government notification.
It is pertinent to highlight that the CZMP Maps for the State of Karnataka prepared under CRZ Notification 2019 suffers from various shortcomings. To name a few- misrepresentation of existing fishing infrastructure, non-demarcation of fisher folk houses and coastal commons, non-demarcation of Kasarkod as Turtle nesting beach, demarcation of Port Limits covering our properties without consultation, etc.
It is pertinent to highlight that as per Para 6 (vi) of the CRZ Notification, 2019 the State has the power to revisit the CZMP maps. The highlighted discrepancies is reason enough for such a revision. A copy of the RTI response inclusive of Government Order No. AHF 51 SFS 2015, Bangalore, dated 15th September 2016 is annexed as Annexure-4.
The alignment and width of the proposed port connectivity road have undergone significant changes since the Public Hearing conducted on 27th January 2012: As per the EIA Report submitted in 2012 for obtaining Environmental Clearance, the connectivity road was proposed by expanding the existing single-lane road along the shoreline, running parallel to the coast for approximately 4 km from the project site through Kasarkod village up to National Highway-66, with a proposed width of 25 metres.
In contrast, the EIA Report submitted in 2024 now proposes an entirely different alignment. The connectivity road is planned parallel to the existing road but at an offset distance of about 100 metres, with a reduced total length of 2.58 km from NH-66 to the project site, and an increased width of 30 metres.
Further, a survey conducted in February 2025 was specifically intended to identify and demarcate households and community property within 35 metres from the High Water Mark that would be directly impacted by this revised alignment.
It is evident that there has been a substantial change in the material particulars relating to the alignment, length, and width of the port connectivity road passing through the sea shore of Kasarkod village. These alterations, introduced after the Public Hearing of 2012, constitute significant deviations that were never placed before the affected communities for consultation.
Survey of Fisherfolk Properties Impacted by 35m Wide Road Conducted in Secrecy (February 2025): It has come to light, through information obtained under the Right to Information Act from the Office of the Deputy Commissioner, Karwar, that a survey of fisherfolk properties falling within 35 metres of the High Water Mark was completed on 26th February 2025 and the report on the same was circulated between various Government Department by 21st May 2025. However, this report has neither been made available to the Kasarkod Gram Panchayat nor shared with the fishing unions and affected fisherfolk whose properties and livelihoods stand to be directly impacted by the proposed port access road.
It is further submitted that the survey grossly underestimates the number of infrastructures and fishing-related sheds that will be lost due to the construction of the 35-metre-wide road. RTI response dated 1st August from Deputy Commissioner, Karwar is hereto marked and annexed as Annexure-5.
Omission of Kasarkod Village from the List of Impacted Fishing Villages in the EIA Report
It is submitted that the EIA Report (Chapter 3: Description of Environment, Table 3-35) lists 17 fishing villages along with details on the number of families, traditional fishermen families, BPL families, and fisherfolk population, purportedly sourced from the CMFRI Fishery Census Handbook 2016 for Karnataka State.
However, the details pertaining to Kasarkod village, where the proposed port project is located, have been entirely omitted in the report submitted by HPPL.
As per the CMFRI Fishery Census Handbook (2016), Kasarkod village comprises 752 fishermen families, including 719 traditional fishermen families, 696 BPL families, and a total fisherfolk population of 3,736.
It is further significant to highlight that Kasarkod village hosts the largest fisherfolk population in the entire Honnavar Taluk. The deliberate exclusion of this vital data renders the EIA report incomplete, misleading, and in violation of the requirement to present a true and comprehensive picture of the project’s social and livelihood impacts.
The report in its entirety can be accessed at the link below:
https://drive.google.com/drive/folders/1V-GuQPbgU0jcjtgiSU651xxX5GJfB-i7?usp=sharing
Non-disclosure on Rehabilitation and Resettlement that it ought to arise from the road and rail connectivity: It is submitted that the proposed 2.58 km long road and 8.5 km railway network is aligned through the coastal village of Kasarkod which as per 2016 data is inhabited by 752 fisherfolk families and has a total population of 3,736 individuals. It is submitted that all these fisherfolk families in Kasarkod village were granted land by the Government of Karnataka in 1979 and were rehabilitated from flood affected village of Mallukurva. Since then, they have inhabiting on the same land and has been paying taxes and levies to the Government.
The EIA report submitted by HPPL fails to acknowledge the existence of such a huge fisherfolk population in the nearest vicinity of the project and makes no provision for their rehabilitation and resettlement.
In fact, Chapter 7 of the EIA report under Table 7-1: Public Hearing Action Plan, responding to a specific objection raised during the PH about the land acquisition, the proponent vehemently denies the requirement of private land acquisition and requirement of rehabilitation. Notably, the Project Engineer of the Project Proponent has himself publicly stated that 101 structures are falling on the 35 meter road being planned to be built along with the port, which indicates that there is need for rehabilitation.
Provision of Turtle Conservation Plan: The EIA Report refers to a Turtle Conservation Plan in Appendix Q, which has not been made available on the Parivesh Portal. Accordingly, it is requested if a copy of the said Turtle Conservation Plan can be shared with the undersigned.
In light of the above, it is respectfully submitted that the Honnavar Port project suffers from serious procedural lapses, misrepresentations, and material omissions that strike at the root of its validity under the Environmental Impact Assessment (EIA), 2006 framework and the Coastal Regulation Zone (CRZ) Notification, 2019. The denial of public hearing, the misclassification of fishing infrastructure in the CZMP, the omission of Kasarkod village and its large fisherfolk population from the EIA, the non-disclosure of rehabilitation and resettlement obligations, and the secretive and inaccurate survey of properties cumulatively demonstrate a failure to uphold the principles of transparency, natural justice, and participatory decision-making mandated under law.
Given the Hon’ble Supreme Court’s order dated 8th September 2025, affirming our right to approach this Authority, we humbly request that the SEIAA:
Reconsider and review the Environmental Clearance granted to M/s Honnavar Port Pvt Ltd on 31st December 2024, in light of the discrepancies and omissions detailed herein;
Direct a fresh and comprehensive assessment, including mandatory public hearing, with full participation of the fisherfolk of Kasarkod and other affected villages;
Ensure a transparent re-survey of properties and infrastructures affected by the proposed 35-metre-wide port access road, with prior notice to and participation of the Kasarkod Gram Panchayat and the fishing unions; and
Take all further steps necessary to safeguard the rights, livelihoods, and environment of the Kasarkod fisherfolk community.
We, the affected fisherfolk and their union, therefore pray that this Authority act in the spirit of fairness and legality to ensure that the Honnavar Port project does not proceed at the cost of our community’s survival and the fragile coastal ecology.
Respectfully,
Sd/-
(Rajesh Govind Tandel)
President, Karvali Menugarar Karmika Sanga
Copy marked to:
The Additional Chief Secretary
Government of Karnataka,
Forest, Ecology & Environment Department,
M.S.Building, Dr.Ambedkar Veedhi, Bangalore – 560 001
Email: prs-fee@karnataka.gov.in
Director of Ports & Member (Maritime & IWT Operations)
Directorate of Ports & IWT, Baithkol, Karwar
Email: directoratep@gmail.com
Directorate of Fisheries Government of Karnataka
3RD FLOOR, TOWER Dr, PODIUM BLOCK,
Vishweshwaraiah Rd, Ambedkar Veedhi, Vasanth Nagar,
Bengaluru, Karnataka 560001
Email: dfkamataka@rediffmail.com
Deputy Commissioner, Karwar
Uttar Kanada district, Karwar-581301
Email: dckarwar@gmail.com
