In her complaint, Singh has alleged that Shivaji Park, under the Coastal Regulation Zone (CRZ) notification, 2011, falls under the CRZ-III category. As part of this notification, all open spaces, parks, gardens and playgrounds are categorised as a 'no development zones.' "Hence, there is no question of allowing even a makeshift memorial there. This is a gross violation of environmental laws. Even though Bal Thackeray deserves due respect, no one is above the law of the land," Singh said.
"Also, under section 15 of the environmental protection act, 1986, there is a clear need to fix accountability and prosecute those who have violated these CRZ norms by erecting such a structure," Singh said.
With Singh's complaint throwing light on the environmental restrictions on constructing anything at Shivaji Park, the government and Sena will now be forced to look at other options.
Singh's petition names both the state government and the BMC for allowing the memorial to come up.