149 bathing as well as worship of the Mother Ganga.12 However, the immensity of traffic is taking its toll on the waterway where “every day, around three million liters of sewage is emptied into the Ganges … [including] waste from tanneries, chemical plants, textile mills, slaughter houses and even hospitals.”13 As the monsoon and Himalayan glaciers that feed the river become more unpredictable due to climate change, the fate of the river hang in the balance. Clean up, re-planting, and recycling efforts have been aggressive and passionate - but often only making a small dent in a massive problem.14 In 2017, the lack of regulation or protection prompted officials to bring the case to state courts who decided “extraordinary measures needed to be taken to protect the river” or else it may “lose [its] very existence.” The Ganges River was granted personhood, leaning heavily on its “sacred and revered” position in Hinduism. However, due to lack of clarity on who would serve as the guardian of the river — that spans four distinct territories in India, the personhood distinction was revoked by authorities.15 As the previous two examples show, for a natural entity to be granted personhood there are a couple of implicit requirements: there must be a part who can clearly be designated guardians; the natural entity must face a significant threat in viability; it must be demonstrated that the natural entity has a characteristic that elevates it from a human-centered purpose to one larger (and perhaps more spiritual in nature) and without a doubt, there must be clever legal team behind the cause. Historically, cases where personhood has been and remained successful have a heavy participation from Indigenous communities. Comprehensive examples can be seen in the case of New Zealand's Whanganui River and the Māori people as well as in Ecuador's constitution, which 12 “Yamuna River,” Encyclopedia Britannica (Encyclopedia Britannica, Inc.), accessed November 12, 2022, https://www.britannica.com/place/Yamuna-River. 13 Stuart Butler, “The Ganges: River of Life, Religion and Pollution,” Geographical, May 27, 2022, https://geographical.co.uk/culture/the-ganges-river-of-life-religion-and-pollution. 14 Fred de Sam Lazaro and Sarah Clune Hartman, “India's Effort to Clean up Sacred but Polluted Ganga River,” PBS (Public Broadcasting Service, February 11, 2020), https://www.pbs.org/newshour/show/indias-long-term-effort-toclean-up-pollution-in-sacred-ganga-river. 15 Sheber, supra note 4.
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