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Comparative Legal Approaches to Wetland Conservation in India, the United States and China

Oshin Gupta * and Madhuri Parikh

1 Institute of Law, Nirma University, Ahmedabad, Gujarat India

Corresponding author Email: oshingupta1625@gmail.com

DOI: http://dx.doi.org/10.12944/CWE.21.1.21

Wetlands have long-standing economic and socio-cultural benefits and provide essential ecosystem services; yet they are amongst the most administratively vulnerable habitats on the planet. Despite their widely recognized worth, they are significantly collapsing due to governance failure, rapid economic and population growth and land-use policies. Through a comparative legal analysis of India, the United States (US), and China, this article examines how differing legal and regulatory frameworks shape wetland conservation outcomes. The study has four primary objectives: to compare the governance structures of the three jurisdictions; to analyze the role of ecological attributes in legal protection; to evaluate implementation challenges and best practices; and to propose an integrated governance model. The analysis reveals that while each country has developed distinct legal instruments- from India’s decentralized Wetland Rules and the U.S.’s permit-based Clean Water Act to China’s centralized Wetland Protection Law- effectiveness is consistently undermined by fragmented enforcement, regulatory ambiguity, and inadequate community integration. The article argues that sectoral approaches are insufficient to ensure wetland resilience and inter-generational equity. Instead, it contends that wetlands must be incorporated into legal, economic, and socio-cultural frameworks through an “integrated governance model” that combines robust regulation, participatory stewardship, scientific monitoring, and climate-adaptive planning.

Ecosystem Services; Integrated governance; Legal Frameworks; Socio-ecological Systems; Wetland Conservation; Wetland Resilience

Copy the following to cite this article:

Gupta O, Parikh M. Comparative Legal Approaches to Wetland Conservation in India, the United States and China. Curr World Environ 2026;21(1). DOI:http://dx.doi.org/10.12944/CWE.21.1.21

Copy the following to cite this URL:

Gupta O, Parikh M. Comparative Legal Approaches to Wetland Conservation in India, the United States and China. Curr World Environ 2026;21(1).

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