This paper analyses the impact of citizens' actions for protecting the environment in the context of the institutional features of developing countries. The enforcement of environmental regulation is likely to be weak in developing countries, and thus their citizens are being compelled to sue the polluters or take direct actions that are costly to the polluter. The theoretical and empirical analysis, based on 25 cases of citizens' action from the Kerala State of India, show that their impact is influenced by the institutional deficiencies of the country. Such deficiencies include the delay in resolving conflicts through court interventions and the lower cost of taking actions of civil disobedience due to poor law and order enforcement. The analysis leads to the conclusion that citizens' actions may not be very effective in controlling pollution from existing factories, and may be effective in blocking the establishment of new factories. Both these outcomes, i.e., the continued pollution in existing factories, and zero-pollution (or non-establishment) of new factories/projects, cause social losses, in the former case for the citizens and in the latter for the polluter.