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[Cites 4, Cited by 0]

National Green Tribunal

Sarla Soni vs State Of Rajasthan on 25 September, 2023

   Item No. 1
                        BEFORE THE NATIONAL GREEN TRIBUNAL
                            CENTRAL ZONE BENCH, BHOPAL
                              (Through Video Conferencing)
                        Original Application No.107/2023 (CZ)
                               (O.A. No. 601/2022-PB)
   '




   Sarla Soni                                                                 Applicant(s)
                                              Versus
   State of Rajasthan & Ors                                                 Respondent(s)

   Date of Hearing: 25.09.2023
   CORAM: HON'BLE MR. JUSTICE SHEO KUMAR SINGH, JUDICIAL MEMBER
          HON'BLE DR. A Senthil Vel, EXPERT MEMBER

       For Applicant(s):

       For Respondent(s) :                    Mr. Rohit Sharma, Adv.
                                              Mr. Shoeb Hasan Khan, Adv.
                                              Mr. H imanshu Bhushan, Adv.
                                       ORDER

1. The main issue involved in this application is consideration and need for regulatory resign to check acetic activities in testing of gold, compliance of guidelines issued by the CPCB, requirement of grant of CTE and the siting criteria.

2. Ms. Sarla Soni has sent to this tribunal by post copy of the letter petition which has been treated and registered as Original Application. The applicant has submitted that she established Gold Asseying & Hallmarking centre in the name of Kapees Hall Marking center at Byavar District Ajmer (Rajasthan) in rented premises. CTE was granted to her by RSPCB on 06.08.2021 on the basis of which she installed the pollution control systems and also took membership of UCCI, Udaipur for management and disposal of hazardous waste. Thereafter, she applied to RSPCB online for CTO on 20.09.2021 after completing all the formalities, but she was informed by letter dated 23.03.2022 that CTE granted to her had been cancelled as she had not established Gold Asseying & Hallmarking centre in the industrial area. No where in India Gold Asseying & Hallmarking centre are established in Industrial area and the same have been established in the main shopping centres. In the letter petition, the applicant has prayed for grant of CTO while mentioning that she is suffering huge losses due to denial of CTO. In support of her claim the applicant has attached copies of documents showing grant of CTO by the State Pollution Control Board for operation of such centers in the markets/commercial areas.

3. The matter was taken up by this Tribunal on 20.09.2022 and notices were issued to the respondents in addition to constituting a Committee to submit the Factual and Action taken Report in light of the relevant rules.

4. The matter was again taken up by this Tribunal on 17.01.2023 and the Tribunal observed as follows:

3. Respondents no. 2 and 3 have mentioned in their reply that in compliance with order dated 18.11.20219 passed by this Tribunal in O.A No. 568/2019 titled as James Jose, Managing Director, CGR Hallmarkers Pvt. Ltd. Vs. Govt. of India guidelines for Gold Assaying and Hallmarking Centers were issued by CPCB in October 2020 and issuance of consent to establish/operate in States/UTs comes under the jurisdiction of the SPCBs and PCCs.
4. In its reply respondent no. 5-RSPCB has mentioned that respondent no. 5-RSPCB vide letter dated 28.03.2022 sought clarification from CPCB to which the CPCB vide letter dated 25.07.2022 clarified that Gold Hallmarking Assaying Facilities/Centers should be established as per the siting Policies/Guidelines of Local Administration. In its reply respondent no. 5- RSPCB has further mentioned that on the basis of the clarification received by the State Government vide letter dated 11.10.2022 the State Board issued order dated 20.10.2022 to the effect that the Consent applications related to Gold Assaying and Hallmarking Centers may be cleared for the existing units provided that they are situated in area where commercial/industrial activities are allowed as per Master/City Plan.

5. Mr. Nishant Awana, learned counsel for the respondent no. 5 has placed before us copy of letter dated 10.01.2023 written by the Director and Joint Secretary, Department of Environment and Climate Change to the Member Secretary, RSPCB, Jaipur which reads as under:-

"Subject:- Disposal of Consent applications for Gold Assaying and Hallmarking Centers.
                          X         X            X                 X


          Kindly          refer         to     your            letter      no.     F.12

(PSC36)/RSPCB/Jaipur/2264 dated 29.11.2022 vide which clarification has been sought for disposal of consent applications for Gold Assaying and Hallmarking Centers.

In this regard, I am directed to state that CTE/CTO may be granted to Gold Assaying and Hall Marking units to operate without any condition of land conversion in the cities having no master plan/city plan provided these units are in local market place/bazaar where other commercial activities are being carried out.

X X X X"

5. The matter was taken up by this Tribunal in Original Application No. 568 of 2019 and vide order dated 18.11.2019, it was found that:

a. Almost all the assay and hallmarking centers are located inside city areas or in busy commercial or business complexes. b. These units seldom comply with the pollution control norms or have adequate measures to contain toxic fumes or emissions emanating in the process of precious metal assaying by conventional fire assay method.
c. There is no emission monitoring systems in these hallmarking centers.
d. There are no personal protective equipments available or being used by the personals handling test procedures. e. Regulatory procedures for the disposal of hazardous residues generated during assaying/testing are not followed in many of the facilities.
f. The approved gold hallmarking method is fire assay test, which requires destructive sampling and many of the manufacturer (customers of hallmarking centers) do not prefer sampling of the finished jewellery articles. Due to this spurious hallmarking practices are on rise without conducting standard fire assay test."

6. The Tribunal further observed as follows:

3. The Committee also considered the guidelines dated 02.09.2018 for recognition and operation of hallmarking centers. 851 hallmarking facilities are recognized in Maharashtra, West Bengal, Tamil Nadu and other States. The Committee conducted 'Fire Assay Test' and also considered 'hazardous waste generation' and 'Gold Assay Techniques'. In the hallmarking centers, it was observed that toxic emissions are released.
2. The Committee has made following observations and recommendations:

"7.0. OBSERVATIONS OF THE JOINT COMMITTEE i. The testing of the jewellery as well as the marking is done in approved, private assaying & hallmarking centers across the country. Approval and monitoring of such private undertaking are done by BIS. Although, hallmarking gold jewellery is mandatory, it is yet to be implemented. Due to wide acceptance of BIS hallmarking among consumers, fake hallmarking of jewellery is on rise.

ii. Most of the hallmarking centers are in the busy commercial areas.

iii. Even though there are many techniques available for assaying precious metal with merits and demerits, the conventional fire assay is still the preferred assaying method for higher accuracy, repeatability, moderate and comparatively lesser cost of analysis.

iv. The fire assay test does create toxic emissions by way of toxic metal and acidic fumes.

v. The AAS or ICP methods, requires expensive equipments, sample processing by acid digestion and trace amount of sample is lost during analysis.

vi. XRF is a non destructive analysis with moderate cost of analysis and requires flattened sample for accurate analysis.

vii. Spark/ Arc OES is a potential method, almost non destructive in nature and only limitation is the high equipment cot.

8.0 SUGGESTIONS OF THE JOINT COMMITTEE A. All the gold assaying and hallmarking centers in the country shall obtain the Consent to Establish / Consent to Operate under Water (Prevention and Control of Pollution) Act, 1974 & Air (Prevention and Control of Pollution) Act, 1981 of the State Pollution Control Boards / Pollution Control Committees. These units shall also obtain authorization under Hazardous and Other Wastes (Management & Transboundary Movement) Rules, 2016. The above regulatory requirements shall be made mandatory to all gold assaying/ hallmarking facilities and the same may be incorporated in the BIS guideline for gold assaying and hallmarking. The committee suggested the KSPCB to issue notice to all defaulting units.

B. The lead fumes generated during cupellation and the acidic nitrous fumes generated during the parting acid treatment are to be treated by a proper fumes extraction I treatment system. Technical guidelines shall be formulated for selection, installation and operation of proper exhaust arrangement for fire assay furnace, parting acid chamber and for the fire assay room for proper extraction and treatment of fumes before discharging into atmosphere. C. Spent cupels containing heavy metals, scrubber water residue containing lead and spent parting acid are the specific hazardous wastes generated during fire assay which need to be disposed properly through authorized waste disposal facilities as per the norms.

D. The conventional fire assay method requires, sample to be scraped/ cut out of the sample and thus it is not an acceptable choice for the finished jewellery articles. Moreover, the use of hazardous materials like lead and parting acids during assaying, also make this methodless preferable though it is a robust method for assaying. Due to the above constraints, alternate instrumental methods with low pollution foot print shall be explored.

E. AAS and ICP methods require expensive equipments and elaborate sample processing in the form of acid digestion during analysis. As in many other countries XRF can be adopted for assaying and hallmarking, but the only limitation is the requirement of flat/ flattened sample. F. Spark or Arc OES is a potential method for precious metal assaying which is almost non-destructive method with minimum or no sample processing. This method is already used in many metal industries to test the purity of alloys and metals."

7. In compliance of the directions passed by the Tribunal in Original Application No. 568/2019, James Jose, Managing Director, CGR Hallmarkers Pvt. Ltd., Vs Govt. of India, CPCB has issued Guidelines for Gold Assaying and Hallmarking Centers in October, 2020. Further, CPCB vide its guidelines, has directed all Gold Assaying and Hallmarking centers to obtain necessary Consents under the provisions of Water (Prevention and Control of Pollution) Act, 1974 & Air (Prevention and Control of Pollution) Act, 1981 86 Hazardous and Other Wastes (Management & Transboundary Movement) Rules, 2016 from the concerned State Pollution Control Boards/ Pollution Control Committees and also directed BIS to make it mandatory to have a copy of consents issued by SPCBs/ PCCs under Water Act 1974 & Air Act 1981 and Authorization certificates while issuing the BIS certificates.

8. The guidelines for Gold Assaying Hallmarking Centres issued in October, 2020 by the Central Pollution Control Board provides as follows:

"2.0 Hallmarking:
The BIS (Bureau of Indian Standards) Hallmark is a certifying mechanism to certify the purity of precious metals jewellery viz. gold and silver, sold in India. The testing and marking of the jewellery is done in BIS certified Assaying & Hallmarking centres across the country. BIS has framed & published the "Guideline (HM/A&HC/Guidelines/2, September,2018)" for recognition and operation of hallmarking centres. BIS guidelines stipulate the procedures for grant, operation, renewal, suspension and cancellation of recognition of Assaying and Hallmarking (A &H) Centers. Indian standard IS 15820:2009 is the basis for recognition of assaying and hallmarking centers, which specifies a Fire Assay test for Assay and Hallmarking of gold, following the procedure prescribed in the method IS 1418: 2009 (Assaying of Gold in Gold Bullion, Gold alloys and Gold Jewelry/Artefacts: Cupellation- Fire Assay Method.) There are 923 recognized Gold Assaying and Hallmarking facilities in India. Highest number of such facilities is in Southern region (312 Nos), followed by Western Region (203 Nos), Eastern Region (181) Central Region (133) and Northern Region (94).

3.0 Gold Assaying Process:

Hallmarking of jewellery/artefact is done in BIS certified facilities/centres, which acts as testing laboratories. These hallmarking facilities/centres/labs are located inside city areas or in busy commercial or business complexes nearby the jewellery manufacturing hub/markets.
Assaying is the technical term used for the quantitative chemical analysis of precious metals. In context of Gold Jewellery, assaying means determination of gold in the jewellery/article. The steps involved in Gold Assaying process are as follows:
i. Reception Section: The process starts from reception.
Jewelry are received from different parties i.e. jewelers and are sorted as per their purity claimed by the party and after acceptance, the jwellery are sent for Assaying. ii. X-ray Fluorescence (XRF) Section: After receiving the jewellery sample, the fineness (purity as declared by customer) of the samples are verified by the XRF machine by comparing with the reference material. iii. Melting Section: The accepted samples (Jwellery/artefacts) are cut/drilled in the defined quantity as per BIS guidelines and these drilled/cut piece of sample is then homogenised in melting furnace in graphite crucibles. iv. Sample preparation: The homogenized sample is weighed and other metals i..e. silver and copper is mixed with the homogenised sample and put in lead foil, which is then assayed . Out of several techniques available for assaying precious metals, Fire Assaying is one of the oldest and most reliable methods for the quantitative analysis of gold and silver.
v. Assaying section (Fire Assay Test): As per the standard IS 15820:2009, Assay and Hallmarking of gold is done by the fire assay test as per the method IS 1418: 2009 (Assaying of Gold in Gold Bullion, Gold alloys and Gold Jewelry/Artefacts). In this test, magnesia or calcium phosphate cupels, parting acids (Nitric acids of specific gravity 1.2 & 1.3 g/cm3), lead foil, precious metals (silver) and other metals like copper are used. The fire assay method is based on the principle of removal of all base metals like lead, copper, etc, present in the sample from noble metals like gold and silver through the process of cupellation and Parting.
Cupellation: In this process samples are kept in cupels for cupellation inside the muffle furnace for 25 min at 1100oC. During the process, lead is oxidised into lead oxide & emitted in the form of fumes, whereas other impurities alongwith lead is absorbed in cupels.
Parting: Once cupellation is completed, a gold and silver alloy in the form of bead is obtained. Separating silver from gold by selectively dissolving silvergold alloy in Nitric acid, is known as parting.

4.0 Sources of Environmental pollution associated with Fire Assay Procedure and Environmental issues of Hallmarking Centres:

Main sources of pollution in Fire Assay Testing and other environmental issues associated with hallmarking centres are as under:
a) Air Pollution:
Lead oxides and Nitrous fumes are generated during cupellation and parting acid treatment respectively. These fumes, if inhaled may pose a health hazard to personals/workers involved in assaying, if not addressed properly.
To control the emissions, fume extraction system is installed and the fumes generated are sucked through suction hood and exhausted fumes are scrubbed by sprinkling of water. The scrubbed water is collected and the recirculate back in the process.
b) Water Pollution As such there is no usage of water in the process, however the scrubbed water is generated from scrubbing operations during fume extractions. Though the scrubbed water is recycled and recirculated in the process, but over a period of time it is discharged which contain lead as contaminant..
b) Hazardous waste:
During the process of cupellation, Cupels become contaminated due to the absorption of lead and other heavy metals. Used/Spent cupels bearing lead and scrubbed water containing residues of lead are the hazardous wastes generated during fire assay posing risk to the environment.
The spent acids generated during parting process are also hazardous waste generated in the fire assay test. The parting process involves boiling of a metal mixture (Gold & Silver) with parting acid (Conc. Nitric acid) to remove the silver. In this process silver present in the metal gets dissolved with nitric acid leaving only gold in its purest form. After recovering dissolved silver from acid, the spent parting acid (Conc nitric acid) is generated which is highly acidic and may adversely affect the receiving environment, if discharged without proper neutralization and treatment. The quantity of nitric acid used in the process is approximately 0.5 litres/assaying and on average daily spent acid generation is 1.0 lit/day. Spent acid has pH about 2.0. Spent acid generated is collected in the small container (20-25 littres) to recover silver.

5.0 Environmental Guidelines:

Environmental Guidelines for "Environmental Guidelines for Gold Assaying and Hallmarking Centres"
1. The emissions from cupellation and parting process should be channelized through a well-designed suction hood and duct arrangement system to control lead and nitric acid fumes.
2. The extracted fumes from cupellation and parting should be scrubbed by installing well designed scrubbing system for removing the pollutants from the exhausted air & discharged through appropriate stack as per SPCBs consent conditions.
3. The adequacy/efficiency of the Scrubber system installed need to be verified by the SPCBs or through Expert institutions.
4. The spent acid generated from parting acid should be sent to TSDF or neutralized before its disposal. These Hallmarking centres should have facilities of pH testing like litmus paper, pH meter to check that the spent acid is neutralized. Page
5. The Spent cupels/scrubbed water containing lead should be sent to TSDF or to the authorized registered lead recyclers dealers.
6. Manifest/records should be maintained for storage and disposal of spent acid/cupels/scrubbed water residue generated during the process.
7. Proper personal protection equipment's such as Face Shields, Helmets, Acid Gloves, First Aid Box, etc. must be used by the personals carrying out fire assay & parting test.
8. Good housekeeping should be maintained by frequent and regular cleaning of the assay lab, preventing lead dust from accumulating on laboratory surfaces.
9. All the gold assaying and hallmarking centers shall obtain necessary Consents under the provisions of Water (Prevention and Control of Pollution) Act, 1974 & Air (Prevention and Control of Pollution) Act, 1981 & Hazardous and Other Wastes (Management & Transboundary Movement) Rules, 2016 from the concerned State Pollution Control Boards / Pollution Control Committees.
10. The Gold Hallmarking Assaying facilities/Centres should be established as per the siting policies/guidelines of local administration.
11. The Blood test of worker for lead, should be done once in a year who has worked for at least 6 months in such facility.
12. BIS may explore new alternate instrumental methods like Spark or Arc OES with low pollution foot print for assaying of Gold.
13. BIS may also make mandatory to have a copy of consents issued by SPCBs/PCCs under Water Act 1974 & Air Act 1981 and Authorization certificates while issuing the BIS certificates.
9. The contention of the Rajasthan State Pollution Control Board is that on 24.06.2020 a meeting was called to discuss the requirement of seeking land conversion and it was directed that the new application may be reverted back to the applicant if the industry is not having appropriate land conversion and in light of that order, the application of applicant was referred back for compliance. Feeling the difficulties of problems, since siting criteria has not been specifically laid down by the guidelines issued by the CPCB, the state PCB brought the consideration before the state board while considering the application related to hallmarking centers.
10. CPCB vide order dated 12.01.2021 has categorized the hallmarking and assaying centers under orange category. Subsequently, the answering respondent vide its order dated 21.01.2022 has also categorized the hallmarking and assay centers under orange category.
11. It is submitted by the RSPCB that as per the Operating Manual, acknowledged and recognized by the State Government and the State Board, land allotment/land conversion order for project for intended land use is a mandatory document for processing of any Consent to Establish application under the Water Act and the Air Act.
12. The applicant was issued Consent to Establish vide order dated

06.08.2021 inadvertently and the same has been revoked vide letter dated 23.03.2022, for the reasons that the unit was not established on the industrial land/ land converted for industrial purpose and these units were categorized under 'Orange' category by the State Board in the Order dated 21.01.2022.

13. The Rajasthan State Pollution Control Board has submitted the reply to the effect:

"That an inter departmental meeting was held under the Chairmanship of Chief Secretary, Govt. of Rajasthan on 18.02.2022 to discuss applicability of land conversion for Industrial/Commercial purposes in case of Consent applications for Gold Assaying 86 Hallmarking Centers under the provisions of the Water Act, 1974 and the Air Act, 1981. In the meeting, it was decided that RSPCB should apprise CPCB about the above issues regarding applications for consent of the Gold Assaying and Hallmarking Centers (GAHC) and Automobiles Service Centers and seek clarification.
That the answering respondent vide letter dated 28.03.2022 has sought clarification from CPCB on the issue as discussed in the meeting dated 18.02.2022 vide letters dated 12.04.2022 and 30.05.2022.
That the CPCB vide letter dated 25.07.2022 clarified the issue, stating that "Gold Hallmarking Assaying facilities/Centers should be established as per the siting Policies/ Guidelines of Local Administration"

14. It is further argued that the State PCB forwarded the clarification received from the CPCB to the State Government for clarification and state board vide order dated 21.10.2022 directed as follows:

"The Consent applications related to Gold Assaying & Hallmarking Centers may be cleared for the existing units provided that they are situated in area where commercial/ industrial activities are allowed as per Master/City Plan"

15. It is to be noted that the meeting dated 14.06.2020 had not considered the subject under question for Gold Assaying and Hallmarking centres and the CPCB has issued guidelines and circular treating the Gold Assaying and Hallmarking in orange category and state has also issued notification dated 21.01.2022, treating it as a Orange category.

16. The matter was again considered by the RSPCB and vide meeting dated 18.02.2022, it was directed that the Gold Assaying and Hallmarking centers shall obtain necessary consent and authorization from the concerned state boards and committees since the matter was categorized in orange category and some of the units are in operational in commercial and residential have represented to the RSPCB for waiving of requirement of land conversion for the industrial purposes activities and it has been notified and found by the State PCB that it is not industrial activity, thus a decision was taken to direct the RSPCB to study the policy adopted by other PCB's and to formulate the policy and to seek clarification from the MoEF & CC and the CPCB. In view of the above facts, the revocation of CTO and the cancellation of continuance of the activities are against the guidelines issued by the RSPCB and the guidelines issued by the CPCB. The decision which has not been taken directly by the CPCB cannot be indirectly enforced by the SPCB and with further even the SPCB has not taken any decision with regard to the conversion of the land and on this ground the rejection of the application was malafide and against the rules which requires reconsideration.

17. RSPCB vide decision taken on 12.04.2022, which has annexed as annexure-6 taken a decision that this is non industrial operation activities and facilities. A letter has been issued from the SPCB to the CPCB with a clarification that Gold Assaying and Hallmarking Centres are not required to convert land use or getting land conversion done for industrial purposes as treating service/facilities as non industrial operation. It is submitted that the clarification is still awaited and thus on the ground that the matter is pending before the CPCB for taking any decision, the revocation of the consent to operate is against the provision of law.

18. The State PCB vide letter dated 29.09.2022 has further addressed the Government with the following facts:

As per the provision of the Water and Air Act, all the industries/activities/projects are required to obtain Consent to Establish/ Operate from the SPCBs. For considering such applications, RSPCB has sought clarification from CPCB. CPCB vide its letter dated 25.07.2022, issued in supersession to its earlier letter, has clarified that the Guidelines for GAHCs clearly prescribed the siting criteria under its point no. 10 that, "GAHCs should be established as per the siting policies/ guidelines of local administration."
RSPCB vide its letter dated 30.05.2022 and 22.08.2022 had written letters to the Director General, BIS, New Delhi to consider issue of BIS certificates to the Gold Assaying and Hallmarking Centres at their level till a final view is taken in this regard. Subsequently, BIS has given relaxation to the GAHCs till 20.10.2022.
Furthermore, based on communication held with CPCB, informally, they have communicated that such bottleneck issues are being faced in the state of Rajasthan only.
In view of this, the State Government is requested to take a view in this regard at the earliest.

19. In response to the letter the Government of Rajasthan has communicated that these applications may be cleared for the existing units of these categories provided they are situated in the area where commercial/industrial activities are allowed as per Master City Plan, and accordingly an office order dated 20.10.2022 was issued. In the reply submitted by the CPCB it has been submitted that the Gold Asseying & Hallmarking centres have been categorized under Orange category under non-industrial operations based on the pollution index and the State PCB's have been directed to follow the siting policy of the local administration. It is nowhere mentioned that the siting policy requires land conversion or the unit to be established in the industrial area. Learned counsel for the MoEF & CC has submitted that in light of the orders of the National Green Tribunal, the guidelines for Gold Asseying & Hallmarking centres has already been issued and this problem is being developed by the RSPCB by taking a separate decision which is problem of the SPCB and revocation of consent to operate is not in accordance with the guidelines.

20. In view of the above discussion, we direct as follows:

1. Guidelines issued for Gold Asseying & Hallmarking centres issued by the Central Pollution Control Board in October, 2020 and amendment thereafter must be complied with in letter and spirit by the respondents taking the Gold Asseying & Hallmarking centres in orange category in light of the circular and notification issued by the Central Pollution Control Board and that it is non-industrial activities.
2. In view of the above, the guidelines issued by the Central Pollution Control Board noted above must be updated and notified by the State of Madhya Pradesh, Rajasthan and Chhattisgarh within 15 days and compliance may be duly monitored thereafter. The State of Madhya Pradesh, Rajasthan and Chhattisgarh are also directed to publish the guidelines in the newspaper for implementation and compliance of the guidelines formulated by the Central Pollution Control Board. The Madhya Pradesh Pollution Control Board, Rajasthan Pollution Control Board and Chhattisgarh Pollution Control Board are directed to ensure the implementation status of the guidelines in their states strictly in letter and spirit.
3. The application of the complainant is allowed and the revocation of consent to establish order communicated vide letter dated 23.03.2022 to M/s Kapish Hallmarking Centre Second Floor Private No-201,HousIng No-18,Mataji, Tower Municipal No-2/103,Vinodilal Gali , Beawar, Tehsil: Beawar, District: Ajmer is set aside and SPCB is directed to reconsider the matter to all such revocations and to take a decision within a 30 days in accordance with the guidelines issued by the CPCB and the applicant shall be informed accordingly.
4. The State PCB is further directed to report with regard to proper personal protection equipment such as face shield, helmet and gloves, first aid box to be used by the personals carrying out for assay and parting test and blood test of workers for lead which was required to be done periodically and the action taken in this behalf within a time frame.
5. CPCB is directed to reconsider the environmental guidelines no. 5.0 (10) where the siting policy has been let to the local administration and to decide a fresh after considering the views and suggestions taking from all State PCB's to maintain the uniform policy throughout the nation and to avoid any anomaly and different criteria's. The same may be decided and formulated and published within a reasonable time.
6. A copy of the order be sent to the Central Pollution Control Board regional office at Bhopal for onward transmission to the CPCB, New Delhi, Member Secretary, State PCB (Madhya Pradesh, Rajasthan and Chhattisgarh) for strict compliance and for publication.

21. The Original Application stands disposed of accordingly.

Sheo Kumar Singh, JM Dr. A Senthil Vel, EM 25th September, 2023 O.A No. 107/2023 (CZ) PU