National Green Tribunal
Bhopal CitizenS Forum Through Its ... vs State Of Madhya Pradesh on 20 May, 2026
Item Nos.05&06
BEFORE THE NATIONAL GREEN TRIBUNAL
CENTRAL ZONE BENCH, BHOPAL
(THROUGH PHYSICAL HEARING (WITH HYBRID OPTION)
Original Application No.181/2025(CZ)
Bhopal Citizens' Forum
Through its Convenor Mr. Surendra Tiwari Applicant(s)
Vs.
State of Madhya Pradesh & Ors. Respondent(s)
With
Original Application No.192/2025(CZ)
(I.A.No.31/2026(CZ)
Rashid Noor Khan Applicant(s)
Vs.
State of Madhya Pradesh & Ors. Respondent(s)
Date of Hearing: 20.05.2026
CORAM: HON'BLE MR. JUSTICE SHEO KUMAR SINGH, JUDICIAL MEMBER
HON'BLE MR. SUDHIR KUMAR CHATURVEDI, EXPERT MEMBER
For Applicant (s): Mr. Harpreet Singh Gupta, Adv.
Mr. Harashwardhan Tiwari, Adv.
For Respondent(s) : Mr. Prashant M. Harne, for State of M.P.
Ms. Parul Bhadoria for MPPCB
Mr. Om Shankar Shrivastava, Adv. with
Mr. Pramod Malvia, EE/BMC
Mr. J.P. Sharma, Adv. for R-2
ORDER
1. Alarming deterioration of air quality in the city of Bhopal, also known as a City of Lakes, witnessing unprecedented rise in Air Quality Index (AQI), repeatedly reaching the very poor category with reading as high as 336, posing an immediate and serious threat to the health and lives of the residents adversely affecting the environment and 1 O.A. No.181/2025(CZ) with Bhopal Citizen's Forum through its Convenor Mr. Surendra Tiwari Vs. State of Madhya Pradesh & Ors.
O.A. No.192/2025(CZ) Rashid Noor Khan Vs. State of Madhya Pradesh & Ors.
human health has drawn the attention of the Bhopal Citizens' Forum and for taking immediate remedial measures, this application has been filed with prayer to direct the Respondents to stop artificial manipulation of AQI monitoring and to take immediate urgent air pollution mitigation measures in the city of Bhopal.
2. On 07th January, 2026, this Tribunal observed in following paras as follows:-
"6. The research paper reveals that both the air pollutant PM2.5 and the SARS-CoV-2 virus enter the lungs via the bronchial system (portal organ), with potential systemic health impacts through the blood circulation. Both PM2.5 and SARS-CoV-2 cause vascular endothelial dysfunction, oxidative stress, inflammatory responses, thrombosis, and an increase in immune cells. The SARSCOV-2 infection facilitates the induction of endothelial inflammation in several organs as a direct consequence of viral cytotoxic effects and the host inflammatory response, which can aggravate pre-existing chronic respiratory and vascular (coronary) dysfunction, and cause lung injury by alveolar damage, as well as stroke and myocardial infarction by inducing plaque rupture. Potential common pathophysiological mechanisms of increased risk thus relate to endothelial injury and pathways that regulate immune function. Further, there are strong indications of increased susceptibility to viral infections from exposure to air pollution. It is also stated that lung injuries, including the life- threatening acute respiratory distress syndrome and respiratory failure, as well as acute coronary syndrome, arrhythmia, myocarditis, and heart failure, were shown to be clinically dominant, leading to critical complications. Recent studies in China, the USA, as well as Europe indicate that patients with cardiovascular risk factors or established cardiovascular disease and other comorbid conditions are predisposed to myocardial injury. From the available information, it thus follows that air pollution induced inflammation leads to greater vulnerability and less resiliency, and the pre-conditions increase the host vulnerability. Air pollution causes adverse events through myocardial infarction and stroke, and it is an additional factor capable of increasing blood pressure, while 2 O.A. No.181/2025(CZ) with Bhopal Citizen's Forum through its Convenor Mr. Surendra Tiwari Vs. State of Madhya Pradesh & Ors.
O.A. No.192/2025(CZ) Rashid Noor Khan Vs. State of Madhya Pradesh & Ors.
there is emerging evidence for a link with type 2 diabetes and a possible contribution to obesity and enhanced insulin resistance. Bronchopulmonary and cardiovascular pre-conditions, including hypertension, diabetes, coronary artery disease, cardiomyopathy, asthma, COPD, and acute lower respiratory illness, all negatively influenced by air pollution, lead to a substantially higher mortality risk.
7. On the mechanism of how PM2.5 can aggravate the respiratory disease, Prof. Thomas Munzel of Gutenberg University, Germany, said "When people inhale polluted air, the very small polluting particles, the PM2.5, migrate from the lungs to the blood and blood vessels, causing inflammation and severe oxidative stress, which is an imbalance between free radicals and oxidants in the body that normally repair damage to cells. This causes damage to the inner lining of arteries, the endothelium, and leads to the narrowing and stiffening of the arteries. Extending this analogy to Indian conditions, it is possible to infer that deaths attributable to pollution in India may not be less than 15%.
(Extracted from O.A. No.240/2020, order dated 09.11.2020)"
3. The matter was taken up on 18.02.2026 and the Respondents/Bhopal Municipal Corporation were directed to submit the action plan.
4. Learned Counsel for the Respondent/Bhopal Municipal Corporation has argued that within its statutory and functional mandate, the Health and Environment Department of BMC comprising the Health Department, Corporation Hospitals, Veterinary Section, Garden Department, and Lake Conservation Cell has been consistently undertaking measures aimed at maintaining urban sanitation, scientific waste collection and disposal, vector control, and ecological upkeep. These measures, though indirect in nature, contribute to the overall environmental health and assist in mitigating certain localized factors contributing to air pollution, such as road dust, open waste burning, and unscientific waste handling. The present report, therefore, delineates the actions undertaken by BMC within its defined domain, including utilization of allocated resources 3 O.A. No.181/2025(CZ) with Bhopal Citizen's Forum through its Convenor Mr. Surendra Tiwari Vs. State of Madhya Pradesh & Ors.
O.A. No.192/2025(CZ) Rashid Noor Khan Vs. State of Madhya Pradesh & Ors.
and implementation of ground-level interventions, in furtherance of the broader objective of environmental protection and in faithful compliance with the aforesaid directions, the Bhopal Municipal Corporation has undertaken a series of targeted measures aligned with the objectives of the National Clean Air Programme (NCAP), aimed at controlling and reducing particulate matter levels and addressing key sources of pollution within its jurisdiction. The present report specifically places on record the details of funds allocated under the NCAP framework. The BMC has received financial assistance under the NCAP for implementation of city-specific action plans, focusing on critical sectors such as road dust management, mechanized sweeping, water sprinkling, waste management, and other mitigation measures. In this regard, relevant records pertaining to allocation of funds, sanctioned works, and issuance of work orders for execution of identified activities have been filed. The Corporation has ensured that the utilization of funds is directed towards tangible, on-ground interventions in a time-bound manner and the guidelines issued by the Central Pollution Control Board (CPCB) and other competent authorities. The work orders issued reflect a structured approach towards addressing pollution hotspots and strengthening urban air quality management systems.
5. Submissions of the learned Counsel for the CPCB are that the Continuous Ambient Air Quality Monitoring Stations (C.A.A.Q.M.S.) network in Bhopal consists of 03 stations being operated by Madhya Pradesh Pollution Control Board (M.P.P.C.B.), located at (i) Idgah Hills
(ii) Paryavaran Parisar & (iii) T.T. Nagar, Bhopal. These stations are equipped with state of art reference-grade systems, delivering continuous and near real-time data. These systems constitute the core of the national air quality regulatory framework and operate on 4 O.A. No.181/2025(CZ) with Bhopal Citizen's Forum through its Convenor Mr. Surendra Tiwari Vs. State of Madhya Pradesh & Ors.
O.A. No.192/2025(CZ) Rashid Noor Khan Vs. State of Madhya Pradesh & Ors.
scientifically validated and internationally recognized measurement principles. These are subject to quality assurance and quality control protocols. These monitors operate in an automated manner inside the unmanned, specifically designed C.A.A.Q.M. stations and generate continuous reliable data of 7 pollutants using pollutant specific monitor/analyser. The pollutant specific instruments operate with state of art technology (Methods of measurements) that ensure high precision and stability across seasons and locations. Their methods of measurements are operated as prescribed under National Ambient Air Quality Standards-2009 and gazette notification of N.A.A.Q.S.-2009 published on 16.11.2009 by M.o.E.F. & C.C., vide G.S.R. 826(E) under section 6 and section 25 of the Environment (Protection) Act, 1986 (29 of 1986) and based on ambient concentration of air pollutants and their likely Health impacts, there are six A.Q.I. categories defined under National Air -Quality Index (N.A.Q.I.) namely, Good (A.Q.I.: 050), Satisfactory (A.Q.I.: 51-100), Moderate (A.Q.I.:101-200), Poor (A.Q.I.:201 - 300), Very Poor (A.Q.I.: 301-400) and Severe (A.Q.I.:401-
500). The National Air Quality Index (NAQI) was developed by CPCB through the Indian Institute of Technology Kanpur (IITK) in the year 2015, under the guidance of an Expert Group comprising medical professionals (AIIMS Delhi, MAMC Delhi, SRMCRI Chennai), air quality experts (NEERI, IMD), academia (IIT, Delhi), NGOS and SPCBs. The analysis of A.Q.I. of Bhopal during the year 2025 reveals that number of days in good, satisfactory, moderate, poor, very poor and severe AQI categories are 61, 96, 179, 28, 01 and 0 respectively and various other organizations, global air quality platforms, and private entities also disseminate A.Q.I. They fetch information from government and Non Government sources, including those using monitoring techniques 5 O.A. No.181/2025(CZ) with Bhopal Citizen's Forum through its Convenor Mr. Surendra Tiwari Vs. State of Madhya Pradesh & Ors.
O.A. No.192/2025(CZ) Rashid Noor Khan Vs. State of Madhya Pradesh & Ors.
other than those prescribed under N.A.A.Q.S. (National Ambient Air Quality Standards), 2009. These may include non regulatory grade instruments such as low cost sensors, which have calibration and data quality limitations. Further, the A.Q.I. calculation methodologies adopted by agencies other than the C.P.C.B. may have applied breakpoint concentrations that differ from those used in the N.A.Q..I, and the calculated A.Q.I. may not be the same as the N.A.Q.I. The N.A.Q.I. reported by the C.P.C.B. is the official A.Q.I. for public dissemination in India, and all other A.Q.I.s may not be based on Indian regulations/guidelines/ conditions and are not officially recognized for regulatory or reporting purposes in the country. The real time data from Continuous Ambient Air Quality Monitoring Stations (C.A.A.Q.M.S.) is used for calculating A.Q.I. in near real time. These stations are operated following the standard protocol as per the C.P.C.B. guidelines for measurement of Ambient Air Pollutants Volume II: Real Time Sampling & Analysis (National Ambient Air Quality Series/NAAQMS/37/2012-
13). The complete N.A.Q.I. reporting and public dissemination procedure is near real-time and automated without human intervention. N.A.Q.I. is disseminated at the CPCB website https://airquality.cpcb.gov.in/AQI_India/ and also through a mobile application called SAMEER (available on Android and iOS). Health statements for A.Q.I. It is also stated that that air pollution is one of the factors respiratory ailments and associated diseases. Health is impacted by several factors, including food habits, occupational habits, socioeconomic status, medical history, immunity, heredity, etc., of the individuals apart from the environment.
6 O.A. No.181/2025(CZ) with Bhopal Citizen's Forum through its Convenor Mr. Surendra Tiwari Vs. State of Madhya Pradesh & Ors.
O.A. No.192/2025(CZ) Rashid Noor Khan Vs. State of Madhya Pradesh & Ors.
6. Submissions of the learned Counsel for the Applicant are that the previous order with regard to the Graded Response Action Plan has not been complied with.
7. In response to the above contention, learned Counsel for the State PCB Ms. Parul Bhadoria has submitted that the department concerned has been communicated to take further actions and once the customized Graded Response Action Plan (GRAP) for the State of Madhya Pradesh is fianlized, the same shall be effectively executed and implemented in the airshed areas of non-attainment cities through the respective city level committees constituted for this purpose.
8. It is further argued that:
(i) The CAAQMS stations were operating smoothly and conducting continuous air quality monitoring.
(ii) Monitoring results indicated that the average Air Quality Index (AQI) by the 03 CAAQMS was in the Moderate category.
(iii) Data from the CAAQMS stations is being transmitted to the servers of the ERC, MPPCB, Bhopal, and the Central Pollution Control Board, New Delhi. The data is also displayed on public display boards at various locations in the city.
9. It is further argued that multiple health effects on humans have been observed from the resulting air pollution, ranging from skin and eye irritation to severe neurological, cardiovascular and respiratory diseases. Prolonged exposure to elevated pollution level also increases the mortality rates. There are adverse effects on economy, human health increasing the death rate.
10. Respondents are required to take actions to control the air quality within the parameter by following certain suggestions which have been enumerated as follows:-
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O.A. No.181/2025(CZ) with Bhopal Citizen's Forum through its Convenor Mr. Surendra Tiwari Vs. State of Madhya Pradesh & Ors.
O.A. No.192/2025(CZ) Rashid Noor Khan Vs. State of Madhya Pradesh & Ors.
"A. 100 Days Winter (November to January) Action Plan To improve the air quality i. IEC activity (open waste burning/ biomass burning/ crop residue burning) ii. Enforce solid waste collection and impose fine/challan home burning activity.
Ban on burning of wood/ coal in hotels/restaurants/dabba/open Bhatti/ tandoor iv. Ban on Alav/bonfire and introduce LPG/electric heaters υ. Construction of pit in garden and produce compost vi. Convert agriculture waste into biochar or compost vii. C & D activity: inspection, challan, collection, green net viii. Headline no. for burning/C&D activity ix. Strict checking of PUC of waste collecting/commercial vehicles X. Checking of fitness certificate of vehicles xi. Promoting electric rickshaw and bicycles xii. Heavy vehicle restrictions.
xiii. Free left turns at traffic intersection. xiv. Campaign to inspect four Wheelers and commercial vehicles for emission.
XU. Special drives for maintenance and increase green cover xvi. Mechanical road sweeping xvii. Water sprinkling xviii. Fogging with water sprays xix. Water jetting machine for cleaning off road medians and footpath XX. Fountains: maintenance and development xxi. Paving of roads/building of roads xxii. Increase pedestrian infrastructure/cycle track xxiii. Action to relocate all illegal brick kilns xxiv. Constitution Monitoring Committee for daily monitoring of activity B. Controlling Biomass and Garbage Burning:
i. Eliminating the use of bio-fuels in cooking specifically in commercial establishments like - hotels, restaurants, marriage gardens with the wedding seasons ahead.
ii. Alternate biomass disposal method.
iii. Use of App to monitor the complaints of open waste burning. iv. Ban on burning of wood/coal specially in winters for allow.8
O.A. No.181/2025(CZ) with Bhopal Citizen's Forum through its Convenor Mr. Surendra Tiwari Vs. State of Madhya Pradesh & Ors.
O.A. No.192/2025(CZ) Rashid Noor Khan Vs. State of Madhya Pradesh & Ors.
C. Controlling Vehicular Emissions i. Heavy Vehicle Restrictions: Limiting heavy vehicle entry during peak times in the city limit.
ii. Planning to introduce Emission Control Zones-Designate low-emission zones (LEZ) in areas with high traffic congestion and commercial establishments.
iii. Establishment of vehicle check stations to enforce compliance with Bharat Stage VI (BS-VI) emission norms.
iv. Regular PUC checks in the city, and special drives to check PUC of commercial vehicles entering the city.
D. Construction Dust and C&D Waste Management i. Enforce strict dust control measures at construction sites during winter, requiring builders to cover materials and apply water regularly to suppress dust.
ii. Instruction issued to all the construction agencies for following the "Guidelines on Dust Mitigation Measures in Handling Construction Material And C&D waste."
iii. Diwali Deep Clean Drive is already operational in the city collecting C&D waste.
iv. Use of app for collection of C&D waste from different parts of the city. E. Ban on firecrackers use F. Increasing Green Infrastructure i. Special drive for plantation in the open spaces of the city ii. Increasing green cover in roadside areas to trap airborne dust iii. Increase vertical gardens along flyover and busy streets,
11. The representative of the Municipal Corporation and members of the Joint Committee participated in the proceedings. The representative of the Joint Committee highlighted the various sources causing air pollution in the city and suggested to adopt measures in advance to control the same.
12. We further reiterate that the BMC and the various stakeholder departments to start preparing action plan right now so that necessary action may be undertaken well before the crucial period start to control 9 O.A. No.181/2025(CZ) with Bhopal Citizen's Forum through its Convenor Mr. Surendra Tiwari Vs. State of Madhya Pradesh & Ors.
O.A. No.192/2025(CZ) Rashid Noor Khan Vs. State of Madhya Pradesh & Ors.
air pollution. Action Taken Report be filed before the Tribunal before the next date of hearing.
List it on 20th August, 2026.
Sheo Kumar Singh, JM Sudhir Kumar Chaturvedi, EM 20th May, 2026, Original Application No.181/2025(CZ) With Original Application No.192/2025(CZ) (I.A.No.31/2026) AK 10 O.A. No.181/2025(CZ) with Bhopal Citizen's Forum through its Convenor Mr. Surendra Tiwari Vs. State of Madhya Pradesh & Ors.
O.A. No.192/2025(CZ) Rashid Noor Khan Vs. State of Madhya Pradesh & Ors.