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A. It is submitted that the industry is a small-scale red category industry and has shares of CETP @ 300 KLD.
B. The industry was earlier granted varied Consent to Operate under the Water (Prevention & Control of Pollution) Act, 1974 vide no. CTOW/Varied/LDH4/2022/19608226 dated 12.09.2022 and under the Air (Prevention & Control of Pollution) Act, 1981 vide no. CTOA/Renewal/LDH4/2021/16512614 dated 23.11.2021, which were valid up to 30.06.2023 for discharge of Trade effluent @ 295.0 KLD and domestic effluent @ 5.0 KLD into the dedicated conveyance system leading to CETP of capacity 40 MLD Focal Point Module and for production of RFD/WASHING/POLYSTER DYEING @ 2 Metric Tonnes/Day.
C. The industry was earlier given personal hearing before the Chief Environmental Engineer, Ludhiana on 22.08.2023 u/s 33-A of the Water (Prevention & Control of Pollution) Act, 1974 as amended in 1988 and u/s 31- A of the Air (Prevention & Control of Pollution) Act, 1981 as amended in 1987 and wherein it was decided that: - 1. The industry shall pay Environmental Compensation amounting to Rs. One Lac for discharging its untreated effluent through unauthorized means. 2. The industry shall submit the bank guarantee of Rs. One Lac within one week as an assurance to comply with provisions of Water Act, 1974 in true letter and spirit in future at all times. 3. Environmental Engineer, Regional Office-4, Ludhiana shall visit the site of the industry and verify the contentions made by the industry and process the consents application on merit within 07 days.
D. Accordingly, the site of the industry visited by the AEE this office on 12.12.2023 and it was observed that the industry was in operation during the visit. The industry has not made arrangement for recovery & reuse of cooling water and steam condensate. The industry has installed one thermopac of capacity @ 1500 U attached with twin cyclone as APCD and adequate stack height. Agro Waste was being used as fuel in its thermopac during the visit. During the visit, leakage of emission was observed from the APCD fan. Further, the APCD dust has choked the outlet of the cyclone thus failing its operation.
E. It is added here that industry has neither deposited Environmental Compensation amounting to Rs. One Lac for discharging its untreated effluent through unauthorized means nor bank guarantee of Rs. One Lac as an assurance to comply with provisions of Water Act, 1974. The industry is not complying with provisions of Water (Prevention & Control of Pollution) Act, 1974 and hearing decisions dated 22.08.2023.
F. Accordingly, direction u/s 33-A of the Water Act, 1974 and u/s 31-A of the Air Act, 1981 was confirmed against for disconnection of electric supply. The electric connection of the industry was disconnected by the PSPCL authority and industry has submitted TDCO no. 271/33 dated 27.03.2024.
G. Thereafter the industry was obtained consent to operate under Water (Prevention & Control of Pollution) Act, 1974 vide no. CTOW/Fresh/LDH4/2024/25483751 dated 09.05.2024, which was valid upto 08.11.2024 and Air (Prevention & Control of Pollution) Act, 1981 vide no. CTOA/Fresh/LDH4/2024/25468131 dated 09.05.2024, which was valid upto 08.11.2024 and electric connection of the industry had also been temporarily restored for six months i.e. upto 08.11.2024.
H. The industry auto-generated consent to operate under the Water Act, 1974 and The Air Act, 1981 dated 08.11.2024 valid upto 08.11.2026 each, without getting its electric connection restored permanently.
I. The industry was visited by officer of the Board on 24.03.2025 and emission samples were collected from the common stack of APCD connected with rice husk based boiler of capacity 5TPH and Thermopack of capacity 1500 U and as per the analysis report received from Zonal Lab., Ludhiana dated 01.04.2025, concentration of SPM is found to be 193 mg/Nm3. And whereas, now, the industry was visited by officer of the Board on 23.09.2025 and emission samples were collected from the common stack of APCD connected with rice husk-based boiler of capacity 5TPH and Thermopack of capacity 1500 U (not in operation) and as per the analysis report received from Zonal Lab., Ludhiana dated 10.10.2025, concentration of SPM is found to be 178 mg/Nm3. And whereas, the industry has been operating without obtaining regular consent to operate under the Water Act,1974 and the Air Act,1981 of the Board and without getting its electric connection restored permanently.
J. Accordingly, show cause notice for revocation/cancellation of “auto-renewal” of consent to operate under the Water (Prevention & Control of Pollution) Act, 1974 and Air (Prevention & Control of Pollution) Act, 1981 was issued to the industry with an opportunity of personal hearing before Senior Environmental Engineer, Zonal Office-2, Ludhiana on 14.11.2025, wherein it was decided as under: 1. Auto Renewed Consent to Operate under the Water Act, 1974 and Air Act, 1981 generated by the industry be revoked / cancelled. 2. The industry shall apply for fresh consent to operate under the Water Act, 1974 & Air Act, 1981, within 07 days. 3. The Environmental Engineer, Punjab Pollution Control Board, Regional Office-4, Ludhiana shall submit compliance of the direction’s u/s 33-A of the Water Act, 1974 and u/s 31-A of the Air Act, 1981 issued vide Board's letter no. 928 & 930 dated 09.02.2024, respectively.
K. Accordingly, the auto renewal of consent to operate under the Water Act, 1974 has been revoked by the Board vide letter no. 6619-21 dated 21.11.2025.
L. Now the industry has applied for consent to operate under the Water Act, 1974 and Air Act, 1981 through OCMMS RFD/WASHING/POLYSTER DYEING @ 2 MTD and for domestic effluent @ 5.0 KLD and trade effluent @ 295 KLD into the sewer of CETP and for boiler 5 TPH and Thermopack @ 1500 Kcal/Hour.
M. The industry has deposited CTO fee of amounting to Rs. 21600/- vide R.no. 448499409 dated 24.10.2025 under the Water Act, 1974 and Rs. 21600/- vide R.no. 15410185 dated 24.10.2025 under the Air Act, 1981, which is adequate upto 08.11.2027 against the gross fixed assets of Rs. 873.25 Lacs and plant & machinery of Rs. 417.24 Lacs as per CA Certificate dated 15.10.2025.
N. Now the industry was visited by the officer of this office on 22.12.2025 and it was observed as under: -
1. The industry was not in operation due to disconnection of electric supply. The industry has submitted TDCO no. 271/184 dated 26.09.2025.
2. The industry has obtained shares of 300 KLD for CETP 40 MLD.
3. The industry has also installed 02 printing section which one is in operation and remaining print section is not operational.
4. The industry has installed a digital flow meter at the source of water supply and final outlet leading to CETP. The industry has installed SCADA system for connectivity with CETP server.
5. The SCADA data could not be confirmed from the online module as the website has shifted to a new domain and the modulator ID and Password for PPCB officials has not yet been generated.
6. The details of production capacity viz a viz machinery installed/ liquor ratio/No.s of Bath/No.s of Lots and other details for wastewater generation by the industry is attached as PDF file.
7. The maximum expected discharge from the industry from all three scenarios as mentioned above is 289.8 KLD which is within consented capacity and the industry has shares capacity of 300 KLD.
8. The industry has not made arrangement for recovery & reuse of cooling water and steam condensate.
9. The industry has installed one thermopac of capacity @ 1500 U attached with twin cyclone as APCD and adequate stack height. Agro Waste was being used as fuel in its thermopac during the visit.
10. The industry has installed one boiler of capacity @ 05 TPH attached with multi cyclone as APCD and adequate stack height.
11. Recently, sample of stack emission was collected on 23.09.2025 by the officer of the Board from port hole of common stack of boiler 05 TPH and thermopac of 1500 U. As per analysis results the concentration of the SPM was found to be 178 mg/Nm3 against the prescribed standards of 250 mg/Nm3, which is in permissible limit as per new fuel policy.
12. The industry has installed one DG set of capacity 380 KVA equipped with canopy and adequate stack height.
13. The industry has submitted letter from PDA regarding their Demat account opened and transfer of the shares.
14. The industry has submitted layout plan regarding the pipeline, source of water abstraction and disposal of effluent into PDA.
15. It is pertinent to mention here that the industry has submitted Bank Guarantee amounting to Rs. 1.0 Lac vide no. 50130IGL0000624 with validity upto 14.02.2026. Further, the industry has also deposited Environmental Compensation Rs. 1.0 lac vide R.no. 5543/58 dated 23.01.2024.
It is pertinent to mention here that legal opinion was taken from the Senior Law Officer of the Board for processing consent applications of the CETP member industries in-spite of the standing directions issued u/s 33-A of Water (Prevention & Control of Pollution) Act, 1974 to the CETP-50 MLD to stop its discharge into Buddha Nallah. The Senior Law officer has given his opinion that:
"Acting upon the directions of the Central Pollution Control Board, the Punjab Pollution Control Board has issued directions dated 25.09.2024 to the CETPs of 50 MLD, 40 MLD and 15 MLD at Ludhiana not to discharge the treated effluent into Buddha Nallah and to comply with the discharge standards and disposal condition mentioned in the Environmental Clearance.
2) The CETPs of 50 MLD, 40 MLD and 15 MLD have filed separate appeals against the directions dated 25.09.2024 of the Board before the Hon'ble National Green Tribunal i.e. Appeal No. 40 of 2024, Appeal No.41 of 2024 and Appeal No. 48 of 2024 respectively. After consideration of the appeals, the Hon'ble Tribunal has passed the orders to the effect that no coercive action shall be taken against the CETPs subject to the compliance of environmental norms.
3) It is relevant to mention here that the industrial units (Textile and Dyeing) are the members of the CETPs of 50 MLD, 40 MLD and 15 MLD and the Board is granting consents to operate to the member units under the Water (Prevention and Control of Pollution) Act, 1974 and the Air (Prevention and Control of Pollution) Act, 1981 with certain conditions as mentioned therein. If some major violation is observed by the Board in the functioning of the industrial unit, the Board is empowered to issue any directions in wring to the defaulting industrial unit by invoking the provisions of Section 33-A of the Water (Prevention and Control of Pollution) Act, 1974 and Section 31-A of the Air (Prevention and Control of Pollution) Act, 1981 and such unit has to comply with the directions of the Board. It is significant to mention here that the directions issued by the Board under the above said Sections / Statutes are not permanent in nature and have to be reviewed on making compliance by the defaulter. As and when the directions given by the Board are complied with by the defaulting industrial unit, the Board has to review the directions given for closure or otherwise to the industrial unit by issuing the modified directions.
4) I am of the opinion that if the industrial units (to whom directions for closure had been issued by the Board) have make compliance of the directions of the Board, the Board has to review the directions by issuing modified directions for the operation of the industrial units with suitable conditions.
5) I am of the further opinion that the Board cannot withheld the consents to operate of the industrial units (Textile and Dyeing) under the Water (Prevention and Control of Pollution) Act, 1974 and the Air (Prevention and Control of Pollution) Act, 1981 due to the reason that the CETPs have been issued directions not to discharge the effluent into Buddha Nallah and to meet the prescribed standards. It is pertinent to mention here that the Board has been restrained for taking any coercive action against the CETPs (50 MLD, 40 MLD and 15 MLD) by the Hon'ble National Green Tribunal which means that the Board cannot issue directions for the closure of the said CETPs. In the given circumstances, the Board in my opinion cannot directly or indirectly restrain the operation of the industrial units. The Board in my opinion may grant conditional consents to operate to the industrial units under the Water (Prevention and Control of Pollution) Act, 1974 and the Air (Prevention and Control of Pollution) Act, 1981 if the industrial units are making compliance of the conditions of the consents granted by the Board. While granting the consents, the Board may impose a condition that the grant of consents shall be subject to the decision of the Hon'ble National Green Tribunal in the appeal cases filed by the CETPs of 50 MLD, 40MLD and 15 MLD or in the Original Applications filed against the said CETPs. The Board may also impose other suitable conditions."
As such the Senior Law officer opined that the consent application of the industry can be processed in spite of the standing directions to the CETP. The above said legal opinion has been approved by the Competent Authority of the Board.
In view of above, it is recommended as under: -
1. Electric supply of the industry may be restored for temporary period upto six months.
2. Fresh Consent to operate under the Water Act, 1974 may be granted to the industry upto six months with special conditions as under:-
1. This consent to operate is subjected to the decisions of Hon'ble National Green Tribunal in the appeal case no. 41 of 2024 filed by the CETP of 40 MLD.
2. The industry shall continue to comply with all the Board directions already issued to it under the relevant act.
3. The industry shall not generate/discharge trade & domestic effluent more than its allotted shares capacity.
4. The industry shall discharge the whole of its consented effluent into a dedicated sewer line leading to CETP for final treatment.
5. The industry shall not make any new connection/undisclosed connection for the discharge of effluent either into the public sewer or PDA conveyor system.
6. The industry should either take measures to control its inlet parameters by good practices and selection of good chemicals for processing or shall operate and maintain its existing effluent treatment plant (ETP), regularly and efficiently, so as to achieve the inlet effluent standards of CETP as per DPR.
7. The industry shall make the necessary arrangements to achieve the effluent standards as per the inlet-designed parameters of the CETP.
8. There shall be no any other physical expansion of the unit either with the installation of new machinery without valid permissions of the Board.
9. The industry shall stop discharging its effluent in case due to any reason the CETP is not operational or the dedicated conveyance system is overflowing.
10. The industry shall maintain the record of flow meter installed at source and at the outlet leading to CETP.
11. The industry shall carry out third-party audit from any reputed institute to access the actual discharge capacity of the dyeing unit in compliance with the proceedings issued by the Board vide letter no. 4387 dated 09.08.2023 to the CETP 40 MLD.
12. The industry shall obtain necessary permissions for the abstraction of ground water from PWRDA/CGWA.
13. The industry shall maintain the record of untreated effluent at the outlet in such manner that it shall not affect the working of CETP.
Competency to Grant Consent: SEE
Competency to restore electric connection: Hon’ble Chairman
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