| File Note: |
Subject: Proceedings of the personal hearing given before the Hon’ble Chairperson of the Board on 16.03.2026 w.r.t. Show cause notice for refusal of renewal of Consents to Operate under the Water (Prevention & Control of Pollution) Act, 1974 and notice to issue directions u/s 33-A of the Water (Prevention & Control of Pollution) Act, 1974 and u/s 31-A of the Air (Prevention & Control of Pollution) Act, 1981 - M/s Pure and Cure Healthcare Private Limited, Village: Sundran, Mubarakpur, Derabassi. Distt. SAS Nagar.
The following were present: -
On behalf of Punjab Pollution Control Board
1. Er. Lavneet Kumar, Member Secretary
2. Er. Gursharan Dass Garg, Senior Environmental Engineer (ZP-I)
3. Er. Mohit Bisht, Environmental Engineer (ZP-1)
On behalf of the Project Proponent
1. Sh. Vinayak Bhatt, VP Operations
2. Sh. Sanjay Rai, VP HR
3. Sh. Mukesh Singh, Manager
At the outset, Senior Environmental Engineer, (ZP-1) brought out that: -
The industry had earlier applied for obtaining renewal ‘consent to operate’ under the Water (Prevention & Control of Pollution) Act, 1974 and Air (Prevention & Control of Pollution) Act, 1981. Accordingly, due to violation observed during the visit, the industry was issued notice for was issued notice for refusal of ‘consent to operate’ under the Water (Prevention & Control of Pollution) Act), 1974 and Air (Prevention & Control of Pollution) Act, 1981, alongwith an opportunity of personal hearing before the Chairman of the Board on 20.11.2023 in the said hearing, it was decided as under:
1. The ‘consent to operate’ applied under the Water (Prevention & Control of Pollution) Act, 1974 and Air (Prevention & Control of Pollution) Act, 1981.
2. PSPCL authorities be directed u/s 33-A of the Water (Prevention & Control of Pollution) Act, 1974 to disconnect the electric supply available to the industry with immediate effect.
3. Two bank guarantees amounting to Rs. 5 lakhs each submitted by the industry be encashed.
4. Explanation of PSPCL authorities be called as to why they have failed to comply with the directions issued by the Board u/s 33-A of the Water (Prevention & Control of Pollution) Act, 1974 and electric connection had not been disconnected after 16.10.2023.
The application of the industry for obtaining ‘Consent to Operate’ under the Water (Prevention & Control of Pollution) Act, 1974 and under the Air (Prevention & Control of Pollution) Act, 1981, was refused on 20.11.2023.
The industry was issued following directions u/s 33-A of the Water (Prevention & Control of Pollution) Act, 1974 vide PPCB letter no. 8857 dated 20.11.2023 following directions:
1. The industry shall take all necessary steps to close down its operations and stop forthwith discharging any effluents/ wastewater into sewer/ into storm water drain/ inland surface water/ onto land for stagnation/ irrigation or through any mode.
2. The industry shall stop forthwith discharging any effluent/ emissions from its industrial premises or through any mode.
3. The industry will immediately stop its manufacturing activities and will not restart the same unless all necessary water and air pollution control measures are taken and it obtains valid consents to operate of the Board as required under the provisions of the Water (Prevention & Control of Pollution) Act 1974.
4. The Punjab State Power Corporation Ltd. authorities shall be directed to disconnect the supply of electricity available to the industry.
In compliance to decision no. 4 above, PSPCL vide disconnection order dated 22.11.2023 had disconnected the electric supply available to the industry.
The industry had submitted request letters dated 21.11.2023 and 23.11.2023 to Hon’ble Chairman of the Board, requesting to release the electric connection of the unit. Taking into consideration the compliances made by the industry and considering the request, the Competent Authority of the Board decided to temporarily restoration the electric connection for a period of 03 months vide Board’s letter no. 9132—33 dated 30.11.2023, i.e. upto 29.02.2024.
The electric connection was temporarily restored for six months period till date and lastly the same has been restored upto 31.12.2025 vide letter no. 3977-78 dated 27.08.2025.
The industry had been accorded CTOs under the Water Act, 1974 and Air Act, 1981 for short term periods.
The industry was granted consent to operate vide no. CTOW/Varied/SAS/2025/29147171 dated 27.08.2025 under the provisions of Water (Prevention & Control of Pollution) Act, 1974 and vide no. CTOA/Varied/SAS/2025/29146906 dated 27.08.2025 which was valid till 31.12.2025, for production for Cefepime Hydrochloride @9 mt/anm, Cefpirome Sulphate @4.8 mt/anm, CefpodoximeProxetil @100 mt/anm, CefditorenPivoxeil @6.48 mt/anm, Cefprozil @6.24 mt/anm, Cefotaxime Acid @45 mt/anm, Ceftriaxone Sodium @30 mt/anm, CeftadizimePentahydrate @2.4 mt/anm, Ceftiofur @1.2 mt/anm, Cefonicid @1.2 mt/anm, Cefuroxime Axetil Crystalline @200 mt/anm, Cefuroxime Axetil Amorphous @350 mt/anm, Cefuroxime Acid for Sterile @36 mt/anm,Cefexime @500 mt/anm, Cefdinir @12 mt/anm, Ampicilline Sodium @31.2 mt/anm, Amoxycilline Sodium @120MT/Anm, Cloxacilline Sodium @1.5MT/Anm, Amoxy/Clav (Sterile) @1.5MT/Anm, Oxacilline Sodium (Sterile) @2.4 MT/Anm, Flucloxacillin sodium (Sterile) @1.2MT/Anm, Salbactum Sodium @7.2MT/Anm, Ceftriaxone Disodium @30MT/Anm, Cefotaxime Sodium @45MT/Anm, Cefepime HCL (Strile) @ 5.28MT/Anm, Cefuroxime Sodium (Sterile) @24MT/Anm, AmpicillineTrihydrate @198.9MT/Anm, AmoxycillineTrihydrate @ 330MT/Anm, Cloxacilline Sodium @252MT/Anm, Dicloxacilline Sodium @120MT/Anm, Flucloxacilline Sodium @26.4MT/Anm, Oxacilline Sodium @2.4MT/Anm, subject to certain conditions as mentioned therein. subject to certain conditions as mentioned therein.
The industry has now applied for obtaining renewal of consent to operate under the provisions of Water (Prevention & Control of Pollution) Act, 1974 and Air (Prevention & Control of Pollution) Act, 1981 for production for various Bulk Drugs/ APIs, alongwith requisite documents.
The industry has also submitted written request letter dated 13.10.2025 for restoration of permanent electricity connection as the industry is complying with the directions issued u/s 33-A of the Water (Prevention & control of Pollution) Act, 1974.
The project proponent has already obtained Environmental Clearance vide no. EC22B058PB186332 dated 25.04.2022 for manufacturing of 32 API products.
The industry was visited by the officer of the Board on 03.10.2025 and noted as under:
1. The industry as well as the ETP (followed by RO), MEE & ATFD, STP were found in operation.
2. The OCEMS installed on the RO Permeate line was operational.
3. The industry is reusing RO permeate as cooling tower makeup and boiler feed in its premise and RO reject is being sent to MEE for treatment along with HTDS.
4. The industry is using treated domestic effluent after STP onto land for plantation developed within its premises.
5. During visit the office collected effluent samples from the RO Permeate/ Feed/ Reject lines and MEE Feed/ Condensate lines. The analysis results of RO Permeate showed concentration of pH as 9.1, TSS<5 mg/l, TDS 2446 mg/l, COD 120 mg/l, BOD 20 mg/l.
6. The industry has installed OCEMS at RO permeate line and the same was in operation and reading were shown as BOD @ 18 mg/ltr, COD 78 mg/ltr, pH 8.54, TSS 40 mg/ltr.
7. The industry has installed 2 no. boiler of capacity 6 TPH (rice husk fired having Trema cyclone followed by bag filter house as APCD) and 3 TPH (biomass bricket fired having mechanical dust collector followed by bag filter house as APCD). The industry has provided common stack with these boilers and emission sample was collected from the stack and the results are within the prescribed limit of the Board.
8. Incinerator installed by the industry was not in operation.
9. The industry has installed one SRP unit and has installed VOC and TOC analyzer with the same.
10. The RO brought out in its report that the Board has issued directions vide dated 20.11.2023 to disconnect the electricity connection. Thereafter, the industry was visited by the officers of the Board on 07.12.2023, 06.06.2024, 04.11.2024, 10.12.2024, 16.04.2025, 19.06.2025, 03.10.2025 was found complying.
It was noted that as per the analysis results the RO Permeate exhibited a pH of 9.1, TSS < 5 mg/l, TDS 2446 mg/l, COD 120 mg/l, and BOD 20 mg/l. These results clearly show non-compliance, as the pH exceeds the permissible limit of 8.5 and the TDS is significantly above the general standard of 2100 mg/l.
It was noted that samples from the final outlet (RO Permeate line) were not collected & analyzed for the full set of parameters mandated under GSR 541(E) dated 06.08.2021. Only pH, TSS, TDS, COD, and BOD had been analyzed, whereas several critical prescribed parameters—such as Ammoniacal Nitrogen, Oil & Grease, Bioassay Test, Phosphates (as P), Sulphides (as S), Phenolic Compounds, Zinc, Copper, Total Chromium, Hexavalent Chromium (Cr⁶⁺), Cyanide (as HCN), Arsenic, Mercury, Lead, etc.—were not collected or analyzed. As a result, the adequacy of the treatment system could not be assessed.
The industry was thereafter visited as part of quarterly monitoring protocol by team of officers headed by Er. Gursharan Das Garg, SEE comprising of Er. Mohit Bisht, EE. Er. Subham Puri, AEE and Dr. Rupinder Kaur, JSO on 17.12.2025. During visit, was observed as under:
1. The industry was in operation and engaged in manufacturing of APIs using various chemicals as raw materials.
2. The industry has installed 02 no. tubewells near the main entrance and has installed flow meters with both the tubewells. The industry is maintaining record regarding ground water abstraction.
3. The industry has installed MEE of capacity 130 KLD followed by ATFD of capacity 1300 Kg/hour, for treatment of HTDS being generated from its process. On arrival of the team, the MEE was not in operation and was made operational to collect samples from the same.
4. The industry has installed an ETP followed by RO system for treatment of LTDS and MEE condensate being generated from the unit. The ETP as well as the RO plant installed by the industry was in operation during the visit.
5. The industry has installed OCEMS at RO condensate line and the same was in operation & online and the readings were noted as BOD @ 18 mg/ltr, COD 80 mg/ltr, pH 8.82, TSS 41 mg/ltr.
6. The industry is reusing RO permeate as makeup water in the cooling tower & as boiler feed and the RO reject is sent to MEE for treatment along with HTDS.
7. The industry has installed as kid mounted type STP of 50 KLD capacity for treated of domestic effluent being generated from the unit. STP installed by the industry was in operation during the visit. The industry is using treated domestic effluent after STP onto land for plantation developed within its premises.
8. During visit, the effluent samples were collected from outlet of STP and sent to Head Office Lab Patiala for analysis. The analysis results are as under:
S. No. Test Parameter Outlet of STP Prescribed Standards
1) pH 7.8 5.5 – 9.0
2) TSS (mg/l) 31 200
3) TDS (mg/l) 1802 -
4) BOD (mg/l) 25 100
5) COD (mg/l) 127 -
6) O&G (mg/l) 5.5 10
The analysis results reveals that the industry is achieving the prescribed discharged standards for such effluent.
9. During visit, the effluent samples were collected from the MEE Feed, MEE Concentrate and MEE Condensate to analyze the treatment efficiency and sent to Head Office Lab Patiala for analysis. The analysis results are as under:
Sr. No Test Parameters Units Results
MEE Feed MEE condensate MEE Concentrate
1 pH value at 25o C - 7.2 9.8 6
2 Total Suspended Solids (TSS) mg/l 940 8 159
3 Total Dissolved Solids (TDS) mg/l 65219 23138 109770
4 Chemical Oxygen Demand (COD) mg/l 38300 11600 24120
5 Bio-Chemical Oxygen Demand (BOD) mg/l 15000 4060 9160
The analysis results reveals that Concentration of total solids in the effluent at the inlet of MEE i.e. MEE feed and concentrate of MEE has been analyzed as 66159 mg/l (6.6 %) and 109929 mg/l (10.99 %), respectively which indicates that the MEE was not being operated properly and effectively as the same has been designed to get concentration of total solids in the range of 25-30% and reflects improper operation and/or inadequate evaporation performance.
10. During visit, the effluent samples were collected from the RO permeate line to analyze the treatment efficiency and sent to Head Office Lab Patiala for analysis. The analysis results are as under:
Sr. No. Test Parameters Units Results Prescribed Standards as per as per GSR 541(E) dated 06.08.2021
Inlet of ETP RO Permeate
1. pH value at 25o C - 9 9.4 6.0 – 8.5
2. Total Suspended Solids (TSS) mg/l 105 <5 100
3. Total Dissolved Solids (TDS) mg/l 2690 468 -
4. Chemical Oxygen Demand (COD) mg/l 8800 744 250
5. Bio-Chemical Oxygen Demand (BOD) mg/l 1700 110 30
6. Oil & Grease mg/l 17.4 BDL 10
7. Zinc mg/l <0.1 <0.1 5
8. Copper mg/l <0.1 <0.1 3
9. Total Chromium mg/l <0.1 <0.1 2
10. Phenolic Compound mg/l 4.5 BDL 1
11. Cynide mg/l BDL BDL 0.1
12. Sulphide mg/l 3.6 BDL 2
13. Ammonical Nitrogen mg/l 16 13.6 100
14. Phosphate mg/l 8.7 BDL 5
15. Hexa Chromium mg/l BDL BDL 0.1
16. Bio-Assay - - Zero% survival of fish in 100% effluent after 96 hours 90% survival of fish in 100% effluent after 96 hours
The analysis results reveals that the concentration of pH, BOD, COD and Bio-Assay are beyond the permissible limits. Notably, in the effluent standards collected by Regional Office on 03.10.2025, the RO Permeate exhibited a pH of 9.1 and TDS 2446 mg/l, which also exceeded the permissible limit of 8.5 and the TDS was significantly above the general standard of 2100 mg/l.
11. The industry has installed OCEMS on the RO permeate line and the same was found operational & online. The reading on the same was noted as pH 8.82, TSS 41 mg/l, BOD 18 mg/l and COD 80 mg/l.
12. During visit, it was observed that the industry has installed 2 no. boiler of capacity 6 TPH (rice husk fired having Trema cyclone followed by bag filter house as APCD) and 3 TPH (biomass briquette fired having mechanical dust collector followed by bag filter house as APCD). The industry has provided common stack with these boilers and emission sample was collected from the stack and the results are as under:
Port Hole on Common stack after APCD attached with Boiler furnace of capacity 6 TPH & 3 TPH (When only 6 TPH boiler was in operation)
Particulate Matter – 135 mg/Nm3 (prescribed standard – 250 mg/Nm3)
The results are within the prescribed limit of the Board.
13. The industry has installed OCEMS only said stack and the same was found operational & online and the reading of SPM on the same was noted as 50 mg/Nm3.
14. The incinerator installed by the industry was not in operation During the conduct of visit.
15. The industry has installed one SRP in its premises. The industry has installed VOC and TOC analyzer with the same.
It is clear from the above report that the industry was found violating the provisions of the Water (Prevention & control of Pollution) Act, 1974 as not achieving the prescribed standards.
The competent authority has decided to refuse the applications filed by the industry for renewal of Consent to Operate under the Water (Prevention & Control of Pollution) Act, 1974; as well as take stringent action against the institute by issuing directions u/s 33-A of the Water (Prevention & Control of Pollution) Act, 1974, after affording an opportunity of show cause-cum-personal hearing to it.
The matter has been viewed seriously by the competent authority of the Board and decided to take stringent action against the project proponent by way of issuing show cause notice for refusal of renewal of Consents to Operate under the Water (Prevention & Control of Pollution) Act, 1974 and notice to issue directions u/s 33-A of the Water (Prevention & Control of Pollution) Act, 1974 and u/s 31-A of the Air (Prevention & Control of Pollution) Act, 1981.
Accordingly, notice to issue show cause notice for refusal of renewal of Consents to Operate under the Water (Prevention & Control of Pollution) Act, 1974 and notice to issue directions u/s 33-A of the Water (Prevention & Control of Pollution) Act, 1974 and u/s 31-A of the Air (Prevention & Control of Pollution) Act, 1981 issued vide Board’s letter no. 7971 dated 19.02.2026 alongwith another opportunity to appear in person before the Chairperson of the Board at Punjab Pollution Control Board, Vatavaran Bhawan, Nabha Road, Patiala on 10.03.2026 at 11:00 AM, with the following proposed directions:
i. The industry shall take all necessary steps to close down its operations and stop forthwith discharging any effluents/ wastewater into sewer/ into storm water drain/ inland surface water/ onto land for stagnation/ irrigation or through any mode.
ii. The industry shall stop forthwith discharging any effluent from its industrial premises or through any mode.
iii. The industry will immediately stop its manufacturing activities and will not restart the same unless all necessary water pollution control measures are taken.
iv. The Punjab State Power Corporation Ltd. authorities shall be directed to disconnect the supply of electricity available to the industry.
v. That an environment compensation of suitable amount be imposed on the industry.
vi. That the machinery & DG Sets (if any) installed by the industry be sealed.
The hearing could not be conducted on 10.03.2026, due to administrative reasons and it was decided to give another opportunity of personal hearing to the industry before the Hon’ble Chairperson on 16.03.2026.
Meanwhile, the industry was visited by team of officers headed by Dr. Rajeev Kumar Gupta, SEE (ZP-II), comprising of Er. Kamal Singla, EE (ZP-II), Er. Sachin Singla, AEE (RO, Patiala), and Ms. Rupinder Kaur, JSO, (Air Lab) on 20.02.2026; in compliance to the orders of the Competent Authority of the Board regarding monitoring protocol for 17 categories of highly polluting industries. During visit, it was observed as under:
1. The industry was in operation operating at a capacity of 10 % as per the production record submitted by the industry and only batch of proxetil was being produced using chemicals as raw materials. Further, the industry vide email dated 06.03.2026 has informed about the irregular operations of the plant due to low market demand.
2. The industry has installed 02 no. tubewells near the main entrance and has installed flow meters with both the tubewells. However, the 2nd tubewell has been abandoned and new tubewell is being dug out at the back of Admn. Block. The industry is maintaining record regarding ground water abstraction. The meter reading at first borewell was 75900 KL.
3. The industry has installed peiozometer within its premises for monitoring of groundwater, however, sample of groundwater could not be collected due to non-availability of the pump.
4. The industry has installed MEE of capacity 130 KLD followed by ATFD of capacity 1300 Kg/hour, for treatment of HTDS being generated from its process. On arrival of the team, the MEE, ATFD as well as incinerator were not in operation due to which samples from MEE could not be collected.
5. The industry has installed an ETP followed by RO system for treatment of LTDS and MEE condensate being generated from the unit. The ETP as well as the RO plant were in operation and samples from inlet of ETP, Aeration tank 1 & 2 and RO permeate were collected and sent to HO lab for analysis.
6. The industry has installed OCEMS at RO permeate line which was being changed in order to install a new one and a mail in this regard was sent by the industry to the Regional Office on 12/03/2026. The readings on new OCEMS after installation by the industry were noted as BOD @ 6.6 mg/ltr, COD 26.4 mg/ltr, pH 6.87 TSS 13.2 mg/ltr. Further, the record of RO permeate maintained by the industry was checked for the last two months and it was observed that conc. of various parameters i.e. pH (remains below 8), TSS (remains around 10 mg/l), COD (remains around 90 mg/l) and BOD (remains around 27 mg/l).
7. The industry is reusing RO permeate as makeup water in the cooling tower & as boiler feed and the RO reject is sent to MEE for treatment along with HTDS.
8. The industry has installed as skid mounted type STP of 50 KLD capacity for treated of domestic effluent being generated from the unit. STP was in operation and treated domestic effluent after STP was being discharged onto land for plantation developed within its premises. The wastewater sample from outlet of STP was collected and sent to Head Office Lab Patiala for analysis. The analysis results are awaited.
9. The industry has installed 2 no. boiler of capacity 6 TPH (rice husk fired having Trema cyclone followed by bag filter house as APCD) and 3 TPH (biomass briquette fired having mechanical dust collector followed by bag filter house as APCD). At the time of visit, the boiler of capacity 6 TPH was in operation. The industry has provided common stack with these boilers and emission sample was collected from the stacks and the analysis results are awaited.
10. The industry is in process of installing the new OCEMS with the stack earlier got damaged due to heavy rain in Jan 2026. The communication in this regard was made to the Regional Office at SAS Nagar by the industry.
11. The industry is disposing off the boiler ash to M/s Manjinder Singh NKO, Vill. Lelhli, PO Dapper, Tehsil Derabassi, District SAS Nagar.
12. The industry has installed one SRP in its premises and the same is equipped with VOC and TOC analyzer.
13. In addition to above, the industry has obtained the EC vide no. EC22B058PV186332 dated 25/04/2022 for enhancement in capacity of 7 existing APIs, out of 32 APIs from various chemicals as raw material. The industry has also obtained the varied consents to operate under the Water (Prevention & Control of Pollution) Act, 1974 and Air (Prevention & Control of Pollution) Act, 1981. The compliance of EC conditions w.r.t green belt developed by the industry was categorically checked and it was observed that the industry has developed plantation in an area of 6 acres (24276 sqm) with 4500 saplings, which is more than the required area of 22460 sqm with 3542 plants saplings imposed in the environmental clearance granted to it by MoEF&CC. The industry has submitted a copy of site plan showing area.
14. Further, the industry is required to spent Rs. 2.0 Cr on CER activities as per the condition imposed in the EC. However, the industry has spent more than Rs. 2.0 Cr within a span of 4 years.
15. The industry has provided sludge drying beds as well as sludge tray drier with 93 trays to dry the sludge generated from its process. The industry has also submitted the record of hazardous waste lifted to the TSDF.
16. The overall housekeeping of the industry was found good.
17. The visiting team seen that the industry is being operated at very low capacity i.e. approx. capacity of about 10% of the installed capacity due to market constraint/ financial health of the industry. However, the team seen that the industry has already installed adequate & appropriate pollution control equipments and the same were found in operation. The team also seen that the industry is also complying with the provisions of the Water Act, 1974 and Air Act, 1981 as well as HWM Rules, 2016 in large.
The representatives of the project proponent attended the hearing but had not submitted any written reply. It was noted that although earlier inspections had indicated non-compliance with prescribed discharge standards, the latest inspection dated 20.02.2026 reflects substantial improvement in the operational status of pollution control systems. It was noted that the ETP followed by RO system and STP were found in operation, and the industry is reusing treated effluent within its premises. The OCEMS readings and records maintained by the industry indicate that key parameters are largely within prescribed limits. Further, the industry has installed requisite pollution control infrastructure including MEE, ATFD, SRP, APCDs, and has demonstrated compliance with Environmental Clearance conditions, and the overall housekeeping and environmental management practices were observed to be satisfactory during the latest inspection. The industry has taken corrective measures and is presently complying with the provisions of environmental laws.
After hearing the representatives of the project proponent and officers of the Board and considering the material aspects of the case, the Chairperson of the Board decided as under:
1. The industry shall ensure proper calibration and continuous operation of the Online Continuous Effluent Monitoring System (OCEMS) installed at the RO permeate line, and shall maintain proper records thereof. The OCEMS shall be installed on a continuous flow permeate line, and no valve/sluice or bypass arrangement shall be provided on the said line, so as to eliminate any possibility of tampering or diversion of flow.
2. The industry shall install CCTV cameras focusing on the OCEMS and critical discharge points, and integrate the same with the Board’s server within a period of 15 days, to ensure real-time monitoring.
3. The application of the industry for grant of Consent to Operate under the Water (Prevention & Control of Pollution) Act, 1974 be granted for a period of 01 year.
4. The industry shall ensure that all pollution control systems, including ETP, RO, MEE, ATFD and APCDs, are operated efficiently at all times, and no untreated/partially treated effluent is discharged under any circumstances.
If approved, the proceedings of the personal hearing as per above be conveyed to the project proponent as well as RO for compliance |
