Disposed

Ravinder Raghu Yadav v. M/S Kajaria Ceramics Limited Chief Executive Officer/ Authorized Representative

NGT12 Sept 2025Original Application No. 272/2024

Case brief

AI extract

What is this about?

This Original Application challenged air and water pollution caused by M/s Kajaria Ceramics Limited's use of mustard husk and ground water extraction in Rajasthan. A joint committee report confirmed violations in ambient air quality, untreated sewage usage, waste dumping, and fugitive dust. The Tribunal directed the plant to rectify deficiencies including wastewater treatment, waste storage, dust

What did the court decide?

Directions issued to respondents to stop using untreated domestic sewage for horticulture, upgrade APCDs for husk-fired generators, cover conveyor belts, seal ball mills, properly store sludge and ash

Ravinder Raghu Yadav vs M/S Kajaria Ceramics Limited… — Environment and Pollution | NGT (2025)

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Item No. 01

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BEFORE THE NATIONAL GREEN TRIBUNAL CENTRAL ZONE BENCH, BHOPAL (Through Video Conferencing)

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Original Application No.272/2024(CZ)

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IN THE MATTER OF:

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1. Ravinder/Raghu Yadav , Aged 28 years, S/o Sh. Hariram, R/o Modhupor of Village Teh. Kotkasim, District Khairthal Tijara [Rajasthan], 2. Lokesh Kumar, Aged 32 years, S/o Sh. Satyaveer Singh, R/o Village Gailpur Teh. Tijara, District Khairthal Tijara [Rajasthan] Applicant(s)

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Versus

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1.	M/s Kajaria Ceramics Limited,
	J1/B1 (Extension), Mohan
	Cooperative Industrial Estate
	(Opposite Badarpur Thermal Power Station), Mathura Road, New Delhi- 110044 through its Chief Executive Officer/authorized representative	Respondent No.01
2.	M/s Kajaria Ceramics Ltd. Having its manufacturing plant at Village Gailpur tehsil Tijara district Khairthal-Tijara [Rajasthan] through its plant head/authorized representative,	Respondent No.02
3.	Bhiwadi Integrated Development Authority,Bhiwadi Tehsil Tijara District Alwar Now Distt. Khairthal- Tijara [Rajasthan] representative through its secretary/ authorized	Respondent No.03
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O A	No.272/2024(CZ)	Ravindra/Raghu Yadav & Ors.

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4. State of Rajasthan, Through its Chief Secretary, Secretariat, Jaipur-302005, Respondent No.04

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5. Rajasthan State Pollution Control Board, Jaipur (Rajasthan), Through its Regional Officer at G.O.1, Phase-2, RIICO Industrial Area, Bhiwadi tehsil Tijara district Khairhtal-Tijara, [Rajasthan]. Respondent No.5

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6. Rajasthan Industrial Investment Corporation Ltd., Head Office Jaipur (Rajasthan), Through its Local office at Bhiwadi tehsil Tijara district Khairhtal-Tijara [Rajasthan], Respondent No.6

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7. District Collector, Khaithal-Tijara, District Khairthal - Tijara (Rajasthan),

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Respondent No.7

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COUNSELS FOR APPLICANT(S):

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Mr. Raghu Yadav, in person

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COUNSELS FOR RESPONDENT(S):

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Mr. Shubham Soni, Adv. with Ms. Sarah Sharma, Adv. for R-1 & 2 Mr. Shoeb H. Khan, Adv. For State Mr. Om Shankar Shrivastava, Adv. with Mr. Kartikey Bhatia, Adv. For RIICO Mr. Rohit Sharma, Adv. For RSPCB

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CORAM:

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HON’BLE MR. JUSTICE SHEO KUMAR SINGH, JUDICIAL MEMBER HON'BLE MR. SUDHIR KUMAR CHATURVEDI, EXPERT MEMBER

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Date of completion of hearing and reserving of order : 09.09.2025 Date of uploading of order on website : 12.09.2025

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O A No.272/2024(CZ)

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Ravindra/Raghu Yadav & Ors.

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JUDGMENT

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Issue raised in this application is water pollution by way of discharge of polluted water into the water bodies and use and burning of farm husk causing air pollution violating the Water (Prevention and Control of Pollution) Act, 1974 and Air (Prevention and Control of Pollution) Act, 1981 and thus this petition. The contention of the applicant is that the respondent No 1 is corporate office and respondent No 2 is its plant of who are engaged in the manufacture of ceramic tiles-earthenware of various kinds and qualities respondent No 2 is using mustard husk as fuel in its plant for manufacturing the tiles and has not put in place any measure to keep the pollution under control whilst the husk being burnt by them as fuel emanates huge smoke which is polluter of highest degree and, thus, ambient air in vast area remains full of such smoke and pollutes the atmosphere to unbearable extent and even breathing has become difficult. Due to such pollution being caused by respondents, several people in the area have been caught by lungs related diseases, asthma, hearing loss, dehydration and heart diseases, sore throat, coughing, lung inflammation and permanent lung damage and their life span has shortened. Further, even clothes worn by residents become deeply dark having been covered by particles spread in the air due to such pollution being caused by respondents and they become unwearable within hours.

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The matter was taken up by this Tribunal and vide order dated 24.12.2024 issued notice to the respondents and further constituted a joint committee consisting the representative of the District Collector, Central Pollution

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O A No.272/2024(CZ)

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Ravindra/Raghu Yadav & Ors.

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Control Board and State Pollution Control Board to submit the factual and action taken report.

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In response to the above reply on behalf of the respondents have been filed. The members of the committee visited the site and submitted the report.

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Heard the Learned Counsel for the parties and perused the record.

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The main contention of the Learned Counsel for the applicant are that use mustard husk as fuel in its plant for manufacturing the tiles and this use of husk is polluting the air causing health problem to the local residing within the periphery of the unit. It is further argued that the respondents No 1 & 2 have submersible motor pumps in more than 100 bore wells wherefrom they exploit underground water round the clock in illegally and unlawfully to use manufacturing of tiles. Due to this, water table in the area is depletingdecreasing at excessively fast speed, as a result where, even agricultural lands of people is heading towards barren which is capable of rendering the agrarian community income less completely destroying the and texture, structure, porosity, fertility and WHC etc. their agricultural lands. That even after use of above water extracted in above illegal manner, such polluted, dirty water containing several hazardous chemicals and water, air pollutants, is released by respondents directly in the bore wells illegally dug up within their premise without routing it through sewerage treatment plant. As result, TDS and fluoride in the left over underground water has increased manifolds and the people are constrained to drink such polluted water most injurious to their health and has hazardous effect in long term.

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O A No.272/2024(CZ)

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Ravindra/Raghu Yadav & Ors.

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In compliance of the order the members of the committee visited the site and

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submitted the report as follows :

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“ Manufacturing process of Ceramic/Vitrified Tiles

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M/s Kajaria Ceramics Limited is located at 19 Km Stone BhiwadiAlwar Road, Village-Gailpur, Tehsil-Tijara, Distt-Kairthal-Tijara, Rajasthan in the NCR region. The unit is involved in the manufacturing of ceramic/vitrified tiles and operates at total area of land 435109.32 Sqm. The manufacturing process of ceramic/vitrified tiles at M/s Kajaria Ceramics Limited, Gailpur includes several key steps: In body preparation raw materials (Ball Clay, Feldspar, Quartz, Talc etc.) are transported, weighed, and mixed with recycled water in a ball mill to create a fine mixture called "slip," which is then stored in agitator tanks. The slip is atomized in a spray dryer with hot air (500–600°C) to form spherical powder particles with 5-6% moisture. This powder is compacted into molds using hydraulic presses, forming the tiles under high pressure (500 to 5000 tons). The pressed tiles are dried in a horizontal dryer using hot air at around 180°C, employing natural gas and heat recovery systems to enhance energy efficiency. After drying, tiles receive a glaze spray. Inkjet printing is used for additional decoration, allowing customization. The decorated tiles are dried to remove additional moisture (1-2%) using recycled heat from the kiln. Tiles are fired at temperatures up to 1200°C in roller hearth kilns, solidifying their structure and making them water-resistant. Postfiring, tiles are polished and squared using abrasives and treated water from the effluent treatment plant. Fired

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O A No.272/2024(CZ)

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Ravindra/Raghu Yadav & Ors.

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tiles undergo quality inspection, sorting, and are then packed in cartons ready for delivery.

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Observation of the Joint Committee

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Based on the deliberations held during the meeting of the Joint Committee, subsequent site inspections of the unit under question, sampling and analysis of Source Emission, Ambient Air Quality Monitoring, Fugitive Emissions, Ambient Noise Level Monitoring Ground Water, Waste Water and documents made available to the Committee, the following observations are made on the ToR:

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A. General observations

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M/s Kajaria Ceramics Limited was inspected by the Joint Committee during 31thJanuary to 2nd February, 2025 as per Hon’ble NGT order dated 20.12.2024 to verify the allegations and obtain factual status of violations of Water Act, 1974 and Air Act, 1981.

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RSPCB issued Consent to Operate to M/s Kajaria Ceramics Limited for production/manufacturing of Ceramic Tiles under the provisions of Section 25/26 of the Water (Prevention & Control of Pollution) Act, 1974 and under Section 21 of the Air (Prevention & Control of Pollution) Act, 1981. Details of CTO are tabulated

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below:

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S. No	Particular	Quantity	Issue date	Validity from	Remarks
1	Unit-I : Ceramic Glaze Tile	14.82 Million Sqm/ Annum	23.04.2024	01.05.2023 to 30.04.2033	Annexure5
2	Unit-II : Ceramic Glaze	16.50 Million Sqm/Ann	u 24.11.2022	25.05.2018 to 30.04.2028	Annexure6

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O A No.272/2024(CZ)

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Ravindra/Raghu Yadav & Ors.

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Tile
3 Unit-III : Vitrified	25,000 Sqm/ Day	24.11.2022	27.11.2019 to	Annexure7
CeramicTile			31.08.2028

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The unit has obtained authorization for generation, collection,

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disposal, storage, transport of hazardous waste under Hazardous and Other Waste (Management and Trans boundary Movement) Rules, 2016 for used or spent oil (Category-5.1) from RSPCB for all three units and generated HW sold to registered recyclers. Details of Hazardous waste authorization are tabulated below:

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S. No	Unit	Type of HW	Category	Quant ity	Issue date	Validity from	Remarks
1	^Unit-I	Used Spent Oil	Schedule Code-5.1	16 KLA	24.12.2020	01.12.2020 to 31.11.2025	Annexure-8
2	^Unit-II			20 KLA	20.12.2024	01.01.2025 to 31.12.2030	Annexure-9
3	^Unit-III			10 KL	A08.09.2021	01.09.2021 to 31.08.2026	Annexure-10

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• RSPCB issued Consent to Operate to M/s Kajaria Ceramics Limited for 100 KLD STP based on MBBR technology for treatment of domestic waste water generated from all the three units of plant. Flow meters are installed at inlet and outlet of the STP. For the month of December, 2024 average waste water received at inlet 59 KLD and average treated waste water after disinfection taken out at outlet 53 KLD for reusing in the horticulture. Treated waste water storage tank of 80 KLD is also installed in the premises. During visit it was observed and informed that total 44 nos. of residential flats provided in the premises and generated domestic waste water

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O A No.272/2024(CZ)

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is being collected in open underground tank without treatment and use in the horticulture without treatment, no record of domestic waste water generation (From residential flats) provided during visit.

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• The raw water requirement of all the three units of the plant is fulfilled through ground water (bore wells). Plant has total 06 number of bore wells, 02 nos. for each unit (01 for industrial purpose and 01 for domestic and other purposes). The unit has obtained NOC from Central Ground Water Authority under overexploited category for groundwater abstraction permission of 374 m3/day for unit-I, 600 m3/day for unit-II and 395 m3/day for unit-III with validity up to 18.03.2025, 27.02.2027 and 23.09.2026, respectively.

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• As details provided by the unit official, total average water consumption for the period from January, 2024 to December, 2024 for unit-I varies from 315 m3/day to 353 m3/day, for unit-II varies from 503 m3/day to 581 m3/day and for unit-III varies from 363 m3/day to 384 m3/day. Total average water consumption for the period from January, 2024 to December, 2024 is within the permission limit for groundwater abstraction as per NOC issued by Central Ground Water Authority. During visit tube well no 2 of unit2 was under maintenance.

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Total average water consumption for the month of January,

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2025 for unit-I is 342 m3/day, for unit-II is 577 m3/day and for unit-III is 371 m3/day.

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• As informed, extracted water from bore wells no 1 from all units is being used in the manufacturing process i.e. body preparation, spray dryer, glaze line, glaze preparation, and press cooling tower. Recycled water from spray dryer, glaze line, glaze preparation, and press cooling tower processes along with water collected from body preparation is reused after the treatment mainly sludge removal in the ball mill charging process and maintaining Zero Liquid Discharge (ZLD) throughout the manufacturing process in all the three units. Water extracted from the bore wells no 2 of all units is being used for domestic purposes and treated in the STP, treated domestic waste water is being used in the horticulture purposes in the premises.

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• Plant has installed ETP for treatment of industrial effluent generated from Unit-I, (comprising of 12 nos. settling tanks) and common ETP for Unit-II & Unit-III (comprising of 14 Nos. of settling tank), respectively with 80 m3 capacity of each settling tank and 01 No. of 160 m3 capacity treated water collection tank for all three units. PAC are using as flocculent in the settling tank and generated sludge is passed through filter press and solid sludge is stored in the sludge storage area inside the premises. ETP are equipped with flow meter at outlet & PTZ cameras at each unit and connected with RSPCB server. Treated effluent from ETP is reused in the manufacturing process of all the units.

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Sludge generated from the settling tank of all three units is

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transferred at sludge drying area, as informed by the plant official, sludge after drying is being reused as raw material in the process.

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Total sludge received and consumed for the period of April, 2024 to December, 2024 for Unit-I are 5347.03 MT & 5242.00 MT, for UnitII are 1303.01 MT & 1368.95 MT and for Unit-III are 2550 MT & 2799.66 MT, respectively. During visit sludge was stored openly on ground near the settling tank area of unit-1 & 3 and housekeeping of the sludge storage area needs improvement. Broken tiles are generated during polishing/finishing are stored openly in the premises. Part of broken tiles is reused in the manufacturing process after grinding and rest is sold locally.

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• Applicant claimed that industrial solid waste is dumped on government land at 04 locations. Joint Committee alongwith applicant visited all the 04 locations near by the plant area i.e. village Naugaon, Jagamalhedi, Chavandi & Pawti, where industrial solid waste (sludge & broken tiles) was found dump openly. Patwari of respective areas i.e. Smt. Sangeeta Yadav and Sh. Pankaj Kumar verified all 4 locations and as informed by the Sh. Ashwani K Pawar ADM, Bhiwadi that industrial solid waste dump on private at 03 locations i.e. Naugaon, Jagamalhedi and Chavandi and at Pawti industrial solid waste dumped on Government land. Sub divisional Officer issued a latter on 03.03.2025 to TehsildarTapukara and instructed for taking action against M/s Kajaria Ceramics Limited.

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• There is a dedicated area for dumping of non-hazardous waste provided by the district administration at Rampur Mundana, Bhiwadi where M/s Kajaria Ceramics Ltd. also sending nonhazardous waste like broken tiles. As details provided by the

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plant official, total 130 dumpers carrying waste sent for disposal during the period of April 2023 to November 2024, however quantity of waste is not revealed.

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• The ash generated of mustard husk during combustion in the hot air generator are temperately stored at outside of the spray drier area of all units and finally stored near ash storage area near sledge settling pit of unit-3. During visit the ash stored openly near settling pit of unit-3 and as informed ash are sold locally to brick manufacturers. No sludge generation and sells record are maintained.

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As alleged in the letter petition, discharge of industrial effluent

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in to the bore wells was not observed by the Joint Committee.

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• The unit has developed rain water harvesting structures inside and outside the plant premises to collect the rain water for recharging of ground water. Plant has obtained NOC from the respective villages of Sarpanch’s for installation of water recharging pits, total 44 nos. of water recharging pits installed at outside the plant premises at various villages and total 42 nos. of recharging pits installed inside the plant premises.

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• To control fugitive dust emissions, conveying of raw material like Mustard husk, Ball Clay, Feldspar, Marble powder, Talc etc. is done through covered vehicles to prevent spillage and dust generation. Separate raw material storage area provided for all raw materials for all three units and stored under covered shed on RCC

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floor which is further transferred through conveyor belts. All the internal and connecting roads to the highway were made of concrete pavement to reduce the fugitive dust emission during transportation. Total 02 nos. Small dust sweeping machines were provided for cleaning of internal roads to reduce the fugitive dust emission during vehicle movement.

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• As informed by the plant official issued a purchase orders dated 28.10.2019 of unit-1 and on 28.10.2019 of unit-2 for procuring total 02 nos. of grinder with bag house as air pollution control device and 50 MT capacity 01 no. storage silo each. Grinder commissioned of unit-1 on January, 2020 and on March , 2020 of unit-2 for grinding of broken tiles and reused as raw material in the tile making process without obtaining prior permission from the RSPCB.

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During visit both grinders are in operational and conveyor belt

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are not covered and cause fugitive dust emission. Fugitive dust emission monitoring was done at both grinder area for Suspended Particulate Matter (SPM) parameter and result found to be at grinding section of unit-I is 878 µg/m3 and at grinding section of unit-III is 912 µg/m3 which is above the prescribed standard is 600 µg/m3.

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Plant is using PNG as fuel in most of the process area and

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installed PNG supply line in the premises. As informed by plant official, about 1,15,000 m3PNG is using as a fuel in the various processes.

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As informed by plant officials, PNG was used as fuel throughout

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the manufacturing process including spray drier, however plant has converted the machineries of spray drier for using farm residue (mustard husk) as heat generation and modified the air pollution control devices i.e. cyclone, wet scrubber etc to reduce the source air emission from all 07 nos. spray drier, 02 nos. in unit-I, 03 nos. in unit-II and 02 nos. in unit-III. During visit plant officials provided details regarding the commissioning of Hot Air Generator (HAG), details of drier, model and commissioning date is tabulated below:

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S. No.	Description	Commissionin date
1	Unit-II Wall Tile Spray Drier (HAG with 02 nos. ofCyclone)Model:ATM 110	15.12.2022
2	Unit-III GVT Spray Drier (HAG with 02 nos. of Cyclone)Model:ATE 110	28.12.2022
3	Unit-II Floor Tile Spray Drier (HAG with 02 nos. ofCyclone)Model:ATI 110	10.01.2023
4	Unit-I Wall Tile Spray Drier (HAG with 02 nos. ofCyclone)Model:ATM 120	25.01.2023
5	Unit-I Floor Tile Spray Drier (HAG with 02 nos. of Cyclone) Model : ATI 140	15.02.2023
6	Unit-III GVT Spray Drier (HAG with 02 nos. ofCyclone)Model:ATE065	21.04.2023
7	Unit-II Spray Drier (HAG with 02 nos. of Cyclone) Model:ATI065	14.10.2024

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Purchase order of wet scrubber modification kit for all 07 nos. of

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spray drier were provided for unit-I, unit-II & unit-III, the operation started after modification and informed to RSPCB, RO Bhiwadi on 11.12.2023.

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During visit it was observed that fugitive dust emission was

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observed in the ball mill area of all units due to not covered most of the material transfer conveyor belt and also not installed suction

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hood on most of the ball mill rollers of all units & connected with APCD through suction duct to reduce the fugitive dust emission.

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• Plant has installed 05 nos. of DG sets of 1000 KVA capacity each for unit-I, 04 nos. of DG sets of 1010 KVA capacity each for unit-II and 03 nos. of DG sets (capacity -1000 KVA-02 Nos. & 2000 KVA-01 No.) for unit-III in the premises as alternate source of power. Unit has installed dual fuel kit of all the DG sets except 01 no. 1000 KVA capacity DG set of unit-01,Which is dismantled stage and not in operation since long time.

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• The hazardous waste display board installed at main gate but no requisites information’s mentioned in the board. The used/spent oil generated as hazardous waste from DG sets and machineries etc. is being stored in the hazardous waste storage site in the premises. During visit it was observed that the hazardous waste site was not as per the guidelines of Hazardous & Other Waste Rules, 2016.

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• During visit it was observed that the records of Hazardous waste generated from all three units are not being maintained on regular basis, however during the time of disposal/sold to authorized recycler common Form-3 of all three units is generated without proper requisite information as per the Hazardous & Other Waste (M&TM) Rules, 2016. As used oil of quantity 4050 Ltr sold to authorized recycler and Manifest (Form-10) generated on 21.11.2024, however this quantity is not mentioned in the Form-3.

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During visit it was observed that workers were engaged without

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using safety kits i.e. mask, gloves, gumboot, helmet goggles etc. inside premises at material handling and process area.

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During the visit the Committee observed that the unit has

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developed green belt inside as well as the outside of the plant premises, as per information provided by unit officials, out of 435109.32 SQM plant area, greenbelt developed on less than 40 % of total plant area.

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• Joint committee also discussed with Dr. Vinod Vijay, In-Charge Medical Officer, Community Health Centre, Tapukara Distt. Khairthal–Tijara about the concerns regarding health complications and other impacts due to mustard husk use as fuel/tile manufacturing units in the area. As per details provided, various diseases are due to bacterial, viral infections, allergic, smoking, dust and other lifestyle changes etc.

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B. Other observations

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(a). Monitoring of Source Emission : During the visit, out of 07 mustard husk fired hot air generator attached with spray dryer, 01 spray dryer of unit-I was not in operation and 01 spray dryer of unit-II was operational but does not have adequate infrastructural monitoring facility, hence monitoring couldn’t be performed during the visit. Source emission Monitoring was carried out of 05 stacks of mustard husk fired hot air generator attached with spray dryer for Particulate matter and 08 stacks of PNG fired Kiln for PM, SO2 and NOx. Monitored data of source emission is given below:

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S. No.	Stack Attached to	Stack Emiss concentration of PM in mg/Nm3	Air Pollution Control Equipme
1	Unit-I: Husk fired hot generator attached with spray dryer (capacity 26 Ton)	211	Multicyclone wet scrubber
2	Unit-II: Husk fired hot generator attached with spray dryer(capacity 22Ton)	65	Multicyclone wet scrubber
3	Unit-II: Husk fired hot generator attached with spray dryer(capacity 22Ton)	101	Multicyclone wet scrubber
4	Unit-III: Husk fired hot generator attached with spray dryer(capacity 22Ton	71	Multicyclone wet scrubber
5	Unit-III: Husk fired hot generator attached with spray dryer(capacity13Ton)	153	Multicyclone wet scrubber
Pre CTO	scribed Standard as per & CAQM direction No. 62	80 mg/Nm

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On the basis of above monitored source emission data, it has

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been observed that the average concentration of PM was found to be in the range of 65 mg/Nm3 to 211 mg/Nm3 and exceeding the limit at three locations i.e. Unit-I: Husk fired hot air generator attached with spray dryer (capacity 26 Ton), Unit-II: Husk fired hot air generator attached with spray dryer (capacity 22 Ton) & UnitIII: Husk fired hot air generator attached with spray dryer (capacity 13 Ton) and at two locations found within the prescribed limit.

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S. No.	Stack Attached to	Stack conc	entration	Emiss in mg/Nm
		PM	SO2	NOx
1	Unit-II: PNGfiredKiln no.1	19	2.8	252
2	Unit-II: PNG fired Kiln no.2	16	3.8	263
3	Unit-II:PNGfiredKiln no.3	17	2.2	278
4	Unit-II:PNGfiredKiln no.4	20	1.9	202
5	Unit-I:PNGfiredKiln no.1	12	3.6	192
6	Unit-I: PNGfiredKiln no.2	19	5.4	236

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7	Unit-III: PNGfiredKiln no.1	19	4.1	219
8	Unit-III: PNG fired Kiln no.2	16	3.1	227
Pre	scribed Standard as per CTO	80	400	600

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On the basis of above monitored source emission data, it has

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been observed that the average concentration of PM was found to be in the range of 12 mg/Nm3 to 20 mg/Nm3 which is within the prescribed limit, gaseous parameters i.e. SO2 & NOx for all kilns are also within the prescribed limit.

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(b). Monitoring of Ambient Air Quality :

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In order to assess the Ambient Air Quality of the area, during the visit Ambient Air Quality Monitoring for 24 hours was carried out at 03 locations in unit premises and near by area of unit for the prominent air pollutant parameters viz. PM10, SO2, NOx. The ambient air quality monitoring stations were installed at up-wind, down-wind and cross wind directions of the M/s Kajaria Ceramics Limited, Gailpur, KhairthalTijara and monitoring carried out for 24-hour basis during 31st January1st February, 2025. The

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monitored results is as given below:

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S.N	Location	PM10 (µg/m3	SO2 (µg/m3	NO2 (µg/m3 )
1	BVM school, Village Jagamalhedi, (Approx Meters away from Kajaria unit)	283	10.29	19.62
2	Backside of Unit-III (near village Bhokar side),	400	12.37	23.08
3	Truck parking area of Kajaria Ceramics Limited (nearGailpur village side),	M 317	16.28	23.72
NA	AQ Standard (Ambient	100	80	80

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quality monitoring carried out for 24 Hr basis)

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On the basis of above monitored Ambient Air quality data, it has been observed that the average concentration of PM10 (24 Hr basis) was found to be in the range of 283 μg/m3 to 400 μg/m3 which is exceeding the limit at all three locations i.e. BVM school, Backside of Unit-III near village Bhokar side and Truck parking area of M/s Kajaria Ceramics Limited near Gailpur village side. The concentration of primary gaseous pollutants i.e. NO2 and SO2 were found to be within the limit at all the monitored locations. High concentration of the dust pollutants in ambient air is found due to cold air in evening time as compared to the day time due to slow dispersion of pollutants and heavy vehicle movement in night time. (c). Monitoring of Fugitive Emissions:

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In order to assess the fugitive dust emission at work place i.e. grinder section area, during the visit fugitive emission monitoring for 04 hours was carried out at 02 locations inside the premises of the plant for the Suspended Particulate Matter (SPM) parameter.

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Monitored data of fugitive dust emission is given below:

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S. No	Location	Suspended Particulate Matter (µg/m3	Standard EP Act for emission grinding (µg/m3)	s as guideli fugit un
1	Grinding sectionofUnit-I	878	600
2	Grinding sectionofUnit-II	912	600

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On the basis of above monitored fugitive dust emission data, it has

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been observed that the average concentration of SPM was found to

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be in the range of 878 µg/m3 to 912 µg/m3 which is exceeding the prescribed limit at both locations.

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(d ) Monitoring of Ambient Noise Level:

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In order to assess the Ambient Noise Level of the area, during the visit Ambient Noise Monitoring during day was carried out at 03 locations in unit premises and near by area of unit. The Ambient Noise level monitored data is given below:

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Sr.	Locations	Ambient Noise Level (dB(A))
No.		Leq. Limit
1.	^{BVM school, Village} Jagamalhedi, (Approx 200 Meters away from Kajariaunit)	41 75
2.	Backside of Unit-III near village Bhokar side	47 75
3.	Truck parking area of M/s Kajaria Ceramics Limited near Gailpur village side	63 75

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On the basis of above monitored Ambient Noise Level data, it has been observed that the average Ambient Noise Level during day time at all three locations are within prescribed standard limits for industrial area.

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(e)Monitoring of Ground Water Quality:

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In order to assess the ground water quality of the area, during the visit ground water samples from the 05 borewells located at various places inside the premises of

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the plant and 02 borewells located outside the plant Khairthal-Tijara area were collected and analysed for various physio-chemical parameters. 01 Borewell of Unit-II was not in operation. Ground water monitored data is given below:

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Analysis result of Ground Water samples

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S No.	Paramete rs				Locations				Standard IS:10500	s as per -2012
		borew ell no. 01 of Unit-I	borew ell no. 02 of Unit-I	borew ell no. 01 of Unit- II	borew ell no. 01 of Unit- III	borew ell no. 02 of Unit- III	borew ell of BVM Schoo l	borewel l of Govt. Sr. Sec. School, village Gailpur	Requirem ent (Acceptabl e limit)	Permissi ble limit in the absence of alternat e source
1.	pH	7.86	8.22	7.91	8.01	7.97	7.8	7.65	6.5-8.5	-
2.	TDS	416.3	447.9	492.8	420.4	404.5	371. 7	776.9	500	2000
3.	COD	10	20	10	20	10	10	30	-	-
4.	Sulphate	44.6	101.6	122.7	55.1	16.6	57.4	155.3	200	400
5.	Total Alkalinit y	355	375	420	360	375	365	490	200	600
6.	Chloride as Cl	18	33	36	31	17	30	104	250	1000
7.	Fluoride	0.2	0.4	0.5	0.1	0.3	0.2	0.6	1	1.5
8.	Total Hardnes s as CaCo3	112	164	114	66	60	154	308	200	600
9.	Phosphat e	BDL	BDL	BDL	BDL	BDL	BDL	BDL	-	-

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All the values in mg/l except pH.

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On the basis of above analysis results of ground water,

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TDS, sulphate, chloride and total hardness are exceeding at 01 location as per acceptable limit but within permissible limit in the absence of alternate source, total alkalinity is exceeding at all locations as per acceptable limit but within permissible limit in the absence of

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alternate source and other parameters are within prescribed limit as per Drinking water specification IS 10500:2012

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(f)Monitoring of Waste Water Quality (STP):

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Unit has installed 100 KLD capacity Sewage treatment plant based on MBBR technology to treat the domestic waste water generated from unit. Treated water is used in the horticulture. Waste water sample was collected from the outlet of STP and analysis results are as given below:

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Analysis result of Waste Water samples

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S. No.	Parameters	Result	Standard as per Consent to Operate letter dated 09.12.2019	Standard as per RSPCB order dated 08.08.2023 in compliance of CPCB direction dated 21.04.2015
1.	pH	7.38	6.5-9.0	6.5-9.0
2.	Total Suspended Solids	191 mg/l	100 mg/l	20 mg/l
3.	Oil & Grease	14.7 mg/l	10 mg/l	10 mg/l
4.	COD	452 mg/l	250 mg/l	50 mg/l
5.	BOD	56 mg/l	30 mg/l	10 mg/l

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On the basis of above analysis results of outlet of STP

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(wastewater) all the parameters (except pH) are exceeding

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the prescribed limit as per State Board Standards

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Action taken by Rajasthan State Pollution Control Board & District Administration on behalf of the Joint Committee report: -

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a) Show Cause Notice for intended revocation /Cancellation of Consent to Operate under Section 25/27 of the Water (Prevention & Control of Pollution) act,1974 & under

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section 21 of the Air (Prevention & Control of Pollution) Act,1981 issued by RSPCB Bhiwadi to M/s Kajaria Ceramics Limited (Unit-I) situated at 19

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k.m. stone, Bhiwadi- Alwar Road Gailpur, Tehsil – tapukara, Distt- Khairthal -Tijara on dated 04.03.2025. at Annexure-37.

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b) Show Cause Notice for intended revocation /Cancellation of Consent to Operate under Section 25/27 of the Water (Prevention & Control of Pollution) act,1974 & under section 21 of the Air (Prevention & Control of Pollution) Act,1981 issued by RSPCB Bhiwadi to M/s Kajaria Ceramics Limited (Unit-II) situated at 19 k.m. stone, Bhiwadi- Alwar Road Gailpur, Tehsil – tapukara, Distt- Khairthal -Tijara on dated 04.03.2025. at Annexure-38.

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c) Show Cause Notice for intended revocation /Cancellation of Consent to Operate under Section 25/27 of the Water (Prevention & Control of Pollution) act,1974 & under section 21 of the Air (Prevention & Control Of Pollution) Act,1981 issued by RSPCB Bhiwadi to M/s Kajaria Ceramics Limited (Unit-III) situated at 19 k.m. stone, Bhiwadi- Alwar Road Gailpur, Tehsil – tapukara, Distt- Khairthal -Tijara on dated 04.03.2025. at Annexure-39.

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d) Sub divisional Officer, Tapukara (Khairthal -Tijara) issued a latter on 03.03.2025 to Tehsildar-Tapukara and instructed for taking action against M/s Kajaria Ceramics Limited for dumping of solid waste on government land.

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The learned counsel for the State PCB has submitted that the members of the committee have also examined the water consumption details by the project proponent and the details have been submitted with as Annexure -16 to Annexure-20 of the report.

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The submission of the Learned Counsel for the Respondent no. 5/ Rajasthan State Pollution Control Board Mr. Rohit Sharma, are that the industry was inspected by the officials of RSPCB on 19.09.2024, and during the verification, it was observed that the industry had installed Cyclones, a Wet 22

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Scrubber, and a Chimney to control air emissions generated from the burning of biomass. The Joint Committee visited the industry from 31.01.2025 to 02.02.2025, and as per its observations, the industry has provided the pollution control measures with spray dryers. Comments were sought from the Medical Officer, CHC, Tapukada, District Khairthal Tijara. The Commission for Air Quality Management in the National Capital Region and Adjoining Areas, vide its direction No. 63 dated 18.05.2022 and amendments in direction No. 65 dated 03.04.2023, has permitted the use of biomass fuels as an alternative option in industries in the NCR, beyond the jurisdiction of the NCT of Delhi. That monitoring of ambient air quality was carried by the Joint Committee three locations, and based on the observed values, a Show out at Cause Notice intending revocation of Consent to Operate was issued to the industry vide letter dated 04.03.2025 for failure to meet the standards and other shortcomings reported by the Joint Committee. A verification of the complaint was conducted on 19.09.2024. During this verification, emissions monitoring was also carried out, and the analyzed results were found to be within the prescribed limits. The Commission for Air Quality Management in the National Capital Region and Adjoining Areas, vide its direction No. 63 dated 18.05.2022 and amendments in direction No. 65 dated 03.04.2023, has permitted the use of biomass fuels as an alternative option in industries in the NCR, beyond the jurisdiction of the NCT of Delhi. During verification dated 19.09.2024, the analyzed results were within the prescribed limits. Comments were sought from the Medical Officer, CHC, Tapukada, District Khairthal Tijara.

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The submission of the Learned Counsel for the RIICO Shri Om Shankar Shrivastava are that the Answering, Respondent / Rajasthan State Industrial Development & Investment Corporations Limited (RIICO) was established on 01.01.1980 after bi-furcation from Rajasthan State Industrial & Mineral Development Corporation (RSIIUDC), A Government enterprise incorporated under the companies Act, 1956 on 28th March 1969. RIICO has pioneered the industrialization of the State of Rajasthan. The role of the answering respondent is limited to the area allotted by the State of Rajasthan for ensuring basic minimum facilities for the lease holders and maintenance of the allotted industrial area. The role of answering respondent is very limited in it's allotted area and have no direct authority to interfere in pollution related issues arises by any such operation of an industry because, RSPCB is the competent authority to allows/ disallows to establish, to operate and have control over the product mix, use of fuel, pollution control arrangement of any industry. However, it is again pertinent to mention here that, the said area where Respondent no-1 & 2 is alleged to be operating is not within the allotted area of RIICO. the technical evaluation, impact assessment and monitoring of compliances, permission and grant of CTE/CTO of any industry as well as suggestive measures to the Government is sole responsibility of Respondent /RSPCB as per Section 17 of the Water (Prevention and Control of Pollution) Act, 1974 and as per section 21 & 22 of the Air (Prevention and Control of Pollution) Act, 1981. The Respondent/State Pollution Control Board play a pivotal role in India's environmental governance framework, acting as regulatory and advisory bodies at the State level. RSPCB is instrumental in ensuring the

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environmental health of their regions by implementing the directives and standards set by the central authority and the specific legislations.

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The submissions of the learned counsel for the Respondent are that Applicant is regularly filing the complaint against the Respondent to unnecessary harass the industry/unit. It is further argued that the Respondent industry has installed the cyclone, wet scrubber and chimney etc. along with spray driers to prevent air pollution and has also installed infrastructure for monitoring. It is also stated that the Respondent has also installed seven biomass spray driers out of which six (6) spray driers are being operated on biomass fuel, whilst one (1) is not being used. As such the air emission of the aforesaid spray dryers was inspected and was found to be in the prescribed standards. It is stated that the biomass is the only fuel authorised by the Commission of Air Quality Management (hereinafter referred to as the "CAQM for the sake of brevity) in the National Capital Region. Additionally, as per the report dated 19.09.2024, during the inspection no disposal of untreated water outside the Respondent industry has been noticed and a sewerage treatment plant has been installed for the treatment of domestic effluents. It is stated that the during the inspection it was also verified through the log book that the aforesaid sewage treatment was cleaned regularly and the treated water is being used for the purposes of gardening. As per the report dated 19.09.2024, it is also crystal clear that six borewells have been installed and are operational in the Respondent industry and flow meters are installed on them and the online monitoring of the same is being maintained through log book by the industry. It is also stated that the Respondent industry has obtained NOC from Central Ground

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Water Authority (CGWA) for its Unit I, Unit II and Unit III. Furthermore, upon a perusal of the report dated 19.09.2024, it is also clearly stated that the solid wasted that is generated during the tile manufacturing process in the Respondent industry is properly dumped into the dumping yard as identified by the RICCO and the records of the aforesaid dumping are being maintained.

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It is further argued that a survey conducted in the Hasanpur, Gailpur area by the Community Health Officer and Female Health Workers working at the Health Centres in Gailpur, and no abnormalities were found in patients like - heart attack, kidney diseases, liver diseases, respiratory diseases, skin related diseases, cancer disease of the village. It is stated that the Medical Officer In-Charge of the Community Health Centre, Tapukara (KhairtalTijara) addressed a written correspondence dated 04.03.2025 to the Regional Officer, Rajasthan State Pollution Control Board, Bhiwadi and mentioned the details of the registered patients in the OPD. It has mentioned in the aforesaid correspondence that the lung related diseases, asthma, dehydration, sore throat, coughing and diseases have been found due to the common cause of the bacterial and viral infection and allergic pollens. Upon a bare perusal of the aforesaid reports dated 20.11.2024 and 04.03.2025 without any reasonable doubt it is understood that the Applicant has made false allegations. It is further stated that the Respondent is the largest manufacturer of ceramic/ vitrified tiles in India and 8th largest in the world, having the annual capacity of 88 million square meters with nine plants in Sikandrabad (Uttar Pradesh), Gailpur and Malootana (Rajasthan), Srikalahasti (Andhra Pradesh), Balanagar (Telangana) and three plants in

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the State of Gujarat whilst one plant is situated in Nepal. The manufacturing units of the Respondent is equipped with the cutting edge, modern technology. It is submitted that the Respondent only procures valid raw materials from valid licenses vendors for its ceramic tiles and glazed vitrified tiles. It is stated that the Respondent being the most reputable brand in the nation, has commissioned the Gailpur (Rajasthan) Plant after obtaining all necessary certificates and has started with the capacity of 5.7 million square meters per annum and presently standing at the capacity of 40.24 million square meters divided into three (3) units. The Kajaria Gailpur (Rajasthan) Plant has a turnover of Rs. 1191.55 crores (FY 2023-2024) resulting in the outstanding revenue generation for the Government of India as well as the State of Rajasthan, and, also paid the GST of Rs 235.14 crores (FY 20232024). It is further stated that that Respondent company and has received the certificates ranging from namely ISO 9001 (Quality Management), ISO 14001 (Environment Management), ISO 45001 (Occupational Health and Safety Management), ISO 22001 (Food Safety Management System) and has been accredited as the most certified tile ISO 50001 (Energy Management System) Certification, and, also BIS Standard-ICI Mark (CM/L-8400126607), CE Certification for fulfilling the international norms.

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It is further argued that the Respondent Plant has received various awards and recognitions inter alia the Indian Green Building Council, Super brand Award Winner, State Safety Award 2023, Rajasthan Factory Safety Award 2024, BHAMASHAH Award. Furthermore, the Respondent Plant has done the Corporate Social Responsibility of Rupees One corers Twenty Two Lakhs Fifty Five Thousand Two Hundred Thirty Five (Rs 1,22,55,235) in the FY

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2023-2024 which clearly shows its commitment towards the development and betterment of the society whilst keeping the principles of safeguarding the environment at its core. It is also state that the Respondent situated in Gailpur, Rajasthan and Respondent after having the duly converted land vide the conversion order dated 01.07.1996 established its units and obtained the factory license which has been duly amended from time to time. It is stated that recently the renewed its factory license for a period commencing from 29.12.2021 to 31.03.2032 vide the order dated 29.12.2021. It is stated that the Regional Office of the Rajasthan State Pollution Control Board issued the Consent to Establish dated 19.06.1996 for the Unit I. Moreover, the Consent to Operate dated 23.04.2024 for the Unit I of the Respondent was issued thereafter by the Respondent No.3 and as per the Consent to Operate dated 23.04.2024, the Consent has been granted for manufacturing/ producing the product of ceramic glaze tile for a quantity of 14.82 million square meters per annum for a period commencing from 01.05.2023 to 30.04.2033. Additionally, in conformity with the applicable rules and regulations, the Respondent was renewed the No Objection Certificate (NOC) dated 19.09.2023 in the name Respondent Unit I for ground water abstraction of existing ground water from a period of 19.03.2023 till 18.03.2027 by the Central Ground Water Authority for which the Respondents paid an amount of Rs 12,29,993.00 along with the application fees of amount of Rs 5000 on 13.02.2025 and Rs 9,73,833 along with the application fees of Rs 5,000 on 10.03.2025 as ground water abstraction charges.

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It is further stated that the Board Analyst of the Respondent Pollution Control Board collected certain samples from the Unit I and tested the same to determine various parameters including pH, total suspended solids mg/l etc. on 29.08.2024 and concluded its findings by way of a report dated 29.08.2024 and as per the said report dated 29.08.2024, the conditions of the sample tested was intact and as such all the parameters of the aforesaid conditions were in the permissible range. It is stated that another sample was collected from stack monitoring attached to biomass fired spray drier number-02 on 19.09.2024 to study the parameters with respect to particular matter and as per the report dated 19.09.2024, the result was intact and the results were within the permissible limit. As such, by way of the inspections conducted by the Respondent Pollution Control Board, it is crystal clear the Unit I of the Respondent is working efficiently and does not cause any damage whatsoever to the environment. It is stated that there are rainwater harvesting measures adopted in Unit I. within the premises of the Unit I, fifteen (15) rainwater harvesting structures have been installed for recharging water generated from the rooftop, paved and open area and the individual design is made of 3m³ of water i.e., 1m³ of water in desilting/settlement tank, 1m³ of water in filtration tank and about 1m³ in the process of infiltration through filtration chamber. Several measures have also adopted outside the premises of Unit I and as such seven (7) existing ponds at village Binoliya, Palpur, Bhindusi, Alapur, Maliyar Gurjar, Baghor and Beriyaki have been selected for developing an artificial recharge site and under this, two (2) to three (3) recharge pits in each pond have been constructed for fast and efficient recharge and due to the aforesaid steps taken by the Respondent, the recharge measure in 67189 m³ per annum and

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outside 231338 m³ per annum, the Unit I is creating recharging potential of the order of 298527 m³ per annum which is nearly 242% of the ground water extraction of 374 m³ per day by the Unit I. Therefore, there is negligible impact on water environment due to ground water withdrawal the aforesaid Unit I. It is also stated that the Unit II was issued the Consent to Establish on 28.02.2006 by the Regional Office of the Rajasthan State Pollution Control Board. Furthermore, the Respondent No.3 issued the revised consent to operate by the Respondent No. 3 on 24.11.2022. The Unit II was issued the Consent to Operate for the manufacturing/ producing the ceramic glaze tile of 16.50 million square meters per annum for a period from 25.05.2018 to 30.04.2028. Thereafter, the Central Ground Water Authority issued the No Objection Certificate (NOC) dated 17.10.2024 in the name of Respondent Unit II for extending the validity of ground water abstraction from a period of 28.02.2023 till 27.02.2027.

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It is further submitted that keeping in mind the highest degree of care for the environment, within the premises of the Unit II of the Respondent, nine (9) rainwater harvesting structures have been installed for recharging water generated from the rooftop, paved and open area. The individual design is made of 3m³ of water i.e., 1m³ of water in desilting/ settlement tank, 1m³ of water in filtration tank and about 1m³ in the process of infiltration through filtration chamber. Whereas, outside the premises of the Unit II, in the existing ponds at village of Baliyawas, Birampur, Mundana and one anicut at Village Jojaka have been selected for developing them as artificial recharge site and under this, nine (9) recharge pits in Jojaka anicut, four (4) recharging pits in Mundhana pond, three (3) recharging pits in Baliyawas

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pond and three (3) pits in Birampur pond having recharge shaft of 6 inch dia and 20 m depth have been constructed for fast and efficient recharge of coming runoff into them. Due to the aforesaid steps taken by the Respondent, the recharge measure in 43906 m³ per annum and outside 525744 m³ per annum, the Unit II is creating recharging potential of the order of 569650 m³ per annum which is nearly 238% of the ground water extraction of 654.50m³ per day by the Unit II and, therefore, there is negligible impact on water environment due to ground water withdrawal the aforesaid Unit II.

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It is further submitted that the Board Analyst of the Respondent Pollution Control Board collected a sample of stack monitoring for biomass spray drier 03 on 23.08.2024 for inspection purposes. As per the report dated 23.08.2024, the particular matter mg/Nm³ was 70 and as such was resulted as "intact." Thereafter, another sample was collected from stack monitoring attached to biomass fired spray drier number-01 on 20.09.2024 to study the parameters with respect to particular matter and as per the report dated 20.09.2024, the result was intact and the results were within the permissible limit. As such, by way of the inspections conducted by the Respondent Pollution Control Board it is crystal clear that the Unit II of the Respondent is working efficiently and does not cause any damage whatsoever to the environment. It is stated that the Unit III was issued the Consent to Establish dated on 26.02.2013 by the RSPCB. Thereafter, the Respondent No.3 issued the revised Consent to Operate dated 24.11.2022 for manufacturing/ producing of vitrified ceramic tiles of 25,000 square meter per day for a period of 27.11.2019 till 31.08.2028. Additionally, the

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Central Ground Water Authority issued the No Objection Certificate (NOC) dated 13.01.2025 in the name of Respondent Unit III for ground water abstraction of existing ground water from a period of 19.03.2023 till 18.03.2025. It is stated that within the premises of Unit III, eight (8) harvesting structures have been installed within the premises for recharging storm water generated from rooftop, paved and open area. The individual design is made of 3m³ of water i.e., 1m³ of water in desilting/settlement tank, 1m³ of water in filtration tank and about 1m³ in the process of infiltration through filtration chamber. Whereas, outside the Unit III premises, one existing pond at village Benoliya, one existing pond at village Dabherah in Bichhala Gram Panchayat have been selected for developing them as artificial recharge site. Under this, six recharge pits in Benoliya village pond and three recharge pits in Dabherah village pond have been constructed for fast and efficient recharge of coming runoff into them. Due to the aforesaid steps taken by the Respondent, the recharge measure in 35959.48m³ per annum and outside 274230 m³ per annum, the Unit III is creating recharging potential of the order of 310189.48 m³ per annum which is nearly 215% of the ground water extraction of 400 m³ per day by the Unit III. Therefore, there is negligible impact on water environment due to ground water withdrawal the aforesaid Unit III.

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It is further argued that the Respondent Unit is involved in the manufacturing of ceramic/ vitrified tiles and operated at a total area of land admeasuring 435109.32 square meters. The manufacturing process of ceramic/ vitrified tiles at the Respondent units include several key steps/ in body preparation, raw materials (ball clay, feldspar, quartz, talc etc.) are

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transported, weighed and mixed with the recycled water in a ball mill to create a fine mixture "slip", which is then stored in agitator tanks. The "slip" is atomised in a spray manner with hot air (500-600 degree Celsius) to form spherical powder particles within the 5-6% moisture. This powder is compacted into moulds using hydraulic presses forming the tiles under high pressure (500-5000 tonnes). The pressed tiles are dried in a horizontal drier using hot air at around 180 degrees Celsius, employing natural gas and heat recovery systems to enhance the energy efficiencies. After drying, the tiles receive a glazed spray. Ink jet printing is used for additional decoration, allowing customisation. The decorated tiles are dried to remove the additional moisture (1-2%) using recycled heat from the kiln. The tiles are fired at temperatures up to 1200 degrees Celsius in a roller hearth kiln, solidifying their structure and making them water resistant. Post-firing, the tiles are polished and squared using abrasives and treated water from the effluent treatment plant. The fired tiles undergo quality inspection, sorting and are then packed in cartons ready for delivery.

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It is also stated that the Respondent units have also obtained the authorisation for generation, collection, disposal, storage, transport or hazardous wastes under the Hazardous and Other Waste (Management and Trans Boundary Movement) Rules, 2016 for used/ spent oil category (5.1) from the Rajasthan State Pollution Control Board (RSPCB) and have generated capital Hazardous Waste sold to the registered recyclers. For the Unit I the Hazardous Waste Authorisation issued on 24.12.2020, and validated from 01.12.2020 till 30.11.2025. For the Unit II the Hazardous Waste Authorisation issued on 20.12.2024, and validated from 01.01.2025

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till 31.12.2030. For the Unit III the Hazardous Waste Authorisation issued on 08.09.2021, and validated from 01.09.2021 till 31.08.2026. It is stated that the the Respondent has also a 100 KLD Sewage Treatment Plant to treat water and the raw water generated is generally passed through the drainage line, before it reaches to collection tank and thereafter it will pass through a bar screen and oil grease trap for removal of any coarse debris and floating oil. Hence, any clogging material like - plastic bags, papers or debris are removed in initial bar screen. This water is then pumped to the main packaged sewage treatment plant, and, the main plant consists of three chambers. Not only the environment is not harmed, there are several advantages of the 100 KLD Sewage Treatment Plant since there is a reduction in the volume of the biological reactor because it uses a support or carrier that gives a high specific surface. Furthermore, there is no sludge recirculation. Besides, the Respondent also duly disposes of the solid waste at the dumping yard situated in Rampur Mundana, Bhiwadi through 130 dumpers on various dates in the year 2023-2024 through its authorised agency M/S Ratan Enterprises.

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It is also stated that the Respondent has been issued the Consent to Operate dated 09.12.2019, valid for a period commencing 25.07.2019 to 30.06.2029 for 100 KLD STP based on MBBR technology for treatment of domestic waste water generated by the RSPCB. It is further stated that for the month of December 2024, the average waste water received at inlet 59 KLD and the average treated waste water after disinfection taken out at the outlet was 53 KLD which is used for the purposes of horticulture. It is stated that with the aim to treat waste water a storage waste water tank of 80 KLD have also

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been installed in the Respondent units. It is stated that all the Respondent units are also equipped with Settling tanks for treatment of industrial effluent generated. The Unit I has 12 settling tanks, whereas Unit II and Unit III have 14 settling tanks respectively with 80m³ capacity of each settling tank and 1 tank of 160 m³ capacity treated water collection tank for all three units. It is further stated that PAC are using as flocculent in the settling tank and generated sludge is passed through filter press and solid sludge is stored in the sludge storage area inside the premises. The settling tanks are equipped with flow meter for filling and sludge storage area inside the premises. The settling tanks are equipped with flow meter at the outlet and PTZ cameras which are installed on all the units are connected with the State Pollution Control Board servers for monitoring purposes. It is also most respectfully submitted that the sludge generated from the settling tank of all 3 units, is transferred at sludge drying area, and the sludge after drying is being reused as raw material in the process. The total sludge received and consumed for the period from April 2024 to December 2024 for Unit I was 5347.03 MT and 5242.00 MT, Unit II was 1303.01 MT and 1368.95 MT and for the Unit III was 3742.53 MT and 3812.19 MT. The broken tiles which are generated during the polishing/finishing are stored openly in the premises. Furthermore, to avoid and minimize wastage the part of the broken tiles are reused in the manufacturing process after grinding and rest is sold locally.

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It is further argued that despite adhering to the highest degree of environmental care and undertaking various social responsibilities, the Respondent there has been a constant and continuous threat posed by

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various notorious elements of the society. It is stated that the Respondent has been time and again been subjected to several ill demands such as extortion by members of the society. It is further stated that in the wake of the ongoing demands of extortion and persisting threats, the Respondent was left with no other alternative but to approach the law enforcement agency of the State. Therefore, in regard to the aforesaid Respondent filed a First Information Report dated 23.06.2023 before the Tapukara Police Station, Bhiwadi Rajasthan and as per the First Information Report dated 23.06.2023 it was reported that certain notorious elements of the society such as Neeraj Kumar (son of the then Sarpanch of the Gram Panchayat) along with his other members inter alia the then Sarpanch, Dinesh Kumar have on a daily basis threated the Respondent for extorting large sums of monies. The aforesaid notorious people have demanded a sum from Rs 20 lacs to Rs 25 lacs from the Respondent with a threat that if the amount would not be paid, the Respondent units shall be shut down. Apart from threatening to shut down the Respondent units, threats of false complaints on the forged/illegal letter head of the Gram Panchayat were submitted before various authorities of the Government including the Rajasthan State Pollution Control Board, Employees State Insurance Corporation etc. It is also stated that the aforesaid notorious elements have also issued several arbitrary, illegal notices against the Respondent and as such have made the daily smooth functioning of the Respondents difficult.

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It is further stated that the Respondent provides a proper source of livelihood to all its employees and workers and Respondent has time and again engaged in several activities to improve the quality of environment of its

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area, and, has also constructed several toilets to ensure safety and proper sanitation for people, and the same has been published by the print media as news. It is noteworthy to mention herein that the Respondent has also permitted several Villagers to inspect the aforesaid three units, and, thereafter the villagers after a satisfactory inspection have reported in positive. It is an extremely sad and sorry state of affair that despite the aforesaid, the Respondent is subjected to constant threat of extortion of money, closure of its units amongst etc. by notorious elements. It is further stated that the Respondent have a valid Consent to Operate from RSPCB and the units have obtained authorisation for the generation, collection, disposal, storage, transport of the hazardous waste under the Hazardous and Other Waste (Management and Trans Boundary Movement) Rules, 2016, for the use or spend oil from the RSPCB and also obtained the Consent to Operate from the RSPCB for the 100 KLD STP based on MBBR Technology for the treatment of domestic waste water generated from all the 3 units of the Plant. It was further observed that the raw water requirement of all the 3 units of the plant is fulfilled through the ground water (borewells) and the units have obtained the NOC from the CGWA for all its 6 borewells and the total average water consumption for the period 01.01.2024 to 31.12.2024 is within permissible limits for the ground water extraction as per the NOC issued by the CGWA.

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It is also stated that since the Respondent is paying the greatest regard to the environment pursuant thereto, the Respondent executed a Memorandum of Understanding (MoU) dated 01.06.2025 with the Indian Institute of Technology, Kanpur (IIT-K) with the aim and objective of initiating a project

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titled "Environmental Audit and Advisory for Improving Air, Water and Waste Management Systems at the Kajaria Ceramics Limited Gailpur" for a period of one year. One of the primary reasons for the Respondent to execute an MoU with IIT-K was because of the rich educational values of the institution and as such IIT-K, being a technical expert i.e., a person/ institute with specialised knowledge in a specific field who provides expert opinions, imparts and undertakes cutting-edge research in various areas of science, engineering, design, management and humanities. The scope and objectives of the MoU dated 01.06.2025 is inter alia a detailed audit of existing systems of air, water and waste management at the Respondent Units in terms of their capabilities and performances, and, identification and provide potential means of suggestions/ remedials, additional systems to improve the air, water and waste management facilities at the plant for bringing the emissions and discharges under the compliances. Therefore, it is clearly showing that the Respondent is duty bound to obey each and every norms of the environmental laws while operating its Plants. It is further stated that the pollution is caused by vehicular emissions and not any specific industry as such. It is also stated that upon a perusal of the article dated 23.11.2024, it is crystal clear that the disposal unit outside the Bhiwadi Industrial Authority is not functional. Furthermore, as per the newspaper article dated 23.11.2024 the main reason for local residents of Bhiwadi falling sick is due to the allergens produced by sulphur, dust and vehicular emissions. It is crystal clear from the newspaper article dated 23.11.2024 that the same is not directed towards the Respondent since the 6 hotspots in Bhiwadi wherein the AQI is bad are Dhabha Complex to Bhiwadi Turn, Bhiwadi Turn to Toll Plaza, Alwar, Alwar Road to Mansha Chowk, Mansha Chowk to Relaxo

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Chowk, UIT Residential Area to Chopanki Road. Furthermore, the major reasons for the poor AQI at the hotspots are namely Rajasthan Industrial State Development and Investment Corporation Limited (RIICO) Industrial Area wherein smoke is produced from heavy industries, improper disposal of factory waste and chemical emissions and the RIICO Industrial Area is considered to be the hotspot with the worst AQI followed by the Alwar Bypass Road. It is stated that due to the heavy tragic severe and construction work severe vehicular emission and air pollution is cased making the dust and smoke levels alongside the road dangerously highly and the third major reason for poor AQI in the Bhiwadi hotspot is the Phase II Industrial Zone wherein several chemical factories are situated and these chemical factories and industries produce a lot air and water pollutants as such degenerating the environment. Thereafter, areas including the Bhiwadi bus stand and Kushkhera Industrial belt play an eminent role for the poor quality AQI in the Bhiwadi hostpot and the smoke emitted by the heavy vehicles inter alia buses at the bus stand and the pollution caused by the steel and plastic industries causes chronic respiratory ailments to people in nearby and adjacent surroundings. It is also stated that the newspaper article dated 23.11.2024 itself states that the 77% air pollution is caused by the road dust and industrial dust as produced in the aforesaid hotspots and as 80 tonnes of solid waste and residential garbage is produced in the Bhiwadi. As such, Gailpur wherein the Respondent units are situated does not fall under the aforesaid hotspots.

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It is stated that the Respondent has been accredited as the most certified tile company and has received the certificates ranging from namely ISO 9001

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(Quality Management), ISO 14001 (Environment Management), ISO 45001 (Occupational Health and Safety Management), ISO 22001 (Food Safety Management System) and ISO 50001 (Energy Management System) Certification, and, also BIS Standard-ICI Mark (CM/L-8400126607), CE Certification for fulfilling the international norms. The Respondent Plant has received various awards and recognitions inter alia the Indian Green Building Council, Super brand Award Winner, State Safety Award 2023, Rajasthan Factory Safety Award 2024, BHAMASHAH Award. Furthermore, the Respondent plant has done the Corporate Social Responsibility of Rupees One crore Twenty Two Lakhs Fifty Five Thousand Two Hundred Thirty Five (Rs 1,22,55,235) in the FY 2023-2024 which clearly shows its commitment towards the development and betterment of the society whilst keeping the principles of safeguarding the environment at its core.

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It is further argued that the Respondents was issued the renewed No Objection Certificate (NOC) dated 29.05.2025 in the name of Respondents Unit I for ground water abstraction of existing ground water from a period of 19.03.2025 till 18.03.2027 by the Central Ground Water Authority for which the Respondent paid an amount of Rs 12,29,993.00 along with application fees of amount Rs 5000.00 on 13.02.2025 and Rs 9,73,833.00 along with application fees of Rs. 5000.00 on 10.03.2025 as ground water abstraction charges. It is further stated that the competent authority has issued No Objection Certificate (NOC) on 17.10.2024 in the name of Respondent Unit II for extending the validity of ground water abstraction from a period of 28.02.2023 till 27.02.2027. It is stated that keeping in mind the highest degree of care for the environment, within the premises of the

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Unit II of the Answering Respondent, nine (9) rainwater harvesting structures have been installed for recharging water generated from the rooftop, paved and open area. The individual design is made of 3m³ of water i.e., 1m³ of water in desilting/settlement tank, 1m³ of water in filtration tank and about 1m³ in the process of infiltration through filtration chamber. Whereas, outside the premises of the Unit II, in the existing ponds at Village of Baliyawas, Birampur, Mundana and one anicut at village Jojaka have been selected for developing them as artificial recharge site. Under this, nine (9) recharge pits in Jojaka anicut, four (4) recharging pits in Mundhana pond, three (3) recharging pits in Baliyawas pond and three (3) pits in Birampur pond having recharge shaft of 6 inch dia and 20 m depth have been constructed for fast and efficient recharge of coming runoff into them and due to the aforesaid steps taken by the Respondent, the recharge measure in 43906m³ per annum and outside 525744 m³ per annum, the Unit II is creating recharging potential of the order of 569650 m³ per annum which is nearly 238% of the ground water extraction of 654.50m³ per day by the Unit II. Therefore, there is negligible impact on water environment due to ground water withdrawal the aforesaid Unit II.

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It is further argued that the Respondent Plant had installed a settling tank for the treatment of industrial effluent generated and is equipped with flow meter at the outlet and PTZ cameras at each unit and connected with the State PCB servers. On the issue of industrial effluent and fugitive dust emission, it is contended by the learned counsel for the Respondent that the discharge of industrial effluent into the borewells was not observed by the Fact Finding Committee and the units have developed the rainwater

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harvesting structure inside and outside the plant premises to collect the rain water to recharge the ground water after getting NOC from the respective villages of the Sarpanch's. it is stated that the Committee has also observed that the fugitive dust emission conveying of raw materials, is done through the covered vehicles to prevent spillage and dust generation, and, raw materials stored under a covered shade of RCC flow, and, all the internal and connecting roads to the highway were made of concrete pavement to reduce the fugitive dust emissions during the transportation.

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On the point of use of biomass the learned counsel for the respondent has argued that the Hon’ble Supreme Court of India in the case of M.C. Mehta vs. Union of India has regulated the stubble burning caused by the farmers in the process of farming and not on all farm husk and its bye products and as per the latest directions issued by CAQM in its Notification dated 03.06.2022 & press release dated 24.06.2022, have released the list of approved fuel for the use in industrial purpose in the NCR region after the direction of the Supreme Court. The Answering Respondents in its Kajaria Gailpur plant is not doing the stubble burning and using only those fuel in the industry which is approved by the CAQM in its latest directions (Supra), and same has been re-verified by the Respondent no.5 in its inspection report date 19.09.2024. Therefore, it is futile to say that, the industry of the Respondents is not adhering to the guidelines issued the Tribunals and Hon'ble Supreme Court of India. Earlier vide inspection dated: 19.09.2024, it was found that the Kajaria Gailpur plant is using the approved BIOMASS fuel in the spray dryer machinery and using of this fuel is as per the norms settled by the CAQM. It was also observed that air emission released by the

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spray dryer machinery and found that emission released by the spray dryer machinery is as per the approved emission standards. It is worthwhile to mention here that this Tribunal, in the instant OA, vide order dated 24.12.2024, directed the constitution of the joint committee comprising one representative from the District Collector, Khairtal-Tijara, one representative from the CPCB, one representative from the RSPCB and also directed to conduct the site visit. Pursuant thereto, the joint committee inspected the site of Respondents from 31 January - 2^nd February 2025 and specifically observed that all units of the Respondents have valid consent to operate from RSPCB and unit has obtained authorisation for generation, collection, disposal, storage, transport of hazardous waste under hazardous and other waste (Management and Trans boundary movement) Rules, 2016 for used or spent oil from RSPCB and also obtained consent to operate from RSPCB for 100 KLD STP based on MBBR Technology for treatment of domestic waste water generated from all 3 units of the plant. It was further observed that the raw water requirement of all 3 units of the plants is fulfilled through groundwater (Borewells) and unit has obtained NOC from CGWA for all its six borewells and total average water consumption for the period 1st January 2024 31st December 2024 is within permissible limit for ground water extraction as per NOC issued by the CGWA.

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It was also observed that the plant has installed an ETP/Settling Tank for the treatment of industrial effluent generated, is equipped with a flow meter at the outlet, and PTZ cameras at each unit, and connected with RSPCB servers. Further, it was observed that discharge of industrial effluent into the borewell was not observed by the joint committee, and unit has developed

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the rainwater harvesting structure inside and outside the plant premises to collect the rainwater for recharging ground water after getting NOC from the respective villages of the sarpanch's.

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The joint committee has also observed that fugitive dust emission, conveying of raw material, is done through covered vehicles to prevent spillage and dust generation, and raw materials stored under a covered shed of RCC floor, and all the internal and connecting roads to the highway were made of concrete pavement to reduce fugitive dust emission during transportation. It was also observed that the plant is using PNG as fuel in most of the process areas and has installed PNG supply lines on the premises and unit has developed a green belt inside as well as outside of the premises. Aforesaid, observation of the joint committee clearly shows that the Answering Respondent is operating its unit after complying with all norms and provisions of the environmental laws. The joint committee has also observed some deficiencies with regard to the hospitality of the plant, and recommends some suggestions to remove the same. For this purpose, RSPCB issued show cause notices to the Answering Respondents and your Answering Respondents have filed detailed reply dated 20.03.2025 for all its 3 units. The matter is pending for adjudicating by RSPCB and Answering Respondents have protected their rights to avail legal remedy before the competent court of law. Copies of the reply dated 22.03.2025 will be kept ready at the time of argument to avoid the bulkiness of the reply.

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Since the Answering Respondents is paying his greatest regard to the environment, pursuant thereto, the Answering Respondents executed a memorandum of understanding (MoU) dated 01.06.2025 with the Indian

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Institute of Technology, Kanpur (IIT-K) with the aim and objective of initiating a project titled "Environmental Audit and Advisory for Improving Air, Water and Waste Management Systems at the Kajaria Ceramics Limited Gailpur" for a period of one year. One of the primary reasons for the Answering Respondents to execute an MoU with IIT-K was because of the rich educational values of the institution. The scope and objectives of the MoU dated 01.06.2025 is inter alia a detailed audit of existing systems of air, water and waste management at the Answering Respondents Units in terms of their capabilities and performances, and, identification and provide potential means of suggestions/remedials, additional systems to improve the air, water and waste management facilities at the plant for bringing the emissions and discharges under the compliances. Therefore, it is clearly showing that Answering Respondents are duty-bound to obey each and every norms of environmental laws while operating its plants.

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Learned Counsel for the State PCB has submitted that the periodical report has been filed by the unit and it is regularly monitored by the State PCB and no violations have been found. It is further argued on behalf of the PP that the unit has engaged Indian Institute of Technology for technical advice for disposal of the waste and are doing best efforts for disposal according to rules.

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In view of the above facts, our conclusions and directions are as follows :

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1. Respondents are directed to follow the guidelines issued in O.A No. 258/2024(CZ).

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2. Plant will ensure to stop the untreated domestic sewage generated from the residential colonies from using it for horticulture purpose and to be used after treatment by providing new STP or to be connected to the sewer lines associated with the existing 100 KLD STP, Proper treatment of domestic sewage should be done in the existing 100 KLD STP to achieve the permissible standards limit. Plant should ensure proper housekeeping of sludge storage and mustard husk ash storage area. Mustard husk ash should be stored under covered shed to avoid fugitive dust emission and ash generation & selling records should be maintained properly.

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3. Respondent Plant will carry out regular cleaning of all internal roads particularly truck parking area, vehicle movement area and ensure dust suppression through water sprinkling system to reduce fugitive dust emission. Plant should ensure to cover all the material conveyor belt and installed fume hood on all the ball mills of all 3 units & connected with APCD through suction duct to reduce the fugitive dust emission. Plant should operate both the grinder machines installed with air pollution control devices in the premises only after obtaining prior requisite permission from RSPCB and upgrading the APCDs and cover the material conveyor belt to achieve the fugitives dust emission standard.

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4. Project Proponent will upgrade the air pollution control devices attached with Husk fired hot air generator attached with spray dryer (capacity 26 Ton) of unit –I, Husk fired hot air generator

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attached with spray dryer (capacity 22 Ton) of unit- II & Husk fired hot air generator attached with spray dryer (capacity 13 Ton) of unit –III, in which mustard husk is being used as fuel. Plant should upgrade monitoring facility for source emission of stack no. 3 attached with Husk fired hot air generator attached with spray dryer (capacity 13 Ton) of unit-II. Plant should regularly update the display board installed at main gate with requisite information and maintain the proper record of hazardous waste in Form-3 as per the H & OW (M & TM) Rules, 2016.

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5. As plant is located in the Delhi NCR region, it should also adhere with the directions issued time to time by CAQM, and ensure proper use of safety kits i.e. mask, gloves, gumboot, helmet goggles etc. by all workers inside premises during material handling and process area. Industry has made reasonable efforts for plantation/greening; however, the coverage of green belt is still less than 49% of total plant area. Thus, industry is directed to improve the green belt area and to carrying out planting using Miyawaki technique as per the norms of the Forest department.

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6. The technical expertise, guidance and suggestions provided by the IIT Kanpur as regards the Environment Audit and Advisory for Improving Air, Water and Waste Management Systems at Kajaria Ceramics Limited, Galipur, should be followed for the better management of environment in and around the Respondent industry.

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7. The Municipal Corporation Bhiwadi and the RIICO have to share the responsibility within the Municipal area with regard to the civilians and the waste management. Within the area of the unit it shall be done by the unit in accordance with the rules.

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8. State PCB is directed to periodically monitor it and in case of violation and to take necessary action according to rules.

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With these observations the Original Application No. 272/2024 (CZ) stands disposed of.

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(A copy of this order be communicated on available e-mail to Principal Secretary, Environment, Govt. of Rajasthan, Principal Secretary, Department of Industries, Member Secretary, Rajasthan State PCB, RIICO, BIDA, Municipal Commissioner, Bhiwadi, and CollectorBhiwadi, for information and necessary action.)

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Sheo Kumar Singh, JM

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Sudhir Kumar Chaturvedi, EM

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12^th September, 2025, O.A. No.272/2024(CZ) K

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Ravindra/Raghu Yadav & Ors.

Ravinder Raghu Yadav v. M/S Kajaria Ceramics Limited Chief Executive Officer/ Authorized Representative

Case brief

What is this about?

What did the court decide?

Ravinder Raghu Yadav v. M/S Kajaria Ceramics Limited Chief Executive Officer/ Authorized Representative

Case brief

What is this about?

What did the court decide?

What the court decided

A compact analysis

Issues for consideration

Cases cited

Statutes considered

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