Disposed

Ravinder Raghu Yadav v. Shree Cement through Chif Executive Officer

NGT4 Feb 2026Original Application No. 93/2025

Case brief

AI extract

What is this about?

In an application alleging illegal groundwater extraction, discharge of effluents, and prohibited burning of agricultural residue, the NGT appointed a joint committee to verify claims. The committee found no violations but recommended infrastructural upgradation. Upon the Respondent's compliance, the application was disposed of.

What did the court decide?

The Respondent is directed to complete the Sewage Treatment Plant upgrade within two months and adhere to environmental norms. The original application is disposed of as no violations were found.

Ravinder Raghu Yadav vs Shree Cement through Chif… — Environment and Pollution | NGT (2026)

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Item No.07

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

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Original Application No.93/2025(CZ)

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Ravinder Raghu Yadav Applicant(s)

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Vs.

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Shree Cement, through Chief Executive Officer & Ors. Respondent(s)

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Date of Hearing: 04.02.2026

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

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For Applicant (s): Mr. Ajit Singh, Adv. For Respondent(s) : Mr. Divya Prakash Pandey, Adv. with Ms. Sakshi Popli, Adv. for R-1 Mr. Rohit Sharma, Adv. for RSPCB Mr. Om Shankar Shrivastava, Adv. for RIICO

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ORDER

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The grievance of the Applicant is non-compliance of the environmental rules and illegal discharge of solid waste and non-compliance of the Water (Prevention & Control of Pollution) Act, 1974. It is alleged that the Respondents have illegally dug multiple deep borewells and installed submersible pumps without any lawful permission to extract excessive groundwater for cement manufacturing. Furthermore, untreated industrial effluents containing hazardous chemicals are being directly discharged into these borewells, contaminating the groundwater and drastically increasing levels of TDS and fluoride, leading to severe health issues such as cancer, respiratory disorders, and skin diseases among the local population. The respondents are also illegally burning prohibited materials like mustard husk and farm residue as fuel within the National Capital Region (NCR), releasing large

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O.A. No.93/2025(CZ) Ravinder Raghu Yadav Vs. Shree Cement, through Chief Executive Officer & Ors.

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volumes of toxic smoke, severely degrading ambient air quality and causing irreversible harm to public health, biodiversity, and local agriculture.

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Notices were issued to the Respondents with direction to submit the reply. Replies have been filed.

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During the course of hearing, a Committee was constituted with direction to submit the factual and action taken report. The report has been filed.

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We have heard the learned Counsel for the parties and perused the records.

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The submissions of the learned Counsel for the Applicant are that the Respondent Unit is violating the environmental norms and burning farm residue and mustered of husk as a fuel for manufacturing activity in the Unit situated within National Capital Region which is strictly prohibited in view of pollution issues.

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It is further argued that the Unit has not put in place any measure to keep the pollution under-control while 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.

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To find out the exact status, this Tribunal constituted a Committee and the members of the Committee visited the site and submitted the report with the following observations:-

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“Report of the Joint Committee constituted in compliance with the Order dated 29/07/2025 in the O.A. No 93/2025 in the matter of Ravinder Raghu Yadav V/s Shree Cement & Ors before the Hon'ble National Green Tribunal, Central Zone, Bhopal,

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O.A. No.93/2025(CZ) Ravinder Raghu Yadav Vs. Shree Cement, through Chief Executive Officer & Ors.

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4. Preliminary Discussions of the Joint Committee

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The Committee informed the petitioner, Shri Ravinder Raghu Yadav, telephonically about the proposed visit to the industry. However, the complainant could not participate in the on-site dialogue as he was out of station on the scheduled date of inspection.

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The Committee held a telephonic discussion with the applicant to understand the primary issues and concerns raised in O.A. No. 93 of 2025. During the interaction, the applicant communicated the following key allegations against M/s Shree Cement Limited, Khush Khera:

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That the industry is allegedly discharging untreated wastewater directly into borewells, thereby contaminating groundwater resources;

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That mustard husk and other agricultural residues, i.e., unapproved fuels, are being used as fuel in the manufacturing process;

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That the unit is responsible for generating significant fugitive emissions.

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Subsequently, the Committee deliberated upon the Terms of Reference issued by the Hon'ble National Green Tribunal, examined the factual aspects of the case, and finalized the proposed course of action for verification of the claims made in the application.

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It was decided that a site inspection would be undertaken to assess the veracity of the allegations. Furthermore, the Committee resolved to conduct monitoring and sampling of air and water quality parameters, with technical assistance from the Rajasthan State Pollution Control Board (RSPCB). It was also agreed that historical data related to air and water quality, as available with RSPCB, may be reviewed and incorporated in the report, wherever relevant, to provide context and support to the findings.

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In accordance with the above decisions, the site inspection and environmental monitoring activities were conducted on 12th and 13th September 2025.

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5. Brief of M/s Shree Cement Limited :-

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M/s Shree Cement Limited is located at SP-3/A-11, RIICO Industrial Area, Khushkhera, in District Khairthal-Tijara, Rajasthan. Notably,

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O.A. No.93/2025(CZ) Ravinder Raghu Yadav Vs. Shree Cement, through Chief Executive Officer & Ors.

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the district of Khairthal-Tijara falls within the National Capital Region (NCR). The unit is engaged in the grinding of clinker for the purpose of cement manufacturing.

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A snapshot of the key parameters of the industry is provided below:

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6. Manufacturing Process

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The Clinker Grinding Unit of M/s Shree Cement Limited, located at Khushkhera, operates on dry process technology. The plant grinds clinker to produce cement using a closed-circuit ball mill system, integrated with a pre-grinder (roller press) and a separator.

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The main raw materials used are clinker, gypsum, fly ash, and additives. The unit produces both Ordinary Portland Cement (OPC) and Pozzolana Portland Cement (PPC), depending on the proportion of raw materials used.

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For OPC, about 93-95% clinker is mixed with 5-7% gypsum.

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For PPC, about 60-65% clinker is blended with 5-7% gypsum and up to 35% fly ash, as per BIS specifications.

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To enhance grinding efficiency and reduce moisture in fly ash, pond ash, and gypsum, the unit has installed two Hot Air Generators (HAGs), which use biomass as fuel.

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The grinding system comprises cement mills (2 in no's) operating in a closed circuit. In this system, clinker, fly ash, and gypsum are ground together in a ball mill with steel balls as the grinding media. The

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O.A. No.93/2025(CZ) Ravinder Raghu Yadav Vs. Shree Cement, through Chief Executive Officer & Ors.

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ground material is lifted by a bucket elevator to a separator, which classifies it into fine and coarse fractions.

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Fine particles are collected in cyclones and conveyed to the cement silos through air slides and elevators.

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Coarse particles are returned to the separator for further grinding.

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The separator's circulating air, along with mill venting, passes through a bag filter to capture fine particulate matter. The collected dust is also returned to the cement silos.

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The finished cement is stored in silos, then transferred to a rotary packer, where it is packed in 50 kg HDPE bags and loaded onto trucks for dispatch.

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To control emissions from grinding and material handling, bag houses are provided as Air Pollution Control Devices.

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Process Description:

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The cement grinding process at M/s Shree Cement Limited involves three key stages: feeding and proportioning, grinding, and separation. The primary raw material used is clinker, a stony, porous substance produced by heating limestone and other additives (such as iron ore) in a rotary kiln. To manufacture specific types of cement, additional materials are blended with clinker. In the case of Ordinary Portland Cement (OPC), approximately 93-95% clinker is ground with 5-7% gypsum. For Pozzolana Portland Cement (PPC), the mix typically consists of 60-65% clinker, 5-7% gypsum, and fly ash as the remaining component, up to a maximum of 35%, as per BIS guidelines. Gypsum (CaSO4.2H2O) acts as a retarder, regulating the setting time of cement and improving workability.

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These raw materials are accurately weighed and proportioned before being fed into the roller press and subsequently into the ball mill. The roller press, comprising two rollers, performs the pre-grinding of clinker, thereby reducing the load on the ball mill. The ball mill itself is a large, rotating cylindrical chamber partially filled with steel grinding media of varying sizes. As the cylinder rotates, the grinding media tumble and cascade, breaking down the clinker and additives by impact and attrition. Larger balls are used to crush coarse particles, while smaller balls are effective for fine grinding. The material is thus ground into a fine powder.

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O.A. No.93/2025(CZ) Ravinder Raghu Yadav Vs. Shree Cement, through Chief Executive Officer & Ors.

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Following grinding, the material is conveyed to a high-efficiency separator, a crucial component of the closed-circuit grinding system. The separator uses air currents to differentiate between fine and coarse particles. The fine particles, which meet the desired fineness specification, are transported to the cement silos for storage, while the coarse fraction is returned to the mill for further grinding.

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The entire grinding process is continuously monitored and controlled through a Central Control Room (CCR). Critical parameters such as particle size distribution, chemical composition, and fineness are regularly checked to ensure that the product meets industry standards and customer requirements. The use of modern automation and control systems contributes to operational efficiency, product uniformity, and environmental management.

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7. Observation of the Joint Committee -

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Based on the deliberations held during the meeting of the Joint Committee, subsequent site inspection of the unit under question i.e. M/s Shree Cement Limited, Khushkhera, sampling & analysis of the Source Emission, Ambient Air Quality Monitoring, Fugitive emissions, Waste Water, historical data available with the Rajasthan State Pollution Control Board and documents made available to the Joint Committee, the following observations are made on the ToR:

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A. General Observations

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M/s Shree Cement Limited is located at SP-3/A-11, RIICO Industrial Area, Khushkhera, Tehsil Tapukara District KhairthalTijara.

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The industry is engaged in Cement Manufacturing through Clinker Grinding, for this purpose 2 Cement Mills (Grinding Mills) have been established.

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The industry has obtained Consent to Operate from the RSPCB under the provisions of section 25/26 of the Water Act, 1974 and under section 21 of the Air Act, 1981. Details of the CTO are as under:

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O.A. No.93/2025(CZ) Ravinder Raghu Yadav Vs. Shree Cement, through Chief Executive Officer & Ors.

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The unit has also obtained Consent to Operate from RSPCB under the provisions of section 25/26 of the Water Act, 1974 and under section 21 of the Air Act, 1981 for use of Biomass and PNG as fuel Details of the CTO are as under:

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The unit has obtained authorization for generation, collection, disposal, storage, transport of hazardous waste under Hazardous and Other Waste (Management and Trans boundary Movement) Rules, 2016 for Used / Spent oil from RSPCB and generated HW is either to be disposed in Co-processing in cement kiln or sale to registered recycler. Details of Hazardous waste authorization are tabulated below:

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The production capacity permitted to the industry under Consent to Operate issued by the State Pollution Control Board is 4.5 Million Ton/Annum.

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The unit has obtained Consent to Operate for operating 2 Cement Mills. The mills are designed to handle 300 Tonn/Hour & 240 Tonn/Hour of feed for grinding.

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During the day of inspection, the operational status of both the mills was verified from the PLC system established in the Central Control Room.

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The mills were found operating at about 200-240 Tonn/Hour feed rate.

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B. Observations regarding Water Pollution: -

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The applicant in O.A. No. 93/2025 has alleged that the respondents have illegally dug multiple deep borewells and installed submersible pumps without lawful permission to extract excessive quantities of

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O.A. No.93/2025(CZ) Ravinder Raghu Yadav Vs. Shree Cement, through Chief Executive Officer & Ors.

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groundwater for cement manufacturing. It has further been alleged that untreated industrial effluent containing hazardous chemicals is being directly discharged into these borewells, thereby contaminating the groundwater and leading to elevated levels of TDS and fluoride. The Committee's observations on these allegations are as follows: -

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The industry meets its freshwater requirement through groundwater sourced from two borewells. A valid No Objection Certificate (NOC) has been obtained from the Central Ground Water Authority, New Delhi (CGWA) under the "Overexploited" category, permitting abstraction of up to 150 m³/day through the two borewells. The NOC remains valid until 14.04.2027 (Annexure-7).

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As per the Consent to Operate issued by the RSPCB, the plant is permitted to use total 150 KLD of fresh water out of which 100 KLD of water for industrial purposes and 50 KLD for domestic use.

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Records made available by the industry indicate that from April to August 2025, average daily groundwater abstraction was 65.9 KLD, with a maximum of 119 KLD and a minimum of 20.6 KLD. The month-wise abstraction averages are as follows:

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Further, the industry has established one Piezometric Well for monitoring the level of ground water. As per the data provided by the representative the levels for the current Financial Year are as under: -

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O.A. No.93/2025(CZ) Ravinder Raghu Yadav Vs. Shree Cement, through Chief Executive Officer & Ors.

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There is no direct water requirement in the process of manufacturing of Cement.

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Verification during inspection confirmed that water for industrial purpose is used only as make-up water in cooling towers. The cooled water is recirculated for machine cooling, and no process wastewater is generated. The unit therefore maintains a Zero Liquid Discharge (ZLD) system.

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The domestic sewage is generated from utilities, kitchen/canteen within the premises is treated in a Sewage Treatment Plant (STP), and the treated water is reused for horticulture within the plant premises.

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The Consent to Operate (CTO) issued on 21.09.2021 (Annexure-4) authorizes the generation of 10 KLD of domestic sewage. As per the CTO conditions, all domestic wastewater generated is required to be treated to prescribed standards in Sewage Treatment Plant and utilized for plantation and horticulture purposes within the premises.

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During inspection it was observed that the Sewage Treatment Plant is operational, and the treated domestic sewage generated is being utilized for plantation across the premises.

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Flow meter was found installed only at outlet of the STP.

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As per the records made available by the industry, the range of outflow of treated water from STP is from 0 to 10 KLD. The average outflow of the treated water from Sewage Treatment Plant for current financial year is as under:

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During the inspection, sample of treated water from Sewage Treatment Plant was collected and was analysed by the laboratory of Rajasthan State Pollution Control Board, Bhiwadi. As per the analysis results, the treated water was found to be conforming with the standards prescribed under Consent to Operate, however it was non-confirming to the standards to be achieved w.r.t the office order dated 08.08.2023, issued by

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O.A. No.93/2025(CZ) Ravinder Raghu Yadav Vs. Shree Cement, through Chief Executive Officer & Ors.

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RSPCB in compliance with the directions of CPCB dated 21.04.2015.

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Further, the State Pollution Control Board has been collecting water samples from the borewell established within the industry i.e. M/s Shree Cement Limited regularly under the National Water Monitoring Program of Central Pollution Control Board. The water sample collected is being analysed by the State Board. The historical data for last 2 years was referenced from the State Board for verification of the levels of TDS and Fluoride.

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The results are as under: -

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Further, as alleged in the petition, neither any generation of industrial effluent nor any discharge of industrial effluent in to the borewells was observed by the Joint Committee.

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O.A. No.93/2025(CZ) Ravinder Raghu Yadav Vs. Shree Cement, through Chief Executive Officer & Ors.

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C. Observations regarding Air Pollution: -

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The primary allegation raised in the application pertains to air pollution allegedly caused by the use of mustard husk and other agricultural residues as fuel in the cement manufacturing process. It has been alleged that the unit, despite being located within the National Capital Region (NCR), a region subject to stricter environmental regulations is illegally burning prohibited materials such as farm residue and mustard husk. This practice is claimed to result in the release of substantial volumes of toxic smoke, thereby causing a significant deterioration in ambient air quality. The emissions are further alleged to be contributing to irreversible adverse impacts on public health, biodiversity, and local agricultural productivity. Observations made regarding the same are as under:

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As per Direction No. 63 dated 18.05.2022 and subsequent amendments in Direction No. 65 dated 03.04.2023 issued by the Commission for Air Quality Management in NCR and Adjoining Areas, use of biomass fuels is permitted in industrial units located in NCR, excluding the jurisdiction of NCT of Delhi (Annexure - 13).

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The unit has obtained Consent to Operate from the State Pollution Control Board 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 for use of Biomass and PNG as fuel in the industry. Details of the CTO are as under:

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The industry representative informed that although consent has been obtained for both Biomass and PNG, only Biomass is being used as fuel in both Hot Air Generators (Furnace) currently.

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The nature of raw materials and the manufacturing process inherently results in air emissions, as materials like pond ash,

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O.A. No.93/2025(CZ) Ravinder Raghu Yadav Vs. Shree Cement, through Chief Executive Officer & Ors.

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fly ash, and clinker are prone to becoming airborne with minimal disturbance.

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It is important to note that biomass burning is not practiced year-round. It was informed that HAGs are used particularly when moisture content in the raw materials is high. On the day of inspection, no biomass burning was observed.

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To control fugitive emissions and airborne particulate matter, the industry has established dedicated covered storage sheds/silos for both raw materials and finished goods. The storage capacities as informed during the inspection, are summarized below: -

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Fly Ash and Clinker are directly unloaded into silos using trucks/dumpers. Other materials like Gypsum and Pond Ash are stored in covered sheds with RCC flooring.

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Material conveyance to the cement mill is via conveyors and air conveyors, however the conveyance of raw material stored in sheds to the feeding bays is manual.

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During inspection the Joint Committee observed that, most sheds are equipped with flexible curtains (rubber and plastic layered) at openings for truck movement. However, some sheds lack coverings/have damaged coverings, exposing materials to flow of air.

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O.A. No.93/2025(CZ) Ravinder Raghu Yadav Vs. Shree Cement, through Chief Executive Officer & Ors.

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Water sprinklers are installed along boundary walls and internal roads near storage areas. However, some sprinklers were non-functional.

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To control fugitive emissions during raw material unloading and transfer, the unit has installed 54 Bag Filters (Bag Houses) located across:

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Raw material unloading / handling areas

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Production process units

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Packaging sections

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Miscellaneous transfer points

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Conveyor belts are covered, and suction hoods are provided at transfer points to capture dust.

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In the matter of emissions from the grinding process, the industry has provided Bag House followed by a Stack having height more than 30 m for control of air emissions and safe release of particulate matter emissions.

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During the inspection both the Cement Mills were operational, while the HAGS (furnaces) were non-operational.

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The safe and adequate infrastructural monitoring facility was found established at both the mills. The source emission monitoring for both the mills was carried out during inspection dated 12/09/2025. Monitored data of source emission is as under: -

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On the basis of above monitored source emission data, it is inferred that the average concentration of Particulate Matter is within the prescribed limit.

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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 with the assistance of RSPCB at total 5 locations for the prominent air pollutant parameters i.e. PM 10, SO2 and NOx. Out of the 5 locations, 4 locations were inside the

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O.A. No.93/2025(CZ) Ravinder Raghu Yadav Vs. Shree Cement, through Chief Executive Officer & Ors.

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premises of the industry, whereas one location was outside the premises of the industry.

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The ambient air quality monitoring stations were installed at up-wind, down-wind and cross wind directions. One specific station was installed near the unloading area. The monitored results are as under:

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On the basis of above monitored ambient air quality data, it has been observed that the average concentration of PM10 (24hour basis) was found in the range of 87 µg/m3 to 123 µg/m3. Out of 5 locations the concentration of PM10 was found exceeding the limit of 100 at 3 locations i.e. Rooftop of Colony (Pinku Ji Nandram Pur Bas) main gate of Industry (downwind direction), Main Gate of Industry & Near Unloading area in the premises of industry.

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The concentration of primary gaseous pollutants i.e. SO2 and NOx were found to be within the limit at all the monitored locations.

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The industry has installed 4 packing lines for packaging of cement into HDPE bags with each packer having capacity of packing 180 Tonn of Cement per Hour.

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O.A. No.93/2025(CZ) Ravinder Raghu Yadav Vs. Shree Cement, through Chief Executive Officer & Ors.

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The packaging section is housed in a close shed and for control of fugitive emissions during the packaging, each packer has been provided with bag filters.

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Plant has installed 1 DG set of 750 KVA capacity as alternate source of power, with adequate stack height and acoustic enclosure. The DG set is CPCB IV+ emission standard compliant.

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It is noteworthy that earlier industry was having a DG set of 1000 KVA for which Consent to Operate was obtained from the State PCB, but it has been replaced by DG set of 750 KVA without obtaining prior consent for the change.

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During visit, dust emissions were not observed near the storage sheds / silos and manufacturing process, however, fugitive dust emissions were observed in packaging section and also some part of the shed of the packaging section was found damaged.

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D. Observations from the Online Continuous Emission

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Monitoring System: -

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The unit has installed Continuous Emission Monitoring Systems (CEMS) for monitoring Particulate Matter (PM) emissions at both stacks attached to the Cement Mills.

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The CEMS installations are connected to the servers of the Central Pollution Control Board and the Rajasthan State Pollution Control Board.

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Due to an issue with the RSPCB server, data for the current financial year was referenced from the industry's CPCBconnected portal.

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Based on the data retrieved, the emission ranges from Cement Mill-1 varied between 0.43 mg/Nm³ and 24.26 mg/Nm³, with an average emission level of 9.72 mg/Nm³. For Cement Mill-2, the emission range varied between 0.34 mg/Nm³ and 12.91 mg/Nm³, with an average emission level of 7.40 mg/Nm³.

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All observed emission levels are well within the prescribed standard limit of 50mg /Nm³.

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Daily readings of OCMS system are annexed at Annexure - 21.

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E. Observations regarding Hazardous Waste: -

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The unit has obtained valid authorization under the Hazardous and Other Wastes (Management and

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O.A. No.93/2025(CZ) Ravinder Raghu Yadav Vs. Shree Cement, through Chief Executive Officer & Ors.

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Transboundary Movement) Rules, 2016, for the generation, collection, storage, transportation, and disposal of hazardous waste, specifically Used or Spent Oil (Category 5.1 of Schedule I). The authorization has been issued by the Rajasthan State Pollution Control Board (RSPCB). The hazardous waste generated is either disposed of through co-processing in cement kilns or sold to registered recyclers. Details of Hazardous waste authorization are tabulated below:

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The used/spent oil is primarily generated from DG set and plant machinery, and is stored at a designated hazardous waste storage site within the plant premises. A hazardous waste display board is installed at the main entrance gate.

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The representative provided Form-3 as per the Hazardous & Other Waste (M&TM) Rules, 2016. As per Form-3, the details of waste generation/disposal in current FY are as under:

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The representative of unit also provided a copy of Form-4 i.e. Annual Return submitted to the State Pollution Control Board. As per the form the total hazardous waste generated in previous year i.e. 2024-2025 was 4370 Litre and out of this 3570 Litre of waste was disposed through M/s Shiv Shakti Oil & Lubricants, Chopanki District Khairthal-Tijara, a recycler

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O.A. No.93/2025(CZ) Ravinder Raghu Yadav Vs. Shree Cement, through Chief Executive Officer & Ors.

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registered with RSPCB whereas 800 Litre was the closing stock as on 31.03.2025.

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F. Other Observations: -

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From the details provided by the industry regarding the production achieved in last 4 years, the production has been within the permissible limits.

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During the visit the Committee observed that the unit has developed and maintained green belt inside as well as the outside of the plant premises. As per the information provided by unit officials, out of 1,04,426 sq. plant area, greenbelt developed on about 36% of total plant area. It was informed that more than 7500 plants are there in the premises and whereas near about 8500 plants have been planted outside the premises.

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All the internal roads and connecting roads to nearest metalled road are made of concrete to reduce the fugitive emissions during vehicular movement.

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During inspection, it was informed that manual brooming as well as road sweeping through mechanical sweepers is carried out. For mechanical sweeping, industry has total 3 nos. of mechanical sweepers, 2 small sweepers and 1 trolley mounted sweeper.

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Joint committee also discussed with Dr. Rahul Goyal, Medical Officer, Community Health Centre, Tapukara Distt. KhairthalTijara about the concerns regarding health complications and other impacts raised by the applicant. As per details provided, various diseases are due to bacterial, viral infections, allergic, smoking, dust and other lifestyle changes etc.

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O.A. No.93/2025(CZ) Ravinder Raghu Yadav Vs. Shree Cement, through Chief Executive Officer & Ors.

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8. Recommendations of the Joint Committee:

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i. The existing Sewage Treatment Plant (STP) shall be adequately maintained to ensure effective treatment of domestic sewage in compliance with the standards prescribed under the RSPCB Office Order dated 08.08.2023. If required, the unit shall undertake upgradation of the STP to achieve compliance with the latest norms.

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ii. A metering arrangement to monitor the influent quantity at the Sewage Treatment Plant shall be established.

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iii. Manual raw material handling and transfer shall be discontinued. All materials shall be conveyed through covered conveyor systems only.

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iv. All raw material storage sheds shall be covered with rigid sheets on three sides and at the top, with concrete flooring. The open side used for loading and unloading shall be fitted with double-layer flexible curtains to minimize dust emissions.

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v. The existing clinker unloading bays shall be upgraded to fully enclosed domes constructed with rigid materials on all sides. The design shall ensure that unloading vehicles are completely housed within the dome and that unloading operations are carried out entirely inside the enclosed structure to prevent the escape of fugitive emissions into the ambient air. The domes shall also be equipped with adequate air pollution control systems to effectively capture and control emissions generated during the unloading process.

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vi. Gypsum handling practices shall be improved. Spillage outside the designated storage shed shall be prevented, and overall material management practices shall be strengthened.

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vii. The unit shall ensure that no raw materials are stored in open areas outside the designated covered sheds.

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viii. The operation and maintenance of all bag houses shall be carried out strictly as per prescribed schedules to ensure consistent air pollution control performance.

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ix. Fugitive dust emissions were observed in the packaging section, and part of the shed was found damaged. The unit shall undertake immediate repair of the damaged portion and ensure regular cleaning of the area using mechanical sweepers.

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x. The water sprinkler system requires improved maintenance. The unit shall automate sprinkler operations to reduce manual dependency, increase operational frequency based on ambient

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O.A. No.93/2025(CZ) Ravinder Raghu Yadav Vs. Shree Cement, through Chief Executive Officer & Ors.

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conditions, and expand the number of sprinklers to cover additional areas.

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xi. Regular cleaning of all internal roads, truck parking areas, and vehicle movement zones shall be ensured, along with effective dust suppression through water sprinkling.

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xii. Manual brooming shall be discontinued. All sweeping and cleaning activities shall be carried out using mechanical sweepers. Additional mechanical sweepers should be procured to ensure full coverage of the premises.

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xiii. The unit shall obtain Consent to Establish and Consent to Operate from the RSPCB for the existing 750 KVA DG set, in accordance with applicable regulatory requirements.

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xiv. As the plant is located within the Delhi NCR region, the unit shall strictly adhere to directions issued from time to time by the Commission for Air Quality Management (CAQM).

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xv. The management shall ensure the mandatory use of appropriate personal protective equipment (PPE) such as masks, gloves, gumboots, helmets, earplugs and goggles by all workers during material handling and process operations. Periodic training shall be conducted to ensure adherence.

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xvi. The unit has undertaken efforts towards plantation and greening, with the greenbelt presently covering approximately 36% of the total plant area. The unit shall further enhance plantation activities both within and outside the premises.”

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Reply has been filed by the Respondent/Project Proponent and it is submitted that it can be observed from the report of the Joint Committee that as per the mandate of this Tribunal contained in the order dated 29.07.2025, none of the allegations made by the Applicant has been found to be correct. However, the Joint Committee made recommendations in its report which were required to be complied with by the Respondent in addition to the norms laid down by the authorities from time to time for meeting the environmental obligations by the Respondent and that the Joint Committee, while finding no violation on part of the Respondent has made certain recommendations as a matter of abundant caution and for further strengthening

¶190

¶191

O.A. No.93/2025(CZ) Ravinder Raghu Yadav Vs. Shree Cement, through Chief Executive Officer & Ors.

¶192

environmental safeguards, the said recommendations do not arise out of any violation or any non-compliances attributable to the Respondent. It is stated that the Respondent is in process of complying with the recommendations made by the Joint Committee and has already taken steps towards compliance of the recommendations made therein. Respondent has prepared a chart for the convenience of this Tribunal, which is reflecting the present status of compliance of the recommendations and the Respondent has placed a purchase order for installing and commissioning of an upgraded STP on 29.9.2025 and the work of installation and commissioning of upgraded STP is in progress and is expected to be completed within another 1 month.

¶193

The Respondent/Project Proponent has submitted the compliance report in a following manner:-

¶194

¶195

O.A. No.93/2025(CZ) Ravinder Raghu Yadav Vs. Shree Cement, through Chief Executive Officer & Ors.

¶196

¶197

O.A. No.93/2025(CZ) Ravinder Raghu Yadav Vs. Shree Cement, through Chief Executive Officer & Ors.

¶198

In this way, the perusal of the compliance report reveals that the recommendations as narrated by the members of the Committee has been complied with by the Project Proponent, for construction of the STP, the order has been placed and the work is in progress and same will be completed within a short time.

¶199

We have also examined the report submitted by the Joint Committee and found that no other violations have been reported. Accordingly, we direct the Respondent/Project Proponent to take necessary steps for completion of the STP within two months according to the parameters laid down by the Central Pollution Control Board at scientifically identified suitable locations and ensure that no untreated water be discharged into the open land and environmental norms must be observed according to rules.

¶200

With these observations, the Original Application No.93/2025(CZ)

¶201

stands disposed of .

¶202

Sheo Kumar Singh, JM

¶203

Sudhir Kumar Chaturvedi, EM

¶204

04^th February, 2026,

¶205

Original Application No.93/2025(CZ) AK

¶206

¶207

O.A. No.93/2025(CZ) Ravinder Raghu Yadav Vs. Shree Cement, through Chief Executive Officer & Ors.

Ravinder Raghu Yadav v. Shree Cement through Chif Executive Officer

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Ravinder Raghu Yadav v. Shree Cement through Chif Executive Officer

Case brief

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