1.    Brief Legislative History

The Commission for Air Quality Management in National Capital Region and Adjoining Areas Ordinance, No. 13 of 2020 was initially promulgated by the President on the 28th of October 2020. The Ordinance provided for the setting up of a body to coordinate, research into, identify and resolve problems concerning air quality and other related matters in the region. In accordance with the provisions of Sections 3(1) and 3(2) of the aforementioned Ordinance, the Ministry of Environment, Forest and Climate Change issued a notification on the 5th of November 2020 constituting the Commission for Air Quality Management in National Capital Region and Adjoining Areas (“CAQM”) and appointing its members.[1] On 12th March, 2021, the Ordinance lapsed and on April 13th, the President promulgated another ordinance to extend the operation of the same provisions.

In the meanwhile, the Commission for Air Quality Management in National Capital Region and Adjoining Areas Act, No. 29 of 2021 (“the Act”) was passed by the Parliament and received Presidential assent on the 12th of August 2021.[2] Since this Act of Parliament approved the earlier Ordinance, it was deemed to have been in effect since the 13th of April, 2021.

2.    Government Policy and Objectives of the Legislation

According to IQAir, a Switzerland-based company that monitors air quality worldwide, Delhi is the world’s most polluted major city as of February 2022.[3] There is no doubt that pollution across major cities in India are worsening with time, but the situation in the National Capital Region is by far the unhealthiest and most worrisome. The mounting pressure on the Central Government to take action to address this severe pollution crisis has culminated in several measures, one of which is the enactment of this piece of legislation.

The Preamble of the Act clearly identifies the objectives sought to be achieved which are the ‘better coordination, research, identification and resolution of problems related to the air quality index’ and incidental, connected matters.[4] The use of the word ‘better’ can be interpreted as an admission or recognition by the Parliament that the present measures in place to address the pollution issues in the region are insufficient. There are several parts of the statute itself that show that existing measures before the establishment of the CAQM were deemed to be ineffective. For instance, Section 3(6) of the Act grants wide powers to the CAQM and states that no other body, authority, individual or committee shall have any power or jurisdiction in the matters covered under the Act.[5] Moreover, in case there is any conflict between the CAQM and the Central Pollution Control Board, the state governments of Haryana, Punjab, Uttar Pradesh and Rajasthan, the Government of Delhi, the State Pollution Control Boards of the aforementioned states or any other statutory authority, the order or direction of the CAQM shall prevail. This provision clearly reflects the legislature’s intention to establish a new authority that is vested with the required mandate to fulfil policy objectives.

Another critical outcome of this enactment was the dissolution of the Environment Pollution (Prevention and Control) Authority for the National Capital Region under Section 29 of the Act.[6] The Environment Pollution (Prevention and Control) Authority (“EPCA”) was the apex pollution control body in the NCR, established in 1998 and was thereby replaced by the CAQM. At first glance, the key difference appears to be the inclusion of the term ‘adjoining areas’ in the newly constituted body. Clearly, there is a widening of the jurisdiction to support a more comprehensive policy approach to pollution control since pollution in nearby regions is bound to impact the air quality in the national capital. According to Section 2(1)(a) of the Act, ‘adjoining areas’ refers to the areas in the states of Uttar Pradesh, Haryana, Punjab and Rajasthan which adjoin the NCT of Delhi which have sources of pollution that adversely impacts air quality in the National Capital Region.[7]

The legislative intent and policy behind the enactment are therefore clear. The Act aims to address the deteriorating air quality levels in the regions aforementioned by constituting a body that is vested with wider jurisdiction and powers than its predecessor and other bodies empowered to control pollution in the regions.

3.    Committee Reports

The Department-related Parliamentary Standing Committee on Science & Technology, Environment & Forests under the Chairmanship of Anand Sharma presented the 316th Report before the. Rajya Sabha. The Report was on the Air Pollution in Delhi and National Capital Region and was presented in the Rajya Sabha on 7th August 2018. The Committee analysed the steps taken by the Governments of States around the National Capital Region such as Punjab, Haryana, and Uttar Pradesh to reduce pollution and improve the air quality within Delhi and its adjoining areas. Based on these observations, the Committee made further recommendations to improve the effectiveness of these measures and also further suggested additional steps to be adopted to combat the rising levels of air pollution in the Capital.

In its report, the Committee observed that although neighbouring states had imposed penalties on farmers for burning stubble, the respective governments of the States have failed to implement these provisions.[8] The Committee further noted that the lack of sensitivity of the State Governments to this issue has led to the further deterioration of the air quality in Delhi. The neighbouring states also failed in ensuring that agricultural waste is disposed in a scientific manner which further aggravated the pollution in Delhi. Furthermore, with the increase in vehicular load within the Capital and the surrounding states, there was an exponential increase in the amount of particulate matter in the air which posed a severe health hazard to the residents of Delhi.[9] The Committee urged both, the State and Central Governments to recognise the urgency of the issue and bring into effect more efficient schemes and policies to tackle the depleting air quality in Delhi. 

The report highlighted the urgent need for a body whose powers transcended state boundaries and had full time members who specialised in this field to better combat the degradation in air quality in and around the National Capital Region. One of the primary shortfalls of the EPCA was that it was incapable of enforcing its directions and could merely request state governments to comply with them. The EPCA failed to impose any penalties or initiate proceedings against governments for their failure to comply with the EPCA’s directions and orders. Based off these conclusions, the CAQM was given a broader mandate with certain exclusive and overriding powers to increase accountability and ensure better enforcement of the Commission’s directions and orders.

4.    Political and Legal Issues Faced in Enacting the Law

The CAQM was formed by a Presidential Ordinance dated 28 October 2020. Article 123 of the Constitution states that the ordinance has the same effect as that of an Act of the Parliament however the ordinance needs to be presented before the Parliament in the form of a Bill within 6 weeks from the assembly of the Parliament.[10] After the expiry of the six-week period, the ordinance seizes to exist[11] and therefore becomes inoperative.

The CAQM ordinance ideally should have been presented before the Parliament during the 2021 Budget Session however, the Bill was never taken up for discussion due to which the ordinance lapsed and the CAQM was dissolved on 13th March 2021.[12] The dissolution was sudden to the point that the members of the commission only found out about the same through reports in the media and news outlets.[13] The Union Environment Ministry had completed the requisite formalities and submitted the paperwork required to give legal backing to the Commission to the Union Cabinet.[14] However, the CAQM was dissolved anyway.   

The Centre faced strong opposition from the farmers over the controversial farm laws in 2021. The Government therefore attempted to pacify the protestors by committing to the removal of the provision which penalised the farmers for burning stubble despite it being a major contributor to the reduced air quality. The Ordinance was repromulgated on 13th April 2021 with the aforementioned change being incorporated in Section 14 of the Ordinance. By means of the new Ordinance, the CAQM can impose and collect environmental compensation from the farmers at a rate and manner which may be prescribed.[15] These changes were subsequently adopted by the Legislature as well when it passed the Commission for Air Quality Management in National Capital Region and Adjoining Areas Bill.

5.    Conclusion

The establishment of the CAQM is certainly a step forward in the attempt to combat air pollution in the National Capital Region and restore the quality of the air. The CAQM however, does have certain major shortcomings with the most glaring issue being the lack of representation of local governments and the absence of certain essential ministries such as health and labour ministries from the Commission.[16] Although many critics have said that the CAQM is merely a duplication of previously existing efforts and is bound to fail, the true effectiveness and performance of the body can only be assessed with time.

 



[1] Ministry of Environment, Forests and Climate Change, S.O. 4014(E) (Notified on November 5, 2020).

[2] The Commission for Air Quality Management in National Capital Region and Adjoining Areas Act, 2021, No. 29, Acts of Parliament, 2021 (India).

[3] IQAIR, Air quality and pollution city ranking, IQAIR, https://www.iqair.com/in-en/world-air-quality-ranking (Feb. 5, 2022).

[4] The Commission for Air Quality Management in National Capital Region and Adjoining Areas Act, 2021, Preamble, No. 29, Acts of Parliament, 2021 (India).

[5] The Commission for Air Quality Management in National Capital Region and Adjoining Areas Act, 2021, §3, No. 29, Acts of Parliament, 2021 (India).

[6] The Commission for Air Quality Management in National Capital Region and Adjoining Areas Act, 2021, §29(1), No. 29, Acts of Parliament, 2021 (India).

[7] The Commission for Air Quality Management in National Capital Region and Adjoining Areas Act, 2021, §2(1)(a), No. 29, Acts of Parliament, 2021 (India).

[8] Parliamentary Standing Committee on Science & Technology, Environment & Forests, Three Hundred and Sixteenth Report, Report on Air Pollution in Delhi and National Capital Region 12 (2018).

[9] Id at 35.

[10] India Const. art. 123.

[11] Id.

[12] Centre for Policy Research, The CAQM Act, 2021: An Overview 2 (2021).

[13] Special Correspondent, Air Quality Commission Bill for National Capital Region Cleared, The Hindu (Aug. 4, 2021) https://www.thehindu.com/news/national/lok-sabha-passes-air-quality-commission-bill-for-ncr-adjoining-areas/article35723205.ece

[14] Id.

[15] The Commission for Air Quality Management in National Capital Region and Adjoining Areas Ordinance, 2021, § 15 (Apr. 13, 2021).

[16] Supra note 10 at 3.


About the Author: This post is prepared by Rithwick Ganesh & Yash Chadha, Law Students from Christ (Deemed to be) University, Bangalore. They can be reached at rithwick.g@law.christuniversity.in & yash.chadha@law.christuniversity.in respectively.

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