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NGT Order 108 of 2020
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BEFORE THE HON’BLE NATIONAL GREEN TRIBUNAL SOUTHERN ZONE, CHENNAI. Original Application No. 108 of 2020(SZ) Tribunal on its own motion Suo Motu initiated proceedings based on the News item published in Vikatan E-Magazine edition dated 09.07.2020 Under the caption “Coonoor Misery: Increasing waste in River Water! — Elephants looking for good water’. Vs The Principal Secretary to Government, Public Works Department, Secretariat, Fort St. George, Chennai — 600 009 & 7 others. ...Respondents. INDEX ‘S.No __ Description Page No. 4, [REPORT FILED ON BEHALF OF THE| 1-20 RESPONDENTS - TAMIL NADU POLLUTION CONTROL BOARD. Filed by Thiru. C. Kasirajan, Advocate, Chennai.FURTHER REPORT OF THE DISTRICT ENVIRONMENTAL ENGINEER, TAMIL NADU POLLUTION CONTROL BOARD, UDHAGAMANDALAM ON THE REMARKS OF THE HON’BLE NATIONAL GREEN TRIBUNAL (SZ) DURING THE HEARING HELD ON 04.01.2021, IN O.A. No.:108 OF 2020 (SZ) Backgroun As directed by the Hon'ble National Green Tribunal (SZ) during its hearing on 25.09.2020, the Response of the District Environmental Engineer, TamilNadu Pollution Control Board, Udhagamandalam on the allegations in the News Paper Report were submitted. During the hearing on 04.01.2021, the Hon'ble National Green Tribunal (SZ) took the responses of Environmental Engineer, TamilNadu Pollution Control Board, Udhagamandalam in Record, and made the following orders: 6. The learned counsel appearing for the seventh respondent submitted that some steps are being taken and they have already filed the action plan for remedying the situation. But we have not received the same. The office is directed to verify and place the same before this Tribunal on the next hearing dete. The Pollution Control Board is also directed to file further action taken report for non- implementation of the Solid Waste Management Rules, 2016 in Coonoor Municipality as has been directed by this Tribunal in several earlier cases and also of the non- compliance of the directions given by the Principal Bench of the National Green Tribunal in 0.A.No.606 of 2018 before the next hearing date. 7.Even in the report it is mentioned that whatever steps that have being taken by them will only cater to the possibility of treating 60% of the sewage generated in that area. There is no specific action plan for treating the balance sewage of 40% in an effective manner so as to avoid it is being discharged into the river as alleged in the newspaper report.& When this was pointed out, the leamed counsel appearing for the seventh respondent submitted that he will come with a complete action plan if some time is granted. 9. The Coonoor Municipality as well as Pollution Contro! Board and also the Committee are directed to submit their report to this Tribunal before the next hearing date viz, 3.2.2021 by efiling at
[email protected]
. 10. The Registry is directed fo communicate this order through e-mail immediately to the Members of the Committee, Coonoor Municipality and also the Pollution Control Board so as to enable them to comply with the direction of this Tribunal.” In response, this further report is submitted for the consideration of the Hon'ble National Green Tribunal (SZ). Implementation of Solid Waste Management Rules, 2016 A, Management of Currently generated Solid Wastes: Currently, Coonoor Municipality is generating Municipal Solid Waste to the tune of 14 MT/Day, out of which 8.3 MT/Day is wet waste. Of this, 7 MT/Day is collected and subjected to composting operations, 4 MT/Day at Micro Composting Centre, as well as for through Wind Row Composting at the erstwhile IL & F S Shed, 1 MT/day, non-vegetarian wastes processed through the equipment installed and 2.0 MT/Day of wet waste is composted in four Parks and another 10 on-site locations. 1.0 MT/Day of wet waste generated by 18 Bulk Waste Generators (BWG) and 0.80 MT/Day of wet waste generated by 630 House-holds are managed by themselves, at the point of generation itself.Out of the 5.7 MT/Day of Dry waste generated, 0.7 MT/Day of recyclable waste is sold-out at house hold level; the remaining 5.0 MT/Day of dry wastes cre brought out to the Resource Recovery Centre, sorted and the recyclable wastes are baled, and despatched to recyclers. The non-recyclable wastes such as un- usable cloth waste, used diapers and sanitary napkins are burnt in the controlled high temperature burners installed at the Resource recovery Park at Ottupattarai There are two numbers of High temperature burners installed, one of 600 kg Capacity and another of 1500 kg Capacity. Generally, the management of currently generated Solid Waste by Coonoor Municipality is satisfactory. The Photographs showing the management of Solid Waste Management in Coonoor Municipality are submitted for the perusal of the Hon'ble National Green Tribunal (SZ). B, Old Dumpsites in Coonoor Municipality: In Coonoor Municipality, legacy waste is found in the old dump locations. viz. Ottupattarai dump yard, dumping yard at the back side of the erstwhile { L & F S Processing shed, and the dumping along the sides of Vasampaliam Road. The total quantity of waste was estimated to be in the estimated as 7000 MT at a bulk density of around 0.7. However, subsequent to the fire occurred during the year 2017, substantial quantity of waste was destructed, and the present quantity of the waste is reassessed at 3000 MT by Coonoor Municipality. This wastes need to be subjected to processing/ bio-mining for the separation of the other components such as plastics, glass, rag present in the waste and to dispose them appropriately, and the soil separated has to be disposed as manure or as soil conditioner. C. Show Cause Notice for levying EC: Under the provisions of the Solid Waste Management Rules, 2016, the old dump sites need to be remediated within five years of Notification ofRules, viz. 7" April, 2021. However, the Hon’ble National Green Tribunal (PB) have ordered that Environmental Compensation be levied on Local Bodies for not commencing the remediation of old dumpsites after 1 April, 2021. The same is also emphasized by the Hon’ble National Green Tribunal (SZ) in its previous orders in this case and another case involving Coonoor Municipality. Hence, a show cause notice was issued instructing Coonoor Municipality as to why Environmental Compensation should not be levied, by District Environmental Engineer, Udhagamandalam in proceedings dated 12" January, 2021. The Commissioner, Coonoor Municipality furnished reply vide letter dated 1* February, 2021, wherein the action taken for remediation of dumpsites are elaborated. The veracity of the measures taken are verified through field inspection on 1* February, 2020. The reply furnished is under consideration, as to whether proceeded with the levy of Environmental Compensation or proceeded further on levying of Environmental Compensation. The Copy of the show cause notice and the reply to the show cause notice are submitted herewith for the kind peruse! of the Hon’ble National Green Tribunal (SZ). D. Measures taken for the processing of Legacy Waste: Coonoor Municipality has fabricated a mechanized Selver for the purpose of processing of the legacy waste. The same is found to be stabilized and could be operated at the rate of around 3 MT/Hour, thereby a maximum quantity of 30 MT/day of legacy waste could be processed. It is found during the inspection on 1* February that about 180 MT of legacy waste is processed. Coonoor Municipality has reported that the remaining quantity of waste could be remediated/ processed before 30" June, 2021. It is submitted, that the remaining waste up to around 3000 MT could be processed, before 30" June, 2021, provided the process is not interruptedwith rain. In as much as there is no rainy season till May, it is possible for Coonoor Municipality to meet the Time Line. Action Plan for preventing the entry of Sewage Coonoor Municipality has formulated a road-map for intercepting the sewage out-falls entering in to the River. As per the road-map, a detailed study is instituted to identify the discharges into the water bodies, their quality and quantity, availability space for providing decentralized treatment system, suitable technologies for treatment, and to estimate the CAPEX and OPEX for the scheme. The experts have carried out the reconnaissance survey on 29.01.2021, and the detailed investigation also started on 01.02.2021. The Final Report is anticipated in the first week of April, 2021 and the Proposal would be submitted to the Government by the third week of June 2021. The Project after technical and financial approval, would be completed in 9 months’ time. It is submitted that providing of under-ground sewerage system, by collecting the sewage generated from the households and the commerciai establishments, is expensive, as very huge money is spent on conveyance system, time consuming- taking more than five years to complete all the related works, causing much inconvenience to public such as road closure/ traffic diversion etc., and cumbersome, ie very difficult to execute in general, Particularly for hilly terrain like Coonoor Municipality. Therefore, as an alternate, it is decided that the outfalls in the river be intercepted, diverted to a nearby location, where adequate land is available for the construction of treatment system and then the treated sewage would be discharged back in to the River,Taken by Coonoor Muni Report Coonoor Municipality in their earlier report filed before the Hon‘bie National Green Tribunal (SZ) during the previous hearing in 0.A. No.: 108 of 2020, an action plan was given. Of the above, the survey of Commercial establishments discharging sewage in water bodies completed, so cause notice is issued to such 109 establishments. The replies received are under scrutiny. It is proposed to issue the second notice for demolition / celling of such establishment during the first week of February 2021. Further action will be taken in accordance with Law, under the provisions of the Prohibition of Manual Scavengers and their Rehabilitation, Act, 2013. In the case of households, survey has been completed, notices are being issued to those house hold not having a septic tank / soak pit, but having space, and assured to complete the action before 31.03.2021. Fecal idge Sewage treatment Plant It is submitted that Coonoor Municipality has already commenced the construction of the Fecal Sludge Sewage treatment Plant, for the further treatment of the sludge from the Septic Tanks, at the premises of the Resource Recovery Centre. The works has been commenced and expected to be completed before December, 2021. Remarks of District Environmental Engineer The perusal of documents furnished by Coonoor Municipality and the observations made during the field inspection, the following inferences are arrived at. 1. The management of the solid wastes generated by Coonoor Municipality is found to be satisfactory.2. Coonoor Municipality has commenced the operation of processing of the legacy waste 3. The mechanized Seiver System fabricated for the purpose of carrying out the bio-mining/ processing of legacy waste is functioning satisfactorily. 4. The system could be used to process around 20 to 25 MT/Day of legacy waste, with 8 hours of operation. 5. Around 3000 MT of legacy waste could be processed till 30" June, 2021, provided there is no destruction of activities, due to rain. 6. The detailed study to identify the outfalls, quantify the discharges etc, is commenced. The Final Report could be ready by April, 2021, as planned. a . Availability of suitable, adequate area of land adjacent to the discharges/ interception points is key in formulating the schemes, in a cost effective manner, © . The construction of Fecal STP within the premises of Resource Recovery Centre at Ottupattarai has commenced. However, the same would not prevent the discharge of sewage in the River. Prayer: The District Environmental Engineer, Udhagamandalam, a member of the Joint Committee nominated by Tamil Nadu Pollution Control Board, do hereby submitsthis further Action Taken Report, as ordered by this Honourable Tribunal. It is kindly requested that the Honourable National Green Tribunal (SZ) to accept this further Action Taken Report and to pass appropriate orders the Honourable National Green Tribunal (SZ), considers deem and fit on the facts and circumstances of the issue. Encl: 1. Photographs 2. Show-Cause Notice dated 12.01.2021. 3. Reply for SCN dated 01.02.2021. UdhagamandalamOffice of the District Environmental Engineer, TamilNadu Pollution Control Board, Ground Floor, Block Il, Additional Collectorate Building, Finger Post, Udhagamandalam-643005. TAMILNADU POLLUTION CONTROL BOARD Proc. No.: DEEINLG/ 0.A. 606 of 2018/ NGT -PB/STP/2020-2 dated: 12.01.2021 Sub : TNPCB— Solid Waste Management — Hon'ble NGT orders in OA No. 606 of 2018 — Coonoor Municipality — Not Providing of STP and discharging of Sewage in to Water Bodies — Levying of Environmental Compensation — Show cause Notice — !ssued - Regarding. Ref 4. The Water (Prevention and Control of Pollution) Act, 1974, as amended. 2, Hon'ble National Green Tribunal (Principal Bench) orders dated 16.01.201920, 28.02.2020 and 02.07.2020 in O.A No. 606 of 2018. 3. Green Tribunal (Southern Zone) order dated 04.09.2020 in O.A. No Hon'ble National.: 203 of 2017. 4, Green Tribunal (Southern Zone) order dated 04.09.2020 in O.A. No Hon'ble National.: 108 of 2020. Whereas the Water (Prevention and Control of Pollution) Act, 1974, as amended in 1988, was passed by the Parliament, among other things, for the prevention and control of water pollution and the maintaining or restoring of wholesomeness of water. Whereas Section 24 of the Act, prohibits for the use of any stream or well for the discharge of any polluting matter in to it.Whereas, the Hon'ble National Green Tribunal (Principal Bench) vide orders in OA No. 606 of 2018 has ordered among other things that the commencement of STPs shall be by 31.03.2020 and Compensation is payable for failure to do so at the rate of Rs. 5 lakh per month per STP by concerned Local Bodies/States (in terms of orders dated 28.08.2019 in O:A. No. 593/2017 and 06.12.2019 in O.A. No. 673/2018) w.e.f. 01.04.2020. Whereas Coonoor Municipality has not commenced the works related to the establishment of Sewage treatment Plant till 31.12.2020 and the, sewage from the municipal areas is entering in to Coonoor River and other streams. Whereas the Hon'ble National Green Tribunal (Southern Zone) in their order dated 01.09.2020 in O.A. No.: 203 of 2017 directed to ascertain the aspects of the orders passed by the Hon'ble National Green Tribunal (Principal Bench) in O.A. No. 606 of 2018 and to file a further report. The Hon'ble National Green Tribunal (Southern Zone) has reiterated the same in their order dated 04.01.2021 in O.A.No. 108 of 2020. Therefore, it is proposed to levy Environmental Compensation to Coonoor Municipality for as ordered by the Hon’ble National Green Tribunal (Principal Bench) in O.A. No.: 606 of 2018 at the rate of Rs. OneFive Lakh (Rs. 5,00,000/-) per month starting from 01.04.2020 fill 31.12.2020 totalling Rs. Forty Five Lakhs (Rs. 45,00,000/-) the non-commencement of the works related to the stablishment of sewage treatment plant for the treatment of sewage generated from Coonoor Municipality, as ordered by the Hon'ble National Green Tribunal (Principal Bench) in O.A. No. 593 of 2017 and 673 of 2018 or to levy the Environmental Compensation, as per the Temiplate formulated by the Central Pollution Control Board. Therefore, the Commissioner, Coonoor Municipality, as the Executive Head of the Coonoor Municipality is hereby directed to show-cause, within seven days from the date of receipt of this notice, as to why an Interim Environmental Compensation of Rs. Forty Five Lakhs (Rs.45,00,000/-) should not be levied, for the period of April, 2020 to December, 2020, for the non-compliance of the orders dated 28.08.2019 in O.A. No. 593/2017 and 06.12.2019 in O.A. No. 673/2018 as ordered by the Hon'bleNational Green Tribunal (Principal Bench) in O.A. No.: 606 of 2018, and as to why the Final Environmental Compensation as per the Template formulated by Central Pollution Control Board should not be levied. It is informed that no reply is received within the prescribed time, it would be construed that you do not have any satisfactory explanation for the above said contravention, and further action would be proceeded in accordance with Law, with the available material. P.S. Livingston === District Environmental Engineer, TamilNadu Pollution Control Board, Udhagamandalam To The Commissioner, Coonoor Municipality, Coonoor. oe eran wya ee : - 7 l a ll ae = : oe eee ee LL aeFrom. 7 he The Commissioner, The District Environmental Engineer, Coonoor Municipality, TamilNadu Pollution Control Board, Coonoor. Udhagamandalam. H2/4 2020 dated: 0 1024, Sir, ‘Sub: TNPCB -Hon’ble NGT orders in OA No. 606 of 2018 - Coonoor Municipality - Not Providing of STP and discharging of Sewage in to Water Bodies - Levying of Environmental Compensation -— Show cause Notice - Issued - Reply furnished - Regarding. Ref: Your Office Proc. No. DEE/NLG/0.A, 606 of 2018/ NGT -PB/SWM/2020-2 dated: 12.01.2021. We are in receipt of your above referred show cause notice on 18.01.2021. We submit that we were asked to furnish the reply for the show cause notice within seven days from the receipt of the show-cause notice, Ie, before 25" January, 2021; The intermittent holidays, the works on COVID-19 Control and more importantly, the initiation of detailed study on the discharges into the river, feasibilities on its interception and providing decentralised sewage treatment schemes, technologies, Capital and Operational expenses for the Sewage Treatment Plant, which was scheduled during the last week of January, 2021, which was started with the reconnaissance survey on 29" January, 2021, has resulted a delay of one week in furnishing the reply. We kindly inform that that the delay in furnishing the reply may be condoned, and no adverse action may be proceeded for that reason. In this backdrop, the explanation of the Coonoor Municipality on the Show cause notice is furnished as follows, for your kind consideration and favourable further action:1, It is informed that Coonoor Municipality, even though formed before 150 years, the Municipality is always a fore runner in maintaining the health sanitation and a serene environment to its residents. It is pertinent to note that the local body was having protected water supplies, even before a century, which was not present in many of the urban local bodies at that time. 2. It is informed that Coonoor Municipality was having substantial population, well before five decades. The Local Body was having a Population of 30,690, as per 1961 Census, 38,007 in 1971, which rose to only 45,954 in 2011, after five decades, which ‘indicated a very low decadal population increase, comparing to the other Urban Areas of the State. One of the Important factor for this, is the non- availability of residential space in the Town, and the little residential space available were developed is much earlier, i.e well before fifty years. 3. As the Town has developed much earlier, i.e well before five decades, when the concept of urban planning has not emerged at all, the development was haphazardal. This has resulted in very narrow lanes/ streets, on its both sides the residences were built. 4. However, water bodies/ streams are flowing within the town limits, and there is flow in the water bodies, throughout the year, except in very rare drought conditions. The water bodies acted as disposal point for the domestic waste water generated from the households. Luckily there is no industrial activities within the territorial limits of Coonoor Municipality and as such there is no discharge of industrial effluents into the water body. The continual flow of adequate water in the river/ water bodies, which ensured dilution of the sewage discharged and the undulating terrain of the river, which facilitates natural aeration, have ensured that the quality of the water in the river is not adversely affected, and no odour or other nuisance is caused,6. Moreover, the availability of dedicated water sources for drinking Purposes of the Town, non-existence of major human settlement in the downstream, till the confluence with River Bhavani, the discharge of sewage in to the water bodies has not received any objection from any front. 7, However on the direction of the Hon'ble National Green Tribunal (SZ) in O.A. No.: 108 of 2020 and the continued advice of the District Collector and your good-self, Coonoor Municipality felt the Need to ensure that no untreated sewage Is let into the water body and to achieve this , we have prepared a road-map, which is given below: Ss. ‘Activity Scheduled | Present No.: Time Line | Status 1 [Instituting a Study Team to _| Second week | Identified identify the outfalls, quantify | ofJanuary | and work the same, feasibilities of | 2021 entrusted providing decentralised Sewage Treatment Plants, finalizing the Technologies, estimation of CAPEX and OPEX, 2 | Reconnaissance Survey Last week of [Completed | January on 29" 2021 January, 2021. 3 | Detailed investigation, First week of | Scheduled Collection of samples February, | to 2021. Commence on 3° February, 2021, 4 | Analysis of samples Second week = | of February, 2021. 5 | Preliminary Report with viable | Third week = schemes based on the of February, availability of suitable and 2021. adequate land 6 | Draft Project Report First week of = March, 2021 7 | Evaluation of Report and Third week = communicating the comments | of March2021. 8 | Final Report First week of, = April, 2021, 9 | Approval of the Council* First week of = June, 2021. _| 10 | Submission of Proposal to Third week = Government for Approval of June, 2021. 11 | Completion of the schemes | Nine months = from the financial approval for the schemes, * would be delayed due to the model Code of Conduct prevailing then. 8. It Is informed that in the submission made by Coonoor Municipality to the Hon'ble National Green Tribunal (SZ) during the previous hearing in O.A. No.: 108 of 2020, an action plan was given. Of the above, the survey of Commercial establishments discharging ‘sewage in water bodies completed, so cause notice is issued to such 109 establishments. The replies received are under scrutiny, It is proposed to issue the second notice for demolition / celling of such establishment during the first week of February 2021. Further action will be taken in accordance with Law, under the provisions of the Prohibition of Manual Scavengers and their Rehabilitation, Act, 2013. 9, It Is further informed that in the case of households, survey has been completed. Notices are being issued to those house hold not having a septic tank / soak pit, but having space. All efforts are being taken to complete the action before 31.03,2021 as committed. 10. As already stated in Para 7, a detailed study is instituted to identify the discharges into the water bodies, their quality and quantity, availability space for providing decentralized treatment system, suitable technologies for treatment, and to estimate theCAPEX and OPEX for the scheme. The experts have carried out the Teconnaissance survey on 29.01.2021, and the detailed investigation is scheduled to be started on 03.02.2021. The Final Report is anticipated in the first week of April, 2021 and the proposal would be submitted to the Government by the third week Of June 2021. The Project after technical and financial approval, would be completed in 9 months’ time. 11. It Is also informed that we have already commenced the construction of the Faecal Sludge Sewage treatment Plant, for the further treatment of the sludge from the Septic Tanks, at the premises of the Resource Recovery Centre. The works has been commenced and expected to be completed before December, 2021. 2a In this background the action of levying of environmental compensation for not providing sewage treatment plant as ordered by the Hon’ble National Green Tribunal (PB) in O.A. No.: 606 of 2018, would only act as a deterrent to the initiatives taken by Coonoor Municipality for in this front. 13, We wish to inform that till the orders of the National Green Tribunal (SZ) dated 1* September, 2020 is received, Coonoor Municipality is not aware of the orders of the liability of environmental compensation, for not providing of Sewage Treatment Plant by the local bodies, and once the same is known, all earnest steps were taken and the action is already initiated. 14, You would appreciate the fact, that even in many of Class I Cities and Class II Towns, the provision of sewage treatment plant is either non-exist or not-completed. In such circumstances,levying of environmental compensation to Coonoor Municipality is not at all justified. 15. We also wish to inform that the Central Pollution Control Board requires that the local bodies falling under Class I cities and Class II Towns, need to provide sewage treatment plants and are Monitoring its Implementation. In as much as Coonoor Municipality is only a Class III, have not shown any inclination towards providing the sewage treatment plant. However realizing the need of maintaining the water bodies free from pollution and in compliance to the orders passed by the Hon’ble National Green Tribunal in this regards, we have immediately initiated action to prepare project report. Once the proposals are ready the process of getting approval from the Government and the execution of the scheme will be under taken. As already pointed out detail road map for the same as been presented. 16. It is to be mentioned that Coonoor Municipality is under severe Financial Crunch, and struggling to settle the Power Consumption charges, payment of salaries to its employees in time. In fact, our present level of dues to TANGEDCO, for the power consumed stood at Rs. 160 lakhs. Even with this difficulty, we have initiated action and executing the blo-mining activity is only because of fully understanding our obligation towards environmental Protection. As such, the levying of environmental compensation would not be In the best interest of environmental protection, as this would add further stress on the little available financial resources, and consequent may add stress on the fund requirement for carrying out the preliminary works related to the interception of sewage entering into the river, providing of suitable treatment schemes for the same etc.17. We wish to further inform that Coonoor Municipality is making @ submission before the Hon’ble National Green Tribunal (SZ), during the hearing on 3 February, 2021, that TamilNadu Pollution Control Board may be suitably instructed to keep the procedure of the levying of Environmental Compensation to Coonoor Municipality, and any further course of action in this matter be deferred till June, 2021, and the Environmental Compensation be levied on us, only in case the time-lines prescribed in the road-map are not met with. Considering our submissions as above, we request you to accept our reply and drop all further proceedings on levying of environmental compensation for Coonoor Municipality. 502? Pane er Commissioner (i/c) - Coonoor Municipality AY. Bee Copy submitted to: 1.The Commissioner of Municipal Administration, Chennai. 2.The District Collector, The Nilgiris. 3.The Regional Director of Municipal Administration. Tirrupur.Photographs showing Solid Waste Management Activities E Pt ‘Wind Row composting at IL& FS Premises | Segregation of dry waste at Resource Recovery Centre Bailing of Segregated Waste High Temp. Burning Systems for the disposal of Rags, Diapers &Sanitary Napkins.Photographs Showing works for Sewage Management Fecal Sludge Treatment Plant work. Commenced at Ottupattarai RRC Premises ‘Study Team Discussing with Officials TownBEFORE THE HON’BLE NATIONAL GREEN TRIBUNAL SOUTHERN ZONE, CHENNAI. Original Application No. 108 of 2020(SZ) Tribunal on its own motion Suo Motu initiated proceedings based on the News item published in Vikatan E-Magazine edition dated 09.07.2020 Under the caption “Coonoor Misery: Increasing waste in River Water! — Elephants looking for good water”. Vs The Principal Secretary to Government, Public Works Department, Secretariat, Fort St. George, Chennai — 600 009 & 7 others. ...Respondents. REPORT FILED ON BEHALF OF THE RESPONDENTS TAMIL ___NADU POLLUTION CONTROL BOARD. Advocate for Respondent No. TNPCB Thiru. C. Kasirajan. Date:02.02.2021.
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