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Who Changed Delhi's Air?

Although there is general public approval of the improvements in Delhi's air quality in recent years, the process by which this change was brought about has been criticised. A common perception is that air quality policies were prescribed by the Supreme Court, and not by an institution with the mandate for making environmental policy. A careful review of the policy process in Delhi suggests otherwise. We find that the government was intimately involved in policy-making and that the main role of the Supreme Court was to force the government to implement previously announced policies. A good understanding of what happened is essential, as the Delhi experience for instituting change has become a model for other Indian cities as well as neighbouring countries.

Who Changed Delhi’s Air?

Although there is general public approval of the improvements in Delhi’s air quality in recent years, the process by which this change was brought about has been criticised. A common perception is that air quality policies were prescribed by the Supreme Court, and not by an institution with the mandate for making environmental policy. A careful review of the policy process in Delhi suggests otherwise. We find that the government was intimately involved in policy-making and that the main role of the Supreme Court was to force the government to implement previously announced policies. A good understanding of what happened is essential, as the Delhi experience for instituting change has become a model for other Indian cities as well as neighbouring countries.

URVASHI NARAIN, RUTH GREENSPAN BELL

D
elhi has made surprising strides toward improving its air quality. The data collected by the Central Pollution Control Board (CPCB) suggest that levels of suspended particles, an indicator for respiratory health, have at least stabilised and possibly even fallen [World Bank and Central Pollution Control Board 2005]. Despite popular resistance and widespread protests in 2001, when all public transport-related commercial vehicles were ordered to convert to compressed natural gas (CNG), residents of Delhi today approve of the results. In a survey conducted prior to the November 2003 state elections, it was noted that the improvement in air quality was one of the main achievements of the ruling Congress government for Delhi, and quite likely a factor that contributed to the re-election of the incumbent government [Anon 2003].

Although elected politicians now claim credit for air quality improvements, Delhi’s dramatic evolution from the world’s fourthmost polluted city is more often attributed to decisions of the Supreme Court, which is constitutionally an adjudicator, not an environmental policy-maker. The critics have argued not only that the court overstepped its bounds, but also that it dictated policies that were inefficient. The 2003 India Infrastructure Report, published by the 3iNetwork, contends,

…mandatory conversion to CNG by all vehicles is not necessarily the most efficient way to bring down emission levels. Other options could have been considered…The decision on the appropriate technology should have ideally been made by the executive using a body of experts… [3iNetwork 2003].

These are not academic arguments or theoretical debates but real concerns, as the high courts for other cities in India are considering similar reforms and other countries are watching India’s experience. That alone makes it urgent to understand whether the Supreme Court in fact improperly asserted authority to make environmental policy decisions. In this paper we examine the role of the Supreme Court and the government by looking at the process by which air pollution policies evolved in Delhi.

Our examination leads us to the following conclusions. Although the Supreme Court played a central role in the welcomed changes, especially the conversion of all commercial vehicles to CNG, it was not the source of most of the policies. The court’s important contribution was to push the government in two significant ways: to implement existing policies and to develop new policies. In our view, the court did not exceed the traditional role of a common law court, and in fact acted in some ways like courts in the western democracies that force governments to implement enacted laws.

The court did, however, prod the government at critical points to get past partisan politics and bureaucratic logjams, and it provided a form of protective cover that allowed the government to avoid taking direct responsibility for implementing controversial policies.

The executive branch of the government was the chief driver of the policy-making process, as distinct from policy implementation. Although it vacillated in implementing its own policies to curb air pollution in Delhi, the government was clearly the policy-maker. It did this directly, through its various central and state-level ministries, and indirectly, through statutory committees it was asked by the Supreme Court to set up under Section 3(3) of the Environment (Protection) Act of 1986.

The process of policy-making to reduce air pollution, involving the state, statutory committees, and the court, continues even today and appears to be an effective driver of change. Until the state steps up and directly assumes its responsibilities, and as long as the existing process is transparent and participatory, the existing process may be the only viable way to achieve policy reform.

How It All Began

The Supreme Court’s involvement in policies to curb air pollution in Delhi began with public interest litigation brought to the court by M C Mehta in December 1985. Concerned about rising levels of air pollution and the government’s apparent lack of interest in dealing with it, Mehta petitioned the court to direct government ministries and departments to implement the Air Act of 1981 in Delhi.

The Air Act gave the government authority to take action. Specifically, the Air Act contains authority for CPCB to “lay down standards for the quality of air”, to “advise the central government on any matter concerning the improvement of the quality of air and the prevention, control, or abatement of air pollution”, and to “perform such other functions as may be prescribed”. In 1986, in response to Mehta’s petition, the Supreme Court directed the Delhi administration to file an affidavit specifying the steps it had taken to reduce air pollution.

Economic and Political Weekly April 22, 2006

Quite likely as a result of the court’s involvement, the Delhi administration and the central government started to pay attention to the problem of air pollution. Some have asserted that the Delhi administration and the central government took steps to curb pollution on their own initiative, without the court’s order. In a July 2003 interview, Dilip Biswas, then chairman of CPCB, said that the central government set vehicular standards in 1990 on its own initiative. Given the timing, however, and the correspondence between the court and the government at this time, it is highly likely that the court’s involvement was a precipitating factor.

Several new environmental laws were enacted, as were policies to curtail tailpipe emissions from vehicles and move polluting industries from Delhi. However, these policies were rarely implemented, and those that were can be characterised as largely piecemeal. There was no evidence of a comprehensive plan to tackle the growing problem of air pollution.

The new legislation included the 1986 Environment (Protection) Act, an amendment to the Air Act in 1987, the Motor Vehicles Act of 1988, and the Central Motor Vehicle Rules of 1989. The latter two specifically added authority to set standards for vehicular emissions for manufacturers and users. As a result, in 1990 vehicular exhaust emissions standards were set, imposing some obligations on owners to maintain clean-running vehicles [Agarwal et al 1996]. Ambient air quality standards were also prescribed for Delhi by the ministry of environment and forests (MoEF) (The Statesman, Calcutta, January 2, 1991). Finally, a committee was set up in April 1991 under H B Mathur, of the Indian Institute of Technology in Delhi, to recommend vehicular mass emissions standards for 1995 and 2000 [Anon 1996]. The standards were to replace a voluntary programme in which manufacturers self-certified their vehicles’ performance (The Sentinel, May 31, 1989).

In late 1987, the Delhi administration began a campaign to educate residents about air pollution and encourage them to have their vehicles voluntarily checked for emissions (The Times of India, September 21, 1988). Also at this time, the Delhi traffic police announced its first crackdown on polluting vehicles, especially diesel vehicles (Indian Express, February 24, 1988). Mathur found that the Delhi traffic police prosecuted 2.5 times more vehicles in 1988 than in 1987. His study also found that despite these efforts, the level of pollution far exceeded safe limits. Then, in 1989, the central government raised the penalty on vehicle-owners guilty of breaking the pollution law to Rs 1,000. However, the state transport authority for Delhi was unable to enforce the penalty and cited a lack of service stations with equipment to measure vehicular exhaust (The Sentinel, May 31, 1989).

Starting in the late 1980s, the Delhi administration also began to consider the impacts of industrial pollution. In 1988, the administration identified firms in Delhi that were causing pollution and promised to relocate them to new industrial areas (The Times of India, February 28, 1988). About a year later, the administration announced a policy that would allow only “clean” small industries with low power requirements to operate in the city (Indian Express, November 25, 1989). To the best of our knowledge, this policy was never implemented. In 1990, the central government approved the second master plan for Delhi. It identified category “H” industries – those that were large and associated with hazardous emissions – that needed to be moved out of Delhi within three years – that is, by 1993.

Court Pushes Harder

Nevertheless, pollution continued to rise. Possibly responding to this, in early 1991, the court asked MoEF to set up the first of what turned out to be three statutorily based committees charged with devising policies to curb air pollution in Delhi. Authority to do so derives from the Environment Protection Act, which allows the central government to “constitute an authority…for the purpose of exercising and performing much of [its] powers and functions”, including the power to issue direction. By asking for the establishment of such committees, whose sole purpose was to devise policies to curb air pollution, the court signalled that the government should pay more attention to air pollution and indicated its own need for technical experts.

The first of these committees was constituted in March 1991, when in an extended judgment the court asked counsel to “come forward with useful deliberations so that something concrete could finally emerge”. This committee came to be known as the Saikia Committee, after its chairman, former justice K N Saikia, who had recently retired from the Supreme Court. Other members of the committee were M C Mehta, the chairman of CPCB, and a representative of the automakers. The court directed the committee to (i) assess technologies available for vehicular pollution control; (ii) assess low-cost alternatives for operating vehicles at reduced pollution levels in metropolitan areas and make specific recommendations for implementing these alternatives; and

(iii) make recommendations on how vehicular pollution could be reduced in both the near term and the long run.

One of the Saikia Committee’s first recommendations was to phase out leaded petrol in Delhi by April 1992 [Saikia Committee on Vehicular Pollution 1991]. As if to demonstrate why a firmer hand was needed in these matters, MoEF argued against the lead phase-out policy before the committee [Saikia Committee on Vehicular Pollution 1991] even though in late 1989 the agency itself had announced a plan to introduce unleaded petrol (The Times of India, December 31, 1989).

The committee also recommended CNG as an alternative vehicular fuel for three reasons: it polluted less, cost less, and was more widely available than petrol or diesel. Official discussion about the use of CNG in transportation had begun as early as 1988, when a World Bank study urged the Indian government to use natural gas for transportation, and the Oil and Natural Gas Commission tested CNG in its own vehicles, with encouraging results (Hindustan Times, February 28, 1988). In September 1994, Parliament passed the Motor Vehicles Amendment Act to promote the use of alternative fuels, such as batteries, solar power, and CNG. Motorists using these alternative fuels were not required to obtain permits from the state transport authorities and, for a specified period, were allowed to determine their own freight, fares, and hours of operation.

These incentives were meant to encourage commercial vehicle operators to switch to alternative fuels. The Delhi government also announced its intention to promote the use of CNG as an alternative fuel by opening more CNG outlets and possibly subsidising the cost of CNG conversion kits [Anon 1994b]. On the suggestion of the Saikia Committee that CNG be used as an alternative fuel, in early 1995 the Supreme Court ordered that all government cars switch to CNG or install catalytic converters and use unleaded fuel (Indian Express, February 4, 1995). Despite this flurry of activity, most of which originated with the

Economic and Political Weekly April 22, 2006 government, little effort was made to build the infrastructure needed to make CNG viable in the city.

There was action with respect to other fuel issues, however. On the recommendation of the Saikia Committee, in August 1994 the Supreme Court mandated the phase-out of leaded fuel in Delhi, Mumbai, Calcutta, and Madras by April 1995 and for the entire country by April 2000 (court order, October 21, 1994). The deadline to supply unleaded petrol in Delhi was met on time (though the benzene content of the unleaded petrol was kept at 5 per cent, not 3 per cent as had been recommended by CPCB). The Supreme Court also ordered that the sulfur content in diesel supplied in Delhi be reduced from 1 per cent to 0.25 per cent, in two stages, by April 1998 [Environment Pollution (Prevention and Control) Authority 2001]. This was the first time that the Supreme Court issued fuel quality specifications.

In the early to mid-1990s the Supreme Court also got much more involved in the relocation of polluting industries from Delhi, but again, in response to policies devised earlier by the government. A 1962 master plan had called for the closure of such industries but received no further attention from the Delhi administration for almost three decades. In 1990 a revised master plan for Delhi was approved that reiterated the need to close down hazardous and noxious industries as well as heavy and large industries. The plan gave the administration another three years to implement this provision. This deadline to relocate category H industries also came and went. Starting in 1996, the Supreme Court began to act to force the government to implement its relocation policies. Because of the court’s persistence, polluting category H firms were finally relocated by 1997. At the same time the court got involved in relocating industrial units operating in residential areas, but this process took longer and is still ongoing.

Also in the early 1990s, MoEF proposed that all vehicles have catalytic converters by April 1995. It is conceivable that MoEF was prodded by the Supreme Court to adopt this policy. Inferential evidence is found in a court order dated November 14, 1990, indicating that in that month the Supreme Court brought catalytic converters to the ministry’s attention. In 1995 the Delhi government announced that it would subsidise the installation of catalytic converters in all two- and three-wheel vehicles to the extent of Rs 1,000 within the next three years (Indian Express, January 30, 1995). Furthermore, the petroleum ministry banned the registration of new four-wheel cars and vehicles without catalytic converters in Delhi, Mumbai, Chennai and Calcutta, effective April 1, 1995 (Telegraph, March 13, 1995).

Vehicular mass emissions standards were issued by MoEF in 1993, but the standards that emerged were fairly lax. Under political pressure and lobbying by the automakers, MoEF issued a diluted version of the 1991 Mathur Committee recommendations; it was even more lenient than the initial proposal by CPCB (Indian Express, July 23, 1993), and the deadline for the standards was extended a year, to April 1996 [Agarwal et al 1996]. During this time the government also flirted with policies to reduce pollution from thermal power plants. However, few initiatives went beyond the planning stage, and the few that did were scuttled after they were announced.

In summary, many plans to reduce Delhi’s air pollution – relocate industry, improve fuel standards, and encourage the use of CNG – were announced by the government and then abandoned or ignored. Announced one by one, the initiatives had no particular coherence, and there was no comprehensive approach.

Starting from the early 1990s, however, the court began to push the government to make good on its promises. The court’s efforts included direct orders and the appointment of the Saikia Committee. The city’s air quality nevertheless continued to deteriorate – traffic police were issued masks and even given additional compensation for being exposed to risk of chest and lung abnormalities. Finally, on November 8, 1996, the Supreme Court issued a suo moto notice to the Delhi government to submit an action plan to control the city’s air pollution [Agarwal et al 1996]. Justice Kuldeep Singh was said to have issued the notice after reading Slow Murder, a book about Delhi’s urban air quality problems.

Comprehensive Policy Development

In 1996 and 1997, in response to direct orders of the Supreme Court, the Delhi government and the central government finally developed action plans to curtail pollution in Delhi. These were the first comprehensive policies on air pollution control. Delhi government: The action plan developed by the Delhi administration was articulated in an affidavit filed with the court on November 18, 1996, by Kiran Dhingra, the then-commissioner-cum-secretary of the transport department for Delhi. Dhingra was asked by the court to respond to the following ideas:

  • (a) Freeze or restrict the registration of all types of motor vehicles for the next two to three years.
  • (b) Freeze the registration of three-wheelers and not renew the existing permits.
  • (c) Retire all public buses at five to seven years.
  • (d) Restrict driving such that one-third of registered vehicles are kept off the road on a particular day.
  • In asking for a response, the court appears to have wanted to engage the executive branch in a dialogue about appropriate policies, not impose policies of its own, and to build consensus around pollution control policies.

    In her affidavit, Kiran Dhingra indicated that the government was introducing CNG buses. She named as priorities a mass rapid transport system and a bypass around Delhi. Other components of her strategy were better technology for new vehicles, improved fuel quality, restrictions on excessively polluting in-use vehicles, improvements to the existing public transport system, construction of passenger and freight terminals on the outskirts of Delhi, improved monitoring of ambient air quality, further “greening” in Delhi, and efforts to increase public awareness. She suggested that a task force comprising representatives of relevant government departments and civil society draw up a plan of action and a schedule. The affidavit was comprehensive and detailed, including both policy goals and strategies to achieve them – from strengthening public transportation and improving fuel quality to placing restrictions on in-use vehicles, increasing the use of CNG and propane, and retiring old vehicles.

    On January 3, 1997, it was reported that the central and Delhi administrations had devised an action plan to curb pollution in Delhi. MoEF is said to have asked the Delhi government to add more private buses to the transport system and phase out old Delhi Transport Corporation buses. The same plan urged the central government to consider a request for as many as 3,000 new buses and made suggestions for improving the quality of diesel and imposing stricter emissions standards, but there was no schedule (Business and Political Observer, January 3, 1997).

    A few weeks later, the Delhi government was reported to have decided to introduce new vehicular standards for the capital in

    Economic and Political Weekly April 22, 2006

    1998 instead of 2000. Three other measures were announced: all vehicles fitted with two-stroke engines were to be banned, use of propane in three-wheelers was to be made mandatory beginning in April 1997, and all diesel vehicles were to be fitted with “diesel converters” (Business and Political Observer, January 20, 1997). None of these policies had been mentioned in the affidavit, and none were ever implemented.

    The central government promulgated emissions standards for 2000 in March 1977. The minister of MoEF announced that certain polluting buses would be retired from Delhi’s roads (Hindustan Times, February 22, 1997). In January 1977, the Delhi administration announced that it would impound or heavily fine polluting heavy motor vehicles entering Delhi (The Times of India, January 17, 1997). These policies were later shot down by the law ministry on the grounds that giving the Delhi transport department the power to impound polluting vehicles would circumvent the Motor Vehicles Act (Statesman, April 13, 1997).

    The one part of the affidavit that became a working policy directive from the Delhi administration dealt with phasing out old vehicles and encouraging the use of CNG. In August 1997, the lieutenant governor of Delhi issued instructions to the state transport commissioner for the retirement of old vehicles and technological advancement of the new fleet, pursuant to Section 20 of the Air Act 1981. The new fleet of three-wheelers would include some vehicles operating on alternative fuels, and the fleet of taxis would move to alternative fuels only (electricity, battery, CNG, LPG, propane and solar power). There was no mention of trying to convert the bus fleet to alternative fuels. In all cases, the newer vehicles would meet higher emissions standards.

    In a now-familiar pattern, the Delhi government first responded to pressure from the Supreme Court and in October 1997 developed a policy to phase out old vehicles and encourage the use of CNG. But with elections looming, it withdrew this policy in February 1998. Once again the Supreme Court stepped in and forced the Delhi government to act on the policy it had announced. Central government: In December 1997, a year after the Dhingra affidavit, MoEF issued the ‘White Paper on Pollution in Delhi with an Action Plan’ ‘Ministry of Environment and Forestry 1997]. The white paper was the culmination of a series of meetings with “concerned government agencies, NGOs, experts and citizens”. It proposed policies to curb not only vehicular pollution in Delhi but also all types of pollution, thus going beyond the pollution control strategy suggested by Kiran Dhingra in her affidavit.

    In the white paper, the ministry listed measures and a timetable for controlling vehicular and industrial pollution – about 90 per cent of Delhi’s pollution. Like Dhingra’s affidavit, the white paper called for phasing out old vehicles (including buses more than five years old), possibly phasing out two-stroke two- and three-wheelers, preventing the overloading of buses and trucks, improving traffic flow, building a bypass around Delhi, building a mass rapid transport system, improving the quality of fuel, and introducing CNG buses.

    Measures for controlling vehicular pollution addressed in-use vehicles, traffic management, and fuel quality and types. The white paper also discussed the need for further delegation of statutory powers to functionaries of the Delhi government to carry out enforcement – for example, checks to detect vehicles not complying with emissions norms.

    In January 1998, soon after the release of the white paper and seemingly also in response to the Dhingra affidavit, the Supreme Court directed the central government to set up a third statutory committee – the Environment Pollution (Prevention and Control) Authority (EPCA). According to Harish Salve, who acted as amicus curiae to advise the court in the Delhi litigation, EPCA was set up directly in response to government complaints that the Supreme Court was exceeding its authority by making policy decisions. EPCA was asked to monitor the progress of the white paper, develop new policies to curb vehicular air pollution, and serve as a fact-finding body for the court. EPCA was empowered to direct (a) closure, prohibition, or regulation of any industry, operation, or process; (b) stoppage or regulation of supply of electricity, water, or any other service; (c) the establishment of procedures and specifications to prevent environmental accidents, and to ensure safe handling of hazardous substances; and

    (d) the fitting of vehicles with the proper pollution control equipment and the accurate calibration of these instruments to ensure proper emissions testing (Business Standard, February 14, 1998). But the role that EPCA eventually played went well beyond these responsibilities.

    MoEF issued an order constituting EPCA and nominated Bhure Lal as its chairman (hence EPCA is also called the Bhure Lal Committee) and Dhingra as one of its members. EPCA held its first meeting on February 26, 1998, and met once a week thereafter. It submitted progress reports to MoEF and the Supreme Court at regular intervals as well as specific reports on matters referred to it by the court.

    In its very first progress report, EPCA (1998a) suggested additional pollution policies that built on the action plans of the Delhi administration and MoEF but were bolder and more specific. Rather than just encouraging the use of clean fuels, EPCA proposed to switch all taxis and autos to a clean fuel, ban all eight-year old buses except those on clean fuel, and gradually move the entire bus fleet to a single fuel – CNG. EPCA did not define what it considered clean fuel, however.

    EPCA concluded that pollution control measures already undertaken by the government were limited in their effect because of the number of old vehicles and the rapid increase in new vehicles. EPCA expressed concern about the “lack of action…by implementing departments and the need to focus on effective measures to have an impact in the short run”.

    In its first report, EPCA listed measures from the white paper and the Dhingra affidavit on which there had been no progress:

    (a) ban on commercial vehicles more than 15 years old (to have been implemented by April 1, 1998); (b) setting up of automated facilities for inspection and maintenance of vehicles; (c) formulation of incentive schemes for registration of autos and taxis with clean fuel; (d) ban on alteration of vehicles by replacing petrol engines with diesel engines (to have been implemented by December 31, 1997); (e) restriction on driving goods vehicles during daytime (to have been implemented by December 31, 1997); (f) expansion of premixed oil dispensers to 50 per cent (to have been implemented by June 1997); and (g) ban on supply of loose 2T oil at petrol stations and service garages (to have been implemented by December 1, 1997).

    From the minutes of the first report, it appears that EPCA believed that more drastic measures were needed, including the use of CNG, and that the conversion of vehicles could take place without significant additional cost to owners. Any additional costs could be met through state subsidies.

    EPCA’s plan was converted into a mandate by the Supreme Court on July 28, 1998. Progress over the next four years was

    Economic and Political Weekly April 22, 2006 uneven. CNG fuelling stations, parts, and buses were sometimes unavailable. Key players were reluctant. When bus operators who had not converted to CNG were not allowed to operate, the public staged strikes and protests. And various high-level commissions and committees made last-minute efforts to head off the Supreme Court’s orders. The court refused to reconsider its basic decision, however, and by December 2002, all diesel city buses and commercial vehicles had converted to CNG.

    Conclusion

    Most critics of the Supreme Court’s role in phasing in CNG have focused on its order dated July 28, 1998. This is the principal piece of “evidence” that the court was engaged in activities that went beyond its judicial mandate and appropriate role in Indian political life.

    Our review of the record shows that the policies ordered by the court, including those of July 28, were in fact suggested by EPCA, a representative body of the central government. Furthermore, EPCA’s policy recommendations either derived from or built directly on policies formulated and announced by the Delhi government and by MoEF.

    The court forced the government to carry through its announced policies when the government retreated or wavered. But our extensive review of the process of policy evolution finds little evidence that court devised the policies themselves.

    The pattern observed in Delhi – in which the agencies of elected government announce policies, then withdraw them until forced by the court to implement them – suggests that the road will be similarly rocky for the eight other Indian cities that seek to address their urban air quality and look to the Delhi experience for guidance: Ahmedabad, Kanpur, Lucknow, Pune, Sholapur, Hyderabad, Chennai and Bangalore. The Supreme Court proved itself to be sufficiently above the day-to-day pressure of politics that it could stand firm on the remedies recommended to it by EPCA, and at the same time it made some reasonable, short-term adjustments to adapt to various realities during the difficult transition to CNG. This combination of steadfastness and adaptability helped ease a complicated political and economic shift. It is currently unknown whether the high courts for those cities are capable of playing the same role as the Indian Supreme Court did for Delhi, or what the path of that policy process will be.

    EPW

    Email: narain@rff.org

    [This article is part of a larger project undertaken jointly by Resources for the Future and Jawaharlal Nehru University to understand the process and policies by which Delhi improved its air quality. Details of the project can be found at www.rff.org/clearingtheair, including a more detailed version of this article. The authors are very grateful for the research support provided by Aaron Severn and Nicholas Burger and the time many people in Delhi spent speaking with us and providing us with information.]

    References

    3iNetwork (2003): India Infrastructure Report 2003, Oxford University Press, New Delhi.

    Agarwal, Anil, Anju Sharma and Anumita RoyChowdhury (1996): Slow Murder: The Deadly Story of Vehicular Pollution in India, Centre for Science and the Environment, New Delhi.

    Anon (1992): ‘Masked Oxygen’, Down to Earth, August 31, 2002, Society for Environmental Communications, New Delhi.

  • (1994a): ‘Cops Compensated’, Down to Earth, January 15, Society for Environmental Communications, New Delhi.
  • (1994b): ‘Fair Air on CNG,’ Down to Earth, June 30, Society for Environmental Communications, New Delhi.
  • (1995): ‘Tax on Fly Ash’, Down to Earth, January 31, Society for Environmental Communications, New Delhi.
  • (1996): ‘Smog Inc’, Down to Earth, November 15, Society for Environmental Communications, New Delhi.
  • (2003): ‘Poll Posturing’, Down to Earth, November 15, Society for Environmental Communications, New Delhi.
  • Environment Pollution (Prevention and Control) Authority (1998a): First Progress Report (March-June) submitted to the Supreme Court of India.
  • (1998b): Third Progress Report (October-December 1998) submitted to the Supreme Court of India.
  • (2001): Eleventh Progress Report (January-May 2001) submitted to the Supreme Court of India, June.
  • Kiran Dhingra Affidavit (1996): Affidavit Filed on Behalf of the Government of the National Capital Territory of Delhi with the Supreme Court of India, November 18.

    Ministry of Environment and Forestry (1997): ‘White Paper on Pollution in Delhi with an Action Plan,’ http://envfor.nic.in/divisions/cpoll/ delpolln.html.

    Saikia Committee on Vehicular Pollution (1991): Fourth Bi-Monthly Report (submitted to the Supreme Court of India), November.

    World Bank and Central Pollution Control Board (2005): For a Breath of Fresh Air: Ten Years of Progress and Challenges in Urban Air Quality Management in India (1993–2002), June, World Bank, New Delhi.

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