M/s Rama Natural Foods Pvt. Ltd. vs Commission for Air Quality Management in National Capital Region and Adjoining Areas

Judicial Analysis Court Copy Headnote Facts Arguments Court observation

2025 Supreme(Online)(NGT) 2106

NATIONAL GREEN TRIBUNAL NEW DELHI (PRINCIPAL BENCH)
HON’BLE MR. PRAKASH SHRIVASTAVA, CJ, HON’BLE DR. A. SENTHIL VEL, EM, HON’BLE DR. AFROZ AHMAD, EM
M/s Rama Natural Foods Pvt. Ltd. – Appellant
Versus
Commission for Air Quality Management in National Capital Region and Adjoining Areas – Respondent

Advocates:
For the Appellants/Petitioners: Mr. Rahul Khurana, Mr. Hasil Jain
For the Respondents: Dr. Abhishek Atrey, Mr. Navneet Gupta

Judgement Key Points

Certainly. Here are the key points from the provided legal document:

The appeal was filed under section 18 of the CAQM Act, 2021, challenging a closure order dated 19.09.2025 issued under section 12(2)(xi) of the same Act (!) .
The appellant, M/s Rama Natural Foods Pvt Ltd., contended that the order was passed without giving an opportunity for a hearing and without adhering to principles of natural justice (!) .
The appellant had obtained the Consent to Operate (CTO) on 15.11.2025 and purchased a compliant DG set (!) (!) .
The inspection by the CAQM team on 21.08.2025 identified violations, and it was noted that the unit falls in the red category with a 125 KVA DG set operating without CTO (!) (!) .
The impugned order states that if the unit complies with norms and addresses deficiencies, operations can resume; the appellant claims to have cured these deficiencies (!) .
The court directed the appellant to approach the CAQM with a detailed representation and supporting material during the day, to facilitate a decision within two days (!) (!) .
The Uttar Pradesh Pollution Control Board (UPPCB) is to initiate action for imposing Environmental Compensation (EC) for past violations, following principles of natural justice; this action does not hinder the CAQM from passing appropriate orders (!) .
The appeal was disposed of with the directions that the appellant approach CAQM, and the necessary actions regarding EC will proceed independently (!) (!) .
A copy of the order is to be forwarded to the Member Secretary of UPPCB for compliance (!) .

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Table of Content
1. appellant's compliance and closure challenges (Para 1 , 2 , 3)
2. response to representation and action assurance (Para 4)
3. decision-making required by caqm and ec actions (Para 5 , 6)
4. final disposition of appeal and compliance directive (Para 7)

ORDER

1. By this Appeal filed under section 18 of the Commission for Air Quality Management in NCR and Adjoining Areas Act, 2021 (CAQM Act, 2021), appellant has challenged the closure direction dated 19.09.2025 issued under section 12 (2) (xi) of the CAQM Act, 2021. The counsel for the appellant submits that the impugned order has been passed without giving any opportunity of hearing to the appellant and without complying with the principles of natural justice and the appellant has subsequently obtained the Consent to Operate (CTO) on 15.11.2025 and has also purchased compliant DG set.

2. Learned counsel for the CAQM on advance notice has submitted that the inspection was carried out by the team on 21.08.2025 and violations were noted and it was also found that the appellant unit falls in the red category and was having the DG set of 125 KVA and was operating without the CTO.

3. The impugned order itself in paragraph 6 men

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