Citation Codes

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citation codes

Case Number

Appeal No. 15/2023 / KOLKATA

Disposition

dismissed

Judges

Mr. Justice B. Amit Sthalekar
Dr. Arun Kumar Verma

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Smart Summary

National Green Tribunal, Eastern Zone Bench, Kolkata — Summary of Order (19 July 2023)

Factual and Procedural Background

This appeal (Appeal No.15/2023/EZ) was filed by Khurshid Ahmed challenging the West Bengal Pollution Control Board's (WBPCB) closure order dated 11.04.2023 directing immediate closure of the appellant's unit. The appellant's unit is described as a facility that collects waste copper items and processes them with nitric acid to produce copper-nitrate solution; copper is recovered after sedimentation while the remaining iron-nitrate solution is collected and sold. The WBPCB inspected the area and observed discoloration (orangish-yellow) at the discharge point into the Hooghly river and traced the effluent back, finding a mix of open channel and an underground sewer, with surrounding land used for industrial activities. The WBPCB inspection report (annexed to the impugned order) identified multiple units in the area operating without Consent to Establish (CTE) or Consent to Operate (CTO) and without Effluent Treatment Plants (ETP) or Air Pollution Control Devices (APCD). Water samples taken from the discharge point showed gross failure with respect to pH and heavy metals, and the WBPCB Technical Committee classified the appellant's unit as a Red Category Industry (RCI) operating within Howrah Municipal Corporation (HMC) area in violation of siting criteria. The appellant sought quashing of the closure order; the Tribunal heard counsel for both parties on 19.07.2023.

Legal Issues Presented

Whether the impugned closure order dated 11.04.2023 issued by the West Bengal Pollution Control Board directing immediate closure of the appellant's unit should be quashed.
Whether the appellant's unit, alleged to be operating without statutory consents (CTE/CTO) and without an Effluent Treatment Plant (ETP) or Air Pollution Control Device (APCD), contravenes the regulatory requirements applicable to such industries.
Whether a unit classified as a Red Category Industry (RCI) can lawfully be licensed to operate within the Howrah Municipal Corporation area and the legal implications of issuance of such a license by municipal authorities.
Whether environmental remedial measures — including environmental compensation and potential criminal prosecution of officials who issued an allegedly improper license — are warranted in the circumstances revealed by inspection and analysis.

Arguments of the Parties

Appellant's Arguments

The appellant's counsel (Mr. Prithvijoy Das) submitted that the appellant's unit possessed a license issued by the Howrah Municipal Corporation on 13.07.2023 valid until 31.03.2024 for operating as M/s. Ahmed Copper Refinery (proprietor: Khurshid Ahmed); the counsel provided that document to the Tribunal.
The appellant's counsel further argued that the unit's operations do not generate residue or water wastage, disputing the WBPCB's implication of effluent discharge; however, the WBPCB's inspection report and water analysis concerning pH contradicted this submission.

The opinion does not contain a detailed account of the respondent's (West Bengal Pollution Control Board's) oral or written arguments beyond the contents of the inspection report, water analysis, and Technical Committee classification which are recorded in the impugned order.

Table of Precedents Cited

No precedents were cited in the provided opinion.

Court's Reasoning and Analysis

The Tribunal's analysis proceeded from the factual findings recorded in the WBPCB inspection report and the content of the impugned closure order:

The Tribunal noted the inspection findings that the appellant's unit had been operating for around 22–23 years (as stated by a worker) and that, at the time of inspection, some manufacturing activities were observed at the unit.
The impugned order recorded that none of the units identified in the inspection had Consent to Establish (CTE) or Consent to Operate (CTO) from the State Board, and none had Effluent Treatment Plants (ETP) or Air Pollution Control Devices (APCD). The appellant's unit was included in this finding.
WBPCB collected water samples (on 16.12.2022) from the point where the drain met the Ganga (Hooghly) and the laboratory results showed gross failure with respect to pH and heavy metal concentration. The Tribunal treated these analytical results as material.
The Technical Committee of the Board opined that the appellant's unit falls within the Red Category of Industry (RCI) and is operating within Howrah Municipal Corporation area in violation of the Board's siting criteria. The Tribunal relied on the categorisation and the relevant extract of the Board's Red Category list reproduced in the record to contextualize the prohibition.
The Tribunal considered the appellant's contention of having a municipal license and the submission that no residue or water wastage is generated, but observed that these contentions conflicted with the inspection report and water analysis.
On the basis of the above factual matrix — absence of requisite consents, absence of pollution control systems (ETP/APCD), adverse laboratory results, and classification as RCI operating in a prohibited location — the Tribunal concluded there was no illegality or infirmity in the WBPCB's closure order of 11.04.2023 and therefore declined to quash it.
The Tribunal also addressed systemic regulatory concerns: it observed that the municipal license issued by Howrah Municipal Corporation for an RCI raised "serious issues" about how such a license was granted (either ignorance of rules by municipal officials or collusion with violating industries).
Consequently, the Tribunal directed (a) initiation of criminal prosecution by the WBPCB against the officer(s) who issued the municipal license to operate a Red Category industry within the Howrah Municipal Corporation, and (b) the WBPCB to compute environmental compensation against the appellant after giving due notice, explaining the methodology, inviting objections, determining final compensation and recovering it in accordance with law within two months.

Holding and Implications

Holding: The Tribunal dismissed Appeal No.15/2023/EZ and upheld the impugned closure order dated 11.04.2023.

Consequences and directives resulting from the holding (as recorded in the order):

The closure order issued by the West Bengal Pollution Control Board is upheld; the appellant's challenge was dismissed.
The West Bengal Pollution Control Board is directed to initiate criminal prosecution against the officer(s) who issued the Howrah Municipal Corporation license permitting operation of a Red Category Industry within the Howrah Municipal Corporation limits.
The West Bengal Pollution Control Board is directed to compute environmental compensation against the appellant, after giving him due notice (including methodology and invitation for objections), to determine final compensation and recover it in accordance with law within two months.
Interlocutory applications, if any, were disposed of accordingly; there shall be no order as to costs.

The order does not purport to lay down or rely upon any new legal precedent; it is a decision based on the inspection report, laboratory analysis, and the Board's classification and regulatory framework reproduced in the record.

Source: Order of the National Green Tribunal, Eastern Zone Bench, Kolkata, dated 19 July 2023 — Appeal No.15/2023/EZ (Khurshid Ahmed v. West Bengal Pollution Control Board). The summary above is based exclusively on the content of the provided opinion.

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KHURSHID AHMED v. WEST BENGAL POLLUTION CONTROL BOARD

Item No.05 Court No.1

BEFORE THE NATIONAL GREEN TRIBUNAL

EASTERN ZONE BENCH, KOLKATA

(THROUGH PHYSICAL HEARING WITH HYBRID MODE)

Appeal No.15/2023/EZ

In the matter of:

Khurshid Ahmed

S/o Lt. Luqman Ahmed 180/1, G. T. Road, P.O. & P.S. - Shibpur, Howrah - 711102

…. Appellant(s)

Versus

The West Bengal Pollution Control Board

Through the Member Secretary, Department of Environment, Government of West Bengal, Paribesh Bhawan Building, 10A, Block LA, Sector III, Bidhannagar,

Kolkata - 700106

…. Respondent(s)

Date of hearing: 19.07.2023

CORAM: HON'BLE MR. JUSTICE B. AMIT STHALEKAR, JUDICIAL MEMBER HON'BLE DR. ARUN KUMAR VERMA, EXPERT MEMBER

For Appellant(s) : Mr. Prithvijoy Das, Advocate a/w Ms. Ishani Ghoshal, Advocate

For Respondent(s) : Mr. Dipanjan Ghosh, Advocate a/w Mr. Prithwish Basu, Advocate

ORDER

1. Heard the learned Counsel for the Appellant as well as the Counsel appearing for the West Bengal Pollution Control Board.

2. The Appellant in the present Appeal is seeking quashing of the Order dated 11.04.2023 passed by the West Bengal Pollution Control Board whereby the Appellant unit has been directed to be closed with immediate effect.

3. The Appellant is stated to be carrying on operation of collecting waste copper items which, when mixed with nitric acid, produces copper-

nitrate (sky blue colour liquid) and this liquid is then poured into a tank where waste iron is mixed with the liquid. It is stated that after sedimentation, pure copper is collected from the tank leaving behind the iron-nitrate solution and this iron-nitrate solution is then stated to be collected in large jars and sold to small scale industries for the purpose of weighting silks, tanning, fertilizers etc.

4. According to the Appellant, during inspection carried out by the West Bengal Pollution Control Board an orangish-yellow colour was observed at the point where the effluent discharges through Ramkrishna ferry ghat drain into the Hooghly river. When the drain was traced back for a distance of approx. 300 mtr., it was observed that it is an open channel prior to Foreshore Road and thereafter, there is an underground sewer line for rest of the distance till it meets the river.

5. It is stated that the area on both sides of the underground drain and sewer consists of mixed activities mainly by warehouses, industrial activities and some residences along with khatal. The land is stated to be owned by the Kolkata Port Trust and is being used for industrial activities.

6. It is stated that the State Board inspected some other units including the unit of the Appellant and found that all the units are operating in the area of Howrah Municipal Corporation without having any Consent to Establish (CTE) and Consent to Operate (CTO) of the State Board.

7. The Inspection Report of an inspection carried out by the State Pollution Control Board is contained in the impugned order of 11.04.2023 itself, copy of which has been filed as Annexure 'P-1' to the memo of Appeal. The Inspection Report reads as under:-

“Sl. No.	Name & address of the unit	Type of activity	Remarks
1.	M/s. Ambay Engineering located at 5 no. Mollick Ghat Road, P.O. & P.S.- Howrah, Pin-711101	The unit is engaged in fabrication of aliminium ladders and anodizing aluminium channels. Some of the activities were going on during inspection.	The unit is operating since 10-12 years ago as informed by Shri Sukumar Das, Manager of the unit.
2.	M/s. Janbazar Aluminium located at 5 no. Mollick Ghat Road, P.O. & P.S.-Howrah, Pin-711101	The unit is engaged in fabrication of aliminium ladders and anodizing aluminium channels. During inspection the unit was closed under lock and key.
3.	M/s. Salasar Aluminium located at 15 nos. Charaghat 2nd bye lane, Road, P.O. & P.S.-Howrah, Pin- 711101	The unit is engaged in fabrication of aliminium ladders and anodizing aluminium channels. Some of the activities were going on during inspection.	The unit is operating since November 2022 as informed by Shri Sanjay Pandey, Manager of the unit.
4.	Unit run by Khurshid Ahmed located at 9 no. Mollick Ghat Road, P.O. & P.S.-Howrah, Pin-711101	The unit is engaged in manufacturing of copper materials. Some of the activities were going on during inspection.	The unit is operating since 22-23 years ago as informed by Shahnowaz Ahmed, worker of the unit.
5.	Unit of Haji Jibrial Ansari located at 1 no. Mollick Ghat Road, P.O. & P.S.-Howrah, Pin-711101	The unit is engaged in manufacturing pure copper from waste copper materials. Some of the activities were going on during inspection.	The unit is operating since November 2020 as informed by Haji Jibrial Ansari, Proprietor of the unit.”

8. As per the Inspection Report, the unit of the Appellant is operating since 22-23 years as informed by one Shahnowaz Ahmed, worker of the unit.

9. The impugned closure order mentions that all the units mentioned therein are operating in the Howrah Municipal Corporation area without Consent to Establish (CTE) and Consent to Operate (CTO) from the West Bengal State Pollution Control Board. None of the units have any Effluent Treatment Plant (ETP) or Air Pollution Control Device (APCD) including the Unit of the Appellant. It is also stated that the effluent generated by the unit is discharged directly to the Howrah Municipal Corporation drain which ultimately flows into the river Hooghly.

10. The impugned order also discloses that water samples were collected by the officials of West Bengal Pollution Control Board on 16.12.2022 from the discharge point of the drain to river Ganga and the result of the water samples shows gross failure with respect to pH and concentration of heavy metals.

11. The impugned order also discloses that the Technical Committee submitted its opinion that the unit falls in the Red Category of Industry (RCI) and is operating within the Howrah Municipal Corporation area in violation of the siting criteria of the State Pollution Control Board.

12. Mr. Prithvijoy Das, learned Counsel for the Appellant states that the Appellant unit has license duly issued by the Howrah Municipal Corporation on 13.07.2023 and valid upto 31.03.2024 for operating the unit in the name of M/s. Ahmed Copper Refinery, proprietor Mr. Khurshid Ahmed. Document to that effect has been passed on to the Tribunal by the learned Counsel for the Appellant.

13. The learned Counsel for the Appellant further submitted that in the course of operation of his unit, there is absolutely no residue generated and no water wastage. However, the Report of the West Bengal Pollution Control Board and Water Analysis Report with regard to pH is contrary to the submission of the learned Counsel for the Appellant.

14. There is another aspect of the matter. Though the Counsel for the Appellant states that he has a license issued by the Howrah Municipal Corporation License Department to operate the unit, but the unit itself falls in the 'Red Category of Industry' (RCI). Question is, how was this unit allowed to function and operate within the Howrah Municipal Corporation area.

15. The extract of Red Category of industry as notified under the West Bengal Pollution Control Board Memo No. 1512/4A-18/2010 (Pt.I) dated 14.06.2016 reads as under:-

"LIST-A

RED CATEGORY

Sl.No.	Activity
1	Isolated storage of hazardous chemicals (as per schedule of manufacturing, storage of hazardous chemicals rules, 1989 as amended)
2	Automobile manufacturing (integrated facilities) and heavy engineering including ship building (with investment on plant and machinery >10 crores)
3	Industries engaged in recycling / reprocessing / recovery / reuse of Hazardous Waste under schedule iv of HW (M, H & TBM) rules, 2008 - Items namely - Spent cleared metal catalyst containing copper, Spent cleared metal catalyst containing zinc
4	Manufacturing of lubricating oils, grease and petroleum based products
5	DG Set of capacity>5 MVA
6	Industrial carbon including electrodes and graphite blocks, activated carbon, carbon black
7	Lead acid battery manufacturing (excluding assembling and charging of lead - acid battery in micro scale)
8	Phosphate rock processing plant (including grinding)
9	Power generation plant (including Waste to Energy plants >15 MW capacity which attract provisions of EIA Notification, 2006 as amended) [except Wind and Solar renewable power plants of all capacities and Mini Hydel power plant of capacity<25 MW] (Other than Thermal Power Plants)

storage of hazardous chemicals rules, 1989 as amended)

2 Automobile manufacturing (integrated facilities) and heavy engineering including ship building (with investment on plant and machinery >10 crores)

3 Industries engaged in recycling / reprocessing / recovery / reuse of Hazardous Waste under schedule iv of HW (M, H & TBM) rules, 2008 - Items namely - Spent cleared metal catalyst containing copper, Spent cleared metal catalyst containing zinc

4 Manufacturing of lubricating oils, grease and petroleum based products

5 DG Set of capacity>5 MVA

6 Industrial carbon including electrodes and graphite blocks, activated carbon, carbon black

7 Lead acid battery manufacturing (excluding assembling and charging of lead - acid battery in micro scale)

8 Phosphate rock processing plant (including grinding)

9 Power generation plant (including Waste to Energy plants >15 MW capacity which attract provisions of EIA Notification, 2006 as amended) [except Wind and Solar renewable power plants of all capacities and Mini Hydel power plant of capacity<25 MW] (Other than Thermal Power Plants)

10	Industries engaged in recycling / reprocessing / recovery / reuse of Hazardous Waste under schedule-IV of HW (M, H& TBM) Rules, 2008 - Items namely - Spent catalyst containing nickel, cadmium, Zinc, copper, arsenic, vanadium and cobalt
11	Processes involving chlorinated hydrocarbons [including rigid PVC pipe manufacturing]
12	Sugar (excluding Khandsari)
13	Fibre glass production and processing (excluding moulding) [including glass wool and rock wool production, manufacturing of mica based electrical insulating products using thinners/solvents]
14	Fire crackers manufacturing and bulk storage facilities
15	Industries engaged in recycling / reprocessing / recovery / reuse of Hazardous Waste under schedule iv of HW (M, H & TBM) rules, 2008 - Items namely - Dismantlers Recycling Plants -- Components of waste electrical and electronic assembles comprising accumulators and other batteries included on list A, mercury-switches, activated glass cullets from cathode-ray tubes and other activated glass and PCB-capacitors, or any other component contaminated with Schedule 2 constituents (e.g. cadmium, mercury, lead, polychlorinated biphenyl) to an extent that they exhibit hazard characteristics indicated in part C of this Schedule.
16	Milk processes and dairy products (integrated project)
17	Phosphorous and its compounds
18	Pulp & Paper (waste paper based without bleaching process to manufacture Kraft paper)
19	Coke making, liquefaction, coal tar distillation or fuel gas making
20	Manufacturing of explosives, detonators, fuses including management and handling activities [including manufacturing of safety match]
21	Manufacturing of paints varnishes, pigments and intermediate (excluding blending / mixing)
22	Organic Chemicals manufacturing [including phenolic products, rubber chemicals]
23	Airports and Commercial Air Strips (waste water generation >100 KLD.)
24	Asbestos and asbestos based industries
25	Basic chemicals and electro chemicals and its derivatives including manufacturing of acid
26	Cement
27	Chlorates, per-chlorates & peroxides
28	Chlorine, fluorine, bromine, iodine and their compounds
29	Dyes and Dye–Intermediates
30	Health-care Establishment (as defined in BMW Rules) for waste water generation >100 KLD or with incinerator or both
31	Hotels (3 star and above) and hotels having ≥100 rooms or waste-water generation ≥100 KLD
32	Industries engaged in recycling / reprocessing / recovery / reuse of Hazardous Waste under schedule iv of HW (M, H & TBM) rules, 2008 - Items namely - Lead acid battery plates and other lead scrap / ashes / residues not covered under Batteries (Management and Handling) Rules, 2001. [* Battery scrap, namely: Lead battery plates covered by ISRI, Code word “Rails” Battery lugs covered by

	ISRI, Code word “Rakes”. Scrap drained / dry while intact, lead batteries covered by ISRI, Code word “rains”
33	Industries engaged in recycling / reprocessing / recovery / reuse of Hazardous Waste under schedule iv of HW (M, H & TBM) rules, 2008 - Items namely - Integrated Recycling Plants -- Components of waste electrical and electronic assembles comprising accumulators and other batteries included on list A, mercury - switches, activated glass cullets from cathode -ray tubes and other activated glass and PCB -capacitors, or any other component contaminated with Schedule 2 constituents (e.g. cadmium, mercury, lead, polychlorinated biphenyl) to an extent that they exhibit hazard characteristics indicated in part C of this Schedule
34	Manufacturing of glue and gelatin [excluding glue from starch and including manufacturing of synthetic adhesives, shellac processing, rubber based adhesives, industrial adhesives using paraffin wax and resin powder (for polishing leather goods, shoes etc.)]
35	Mining and ore beneficiation
36	Nuclear power plant
37	Pesticides (technical) (excluding formulation)
38	Photographic film and its chemicals
39	Railway locomotive work shop / Integrated road transport workshop / service centers having waste-water generation ≥100 KLD
40	Yarn / Textile processing involving any effluent / emission generating processes including bleaching, dyeing, printing and colouring [including composite woolen mill, dewaxing of raw wool and raw silk, manufacturing of woolen blanket from woolen fibre]
41	Chlor Alkali
42	Ship Breaking Industries
43	Oil and gas extraction including CBM (offshore & on-shore extraction through drilling wells)
44	Industry or process involving metal surface treatment or process such as pickling / electroplating / paint stripping / heat treatment using cyanide bath / phosphating or finishing and anodizing / enamellings / galvanizing

45	Tanneries
46	Ports and harbour, jetties and dredging operations
47	Synthetic fibers including rayon, tyre cord, polyester filament yarn [including natural fibre, raw wool, raw silk, cellophane paper, cellulose nitrate]

48	Thermal Power Plants
49	Slaughter house (as per notification S.O.270 (E) dated 26.03.2001) and meat processing industries, bone mill, processing of animal horn, hoofs and other body parts
50	Aluminium Smelter
51	Copper Smelter
52	Fertilizer (basic) (excluding formulation / granulation / blending only)
53	Iron & Steel (involving processing from ore / integrated steel plants) and or Sponge Iron units
54	Pulp & Paper (waste paper based units with bleaching process to manufacture writing & printing paper)

55 Zinc Smelter

56	Oil Refinery (Mineral Oil or Petro Refineries)
57	Petrochemicals Manufacturing (including processing of Emulsions of oil and water)
58	Pharmaceuticals (Basic Drugs) and related R & D
59	Pulp & Paper (Large-Agro & wood), Small Pulp & Paper (agro based-wheat straw / rice husk) [including straw board, grey board, duplex board and de-inking, bleaching activity]
60	Distillery (molasses / grain / yeast based) including Fermentation industry with waste water generation ≥100 KLD (including blending, bottling of alcoholic products with waste water generation ≥100 KLD)
61	Ceramic, Refractories having coal consumption ≥12 MT / day
62	Common treatment and disposal facilities (CETP, TSDF, E-waste recycling, CBMWTF, effluent conveyance project, incinerators, solvent / acid recovery plant, MSW sanitary landfill sites, STP)
63	Ferrous and Non-ferrous metal extraction >1 MT/hr involving different furnaces through melting, refining, reprocessing, casting and alloy making and including metal extraction from Lead [including gold and silver smithy using greater than 1.0 litre sulfuric acid / nitric acid per month, forging with coal fired boilers and smelting, lead, zinc and other metals]
64	Industrial estates / parks / complexes / areas / export processing zones / SEZs / biotech parks (For Red Category member industries)
65	Industry or process involving foundry operations(foundries having capacity ≥5 MT/hr and requiring coal / coke consumption ≥500 kg/hr)

66	Manufacturing of glass (bulb, lamp, optical lens etc.) using coal / wood fired kiln including manufacturing of lead glass
67	Parboiled rice mills (Waste Water generation ≥100 KLD or fuel ≥12 MTD or both)
68	Synthetic detergents and soaps (excluding formulation) waste water generation ≥100 KLD
69	Vegetable oils including solvent extraction and refinery / hydrogenated oils having waste water generation ≥100 KLD.
70	Non-alcoholic beverage (soft drink) and bottling of non-alcoholic products with waste water generation ≥100 KLD
71	Building and construction projects >20,000 sq.mtr. built up area (waste water generation ≥100 KLD)
72	Cleaning / washing of old PVC and MS drums using mineral turpentine oil, kerosene oil and water
73	Steel and steel products using various furnaces like blast furnaces / open hearth furnace / induction furnace / arc furnace / submerged arc furnace / basic oxygen furnace [industries attracting EIA (Notification) 2006 as amended]
74	Any industry / industrial activity (irrespective of category), having solid fuel fired boiler / Thermic Fluid Heater (TFH) irrespective of capacity or oil / gas fired boiler >5 TPH

Note:-

a) Any industry / industrial activity which is not covered in category lists, having coal fired boiler with steam generation capacity >5 TPH, will be considered under Red category subject to approval by the categorisation committee of the Board.

b) Any industry / industrial activity using solid fuel (coal / wood / husk etc.) fired boiler / TFH irrespective of capacity and oil / gas fired boiler >5 TPH will be considered under Red category.

c) Capacity of boilers / furnace / kiln / oven / DG set etc. in any unit refers to the cumulative capacity of all such respective items.

d) For activities attracting EIA notification, Environmental Clearance is mandatory followed by 'Consent to Establish' and 'Consent to Operate' of the Board.

e) Detailed information for selection of specific nature of activity under industry category is available in the EMIS of the Board for facilitating project proponents."

16. The other aspect in the case is that the unit-in-question, the Appellant's unit does not have Consent to Establish (CTE) or Consent to Operate (CTO) and has been operating for 22-23 years though the impugned order mentions that no Effluent Treatment Plant (ETP) was found at the site.

17. For reasons aforesaid, we do not find any illegality or infirmity in the impugned order of closure dated 11.04.2023.

18. This case raises serious issues namely with regard to granting of license to operate a Red Category Industry (RCI) within the Howrah Municipal Corporation which is strictly prohibited. Either the officials concerned of the Howrah Municipal Corporation who are granting license are ignorant and not apprised of the rules or are operating hand in glove with the violating industries including the Appellant Unit herein.

19. Needless to say the West Bengal Pollution Control Board shall initiate criminal prosecution against the officer/officers concerned who have issued the license to the Appellant to operate a Red Category industry within the Howrah Municipal Corporation.

20. The West Bengal Pollution Control Board is also directed to compute environmental compensation against the Appellant Unit after giving him due notice, indicating the methodology of computation and inviting his objections to the same, if any, and shall thereafter determine the final environmental compensation and proceed to recover the same from the Appellant in accordance with law within two months.

21. With the aforesaid directions, the Appeal No.15/2023/EZ is dismissed.

22. Interlocutory Applications, if any, stand disposed of accordingly.

23. There shall be no orders as to costs.

.....................................

B. Amit Sthalekar, JM

…..........................................

Dr. Arun Kumar Verma, EM

July 19, 2023, Appeal No.15/2023/EZ

SKB

KHURSHID AHMED v. WEST BENGAL POLLUTION CONTROL BOARD

National Green Tribunal, Eastern Zone Bench, Kolkata — Summary of Order (19 July 2023)

Factual and Procedural Background

Legal Issues Presented

Arguments of the Parties

Appellant's Arguments

Table of Precedents Cited

Court's Reasoning and Analysis

Holding and Implications

KHURSHID AHMED v. WEST BENGAL POLLUTION CONTROL BOARD

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