Kerala High Court
Nelkadir Bone Industries vs The Kerala State Pollution Control ... on 12 November, 2024
WP(C) NO. 13008 OF 2024
& WP(C) NO. 13072 OF 2024 1 2024:KER:84199
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE MOHAMMED NIAS C.P.
TUESDAY, THE 12th DAY OF NOVEMBER 2024/ 21ST KARTHIKA, 1946
WP(C) NO. 13008 OF 2024
PETITIONER:
NATIONAL INDUSTRIES,
V/264 D.A., EDAYAR, MUPPATHADAM P.O.,
ERNAKULAM, REPRESENTED BY ITS PROPRIETOR
AUTHORISED SIGNATORY, PIN - 683110
BY ADVS. ASWIN GOPAKUMAR
ANWIN GOPAKUMAR
ADITYA VENUGOPALAN
MAHESH CHANDRAN
ANGITA T. MENON
SARANYA BABU
RESPONDENTS:
1 KERALA STATE POLUTION CONTROL BOARD,
HAVING ITS HEAD OFFICE AT PLAMOODY- THEKKAMOODU
ROAD, PATTOM, THIRUVANANTHAPURAM, PIN - 695004
WP(C) NO. 13008 OF 2024
& WP(C) NO. 13072 OF 2024 2 2024:KER:84199
2 THE CHIEF ENVIRONMENTAL ENGINEER,
KERALA STATE POLLUTION CONTROL BOARD,
REGIONAL OFFICE, GANDHI NAGAR, KADAVANTHARA P.O,
ERNAKULAM, PIN - 682020
3 THE ENVIRONMENTAL ENGINEER,
ENVIRONMENT SURVEILLANCE CENTRE, FACT-QR NO.S-5,
UDYOGAMANDAL P.O, ERNAKULAM, PIN - 683501
BY ADV SRI. T.NAVEEN SC, KERALA STATE POLLUTION
CONTROL BOARD,
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD
ON 12.11.2024, ALONG WITH WP(C).13072/2024, THE COURT ON
THE SAME DAY DELIVERED THE FOLLOWING:
WP(C) NO. 13008 OF 2024
& WP(C) NO. 13072 OF 2024 3 2024:KER:84199
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE MOHAMMED NIAS C.P.
TUESDAY, THE 12th DAY OF NOVEMBER 2024 / 21ST KARTHIKA, 1946
WP(C) NO. 13072 OF 2024
PETITIONER:
NELKADIR BONE INDUSTRIES,
V/264 D.A., EDAYAR, MUPPATHADAM P.O.,
ERNAKULAM , REPRESENTED BY ITS AUTHORISED
SIGNATORY MR. ABDUL LATHEEF, PIN - 683110
BY ADVS. ASWIN GOPAKUMAR
ANWIN GOPAKUMAR
ADITYA VENUGOPALAN
ANGITA T. MENON
MAHESH CHANDRAN
SARANYA BABU
RESPONDENTS:
1 THE KERALA STATE POLLUTION CONTROL BOARD,
HAVING ITS HEAD OFFICE AT PLAMOODY-THEKJAMOODU
ROAD, PATTOM, THIRUVANANTHAPURAM, REPRESENTED BY
WP(C) NO. 13008 OF 2024
& WP(C) NO. 13072 OF 2024 4 2024:KER:84199
ITS CHAIRMAN, PIN - 695004
2 THE CHIEF ENVIRONMENTAL ENGINEER,
KERALA STATE POLLUTION CONTROL BOARD.
REGIONAL OFFICE, GANDHI NAGAR, KADAVANTHARA
P.O., ERNAKULAM, PIN - 682020
3 THE ENVIRONMENTAL ENGINEER,
KERALA STATE POLLUTION CONTROL BOARD,
ENVIRONMENT SURVEILLANCE CENTRE, FACT-QR NO.
S-5, UDYOGAMANDAL P.O., ERNAKULAM, PIN - 683501
BY ADV SRI. T.NAVEEN SC, KERALA STATE POLLUTION
CONTROL BOARD,
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD
ON 12.11.2024, ALONG WITH WP(C).13008/2024, THE COURT ON
THE SAME DAY DELIVERED THE FOLLOWING:
WP(C) NO. 13008 OF 2024
& WP(C) NO. 13072 OF 2024 5 2024:KER:84199
JUDGMENT
The petitioners are running bone meal processing
industries in the Edayar Industrial Development Area. On the basis
of complaints raised by the residents of the Eloor-Edayar area and
the other nearby areas regarding odour, nuisance and air pollution
issues due to the functioning of the bone meal units, chicken waste
rendering plants, fish oil units and rubber processing units, the
Pollution Control Board decided to avail the service of an expert
agency to assess the operational efficiency of bio-filters/other
odour control measures provided in the 20 industries located in the
industrial area. The Board had engaged CSIR- National Institute of
Interdisciplinary Science and Technology (NIIST),
Thiruvananthapuram, for scientific and technical intervention on
such environmental issues by assessing the present status and
operational efficiency of the measures to be taken in the Edayar
Industrial area.
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& WP(C) NO. 13072 OF 2024 6 2024:KER:84199
2. Through Ext.P1, dated 15.12.2023, the Chief
Environmental Engineer had issued certain directions to all the
industries regarding the remedial of foul smell on account of the
running of such industries, which are as follows:
" 1. The raw materials should be brought to the
processing units in closed vehicles.
2. Raw material storage area should be covered and
shall be provided with suitable ventilation and shall
be connected with biofilter or suitable scientific
odour control system.
3. The raw materials brought to the units should be
processed in the unit without any time delay in
order to prevent decay and odour issues.
4. The raw materials should be brought to the
cooking areas through conveyors, preferably closed
conveyors.
5. A qualified and dedicated technician should be
appointed for the processing unit and attached air
and water pollution devices for efficient
maintenance.
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6. There should be an Effluent Treatment Plant (ETP)
of adequate capacity complying with the standards
prescribed by Pollution Control Board for the
treatment of waste water generated in the unit.
7. The sludge from the ETP should be collected and
shall be scientifically disposed off.
8. The chimney should have a stack height of min
30m with a facility for stack emission monitoring.
9.Estimation and quantifying total quantity of
vapour emanating from the process need to be
assessed. Suitable air pollution (odour) control unit
(i.e., water scrubber, biofilter, incinerator etc.) need
to be installed based on the odour emission and shall
be adequate to treat the vapour formed during the
process.
10. The biofilter techniques adopted in the units
should be scientifically designed and approved.
11. Proper maintenance of bio-filter system should
be done at regular intervals atleast of 6 months. For
the maintenance of bio-filter the following details
shall be ensured.
i. Need proper sizing of biofilter and loading
quantity of packing material based on the process
emission.
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ii. Need proper housekeeping and maintenance of
biofilter area.
iii. Selection of proper filter media which having
high water holding capacity.
iv. Proper arrangement of filter media and compact
packing is essential. Proper maintenance and periodic
replacement of packing media is very much required.
v. Proper ventilation ducting required for inlet gas
stream to the biofilter. Inlet and outlet line should be
properly connected to Biofilter.
vi. Biofilter should be integrated with proper
humidifier or condenser system. Biofilter inlet gas
temperature should be maintained.
vii. Proper suction hood/ ventilation system need to
be installed in processing area, cooking area, loading
and unloading area which should be connected to the
biofilter."
3. The petitioner did not give a reply as directed in Ext.P1,
which made the Board issue Ext.P3 communication on 06.02.2024,
and Ext.P4 issued on 06.03.2024 directing the petitioner to respond.
Finally the petitioner submitted Ext.P5 reply on 25.03.2024, which
reads as follows:
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"I am submitting herewith the action taken to minimise
the odour generated during the material handling and
production process.
1.The raw material is transported to the unit in
accordance with the directions of the board. Open
trucks are not used for this purpose. Utmost care is
taken to avoid any pollution related incidence enroute.
2.Our unit is handling flesh waste, tallow and raw bone.
The waste on receipt is immediately transferred to the
cooker on first come first basis. Hood and suction are
provided in the storage area and connected to the bio
filter.
3.There is no storage of raw bone in our unit. Bone is
stored only after cooking. After cooking there will not
be any foul odour from the cooked bone. Our unit is
provided with odour control spray system which is
operational.
4. The production supervisors and technicians are
experienced and trained to operate equipment hence
the system is well operated.
5. There is no waste water generation during the
production process. The thick slurry is solidified by
using lime powder and is mixed with the bone meal
powder and marketed as manure. For the general wash
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& WP(C) NO. 13072 OF 2024 10 2024:KER:84199
water septic tank and sock pit are provided.
7.Wood fired country boiler is used for boiling and
cooking. The chimney is provided 30 meters above the
roof level and is well maintained.
8.Odour control mechanism is provided with a 10 HP
capacity blower, hoods & suction connected to conduit
lines, wet scrubber, and bio filter are working in good
condition.
9. Our unit is installed with a bio filter of 22.5 meter
cubic volume which is well maintained periodically.
The ventilation system /suction hood are functioning
well."
4. The petitioner challenges Ext.P1 dated 15.12.2023, and
Exts.P3 and P4 which directed them to comply with the directions
in Ext.P1. It is seen from Ext.P5, the reply given by the petitioners,
that their stand was that they have complied with the directions in
Ext.P1. There is no averment at all in Ext.P5 that the measures
suggested in Ext.P1 are either ultra vires the Act or that it is
incapable of compliance. The writ petitions are filed essentially
contending that the standards, which the Board attempts to secure
through Ext.P1, are based on a project report mentioned as EN
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& WP(C) NO. 13072 OF 2024 11 2024:KER:84199
13725 (2003), a European Standard for the measurement of odour,
which, according to the petitioners, is obsolete and has been
withdrawn by the European Union on 23.02.2022 and is no longer
applicable there.
5. The writ petitions were filed on 27.03.2024 challenging
Exts.P1, P3 and P4 dated 15.12.2023, 06.02.2024 and 06.03.2024
respectively. Pending the writ petitions, noticing that the defects
were not cured, closure intention notices dated 14.08.2024 and
13.08.2024 were served on the petitioners in W.P(C) No.13008/2024,
and W.P(C) No.13072/2024, respectively intending to revoke the
consent alleging that the defects pointed out in Ext.P1 have not
been cured. The defects noted as regards the petitioner in W.P.(C)
No.13008/2024 are as follows:
"Whereas inspection was conducted by board officials as
per ref (3) and the following violations/defects were
observed.
1. All of the vehicles used to transport raw materials to the
unit were not found to be fully covered.
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& WP(C) NO. 13072 OF 2024 12 2024:KER:84199
2. The raw material storage area lacks adequate enclosure,
proper ventilation and connection to a biofilter or an
appropriate scientific odour control system.
3. Open conveyors were used to transport raw materials to
the cooking areas, rather than closed conveyors.
4. Qualified and dedicated technician has not been
assigned to the processing unit.
5. No ETP facility was provided for effluent treatment.
6. The chimney lacks the required stack height of 30
meters.
7.The biofilter installed in the unit was not functioning
and has not received any approval.
8. The frequency of maintenance and media replacement
for the biofilter was not found satisfactory. No records of
periodic replacement of packing media are maintained in
the unit.
9. Temperature sensor, humidifier or condenser has not
been provided for biofilter.
10.The loading and unloading area does not have a suction
hood installed.
11. Large quantities of cooked bones and bone powder
were piled up inside the unit. Additionally, huge heap of
cooked bone has been stored in the adjacent unit for the
past 2-3 months."
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& WP(C) NO. 13072 OF 2024 13 2024:KER:84199
6. The defects noted regarding the petitioner in W.P.(C)
No.13072/2024 are as follows:
"Whereas inspection was conducted by board officials on
29.07.2024 and the following violations/defects were
observed"
1. All of the vehicles used to transport raw materials to
the unit were not found to be fully covered.
2.The raw material storage area lacks adequate
enclosure, proper ventilation and connection to a
biofilter or an appropriate scientific odour control
system.
3.The raw materials delivered to the units were
processed with a delay.
4. Open conveyors are used to transport raw materials to
the cooking areas, rather than closed conveyors.
5. Qualified and dedicated technician has not been
assigned to the processing unit.
6. The operation of ETP was found to be unsatisfactory.
7. The chimney lacks the required stack height of 30
meters.
8. The biofilter installed in your unit was not functioning
and has not received approval from the board. Also the
sprinkles provided in the unit were poorly designed and
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& WP(C) NO. 13072 OF 2024 14 2024:KER:84199
defective.
9.The frequency of maintenance and media replacement
for the biofilter was not found satisfactory. No record of
periodic replacement of packing media is maintained in
the unit.
10. Temperature sensor, humidifier or condenser has not
been provided for biofilter.
11. The loading and unloading area does not have a
suction hood installed. Also the vapours were not being
captured by the hood installed above the cooker. The
suction facilities provided in the unit is found to be
inadequate.
12. Large quantities of cooked bones and bone powder
are piled up inside the unit. Additionally, huge pile of
cooked bone powder has been stored here for the past 3
years, and the bone powder stored caught fire during the
inspection."
7. It was specifically alleged in the above notices that the
units were functioning without curing the defects noted above and
accordingly show cause notices were issued as to why closure
directions as per Section 33A of the Water (Prevention and Control
of Pollution) Act 1974 and as per Section 31A of the Air (Prevention
WP(C) NO. 13008 OF 2024
& WP(C) NO. 13072 OF 2024 15 2024:KER:84199
and Control of Pollution) Act, 1981 shall not be issued for the above
non-compliance. The Board also has stated about an inspection
conducted on 29.07.2024 to verify the compliance of the directions
issued vide Ext.P1. The petitioners had submitted Annexure.R3(d)
replies dated 27.08.2024 which also maintained the stand that there
were no defects as alleged by the Board. There is not even a syllable
as to why the petitioners are not required to comply with the
directions in Ext.P1 or in the closure intention notices. The
contention taken in the writ petitions was never put forth as a reply
to either Ext.P1 or to Annexure R3(c), the closure intention notice.
This contention is not supported by any material and was never
urged before the Board to be tested or considered. Accordingly, the
contentions in that regard are only to be rejected.
8. After receipt of the reply, another inspection was
conducted on 04.09.2024 to verify the details mentioned in the
reply. It was found that there was only partial compliance with the
direction of the Board. Therefore, a request letter was sent to the
WP(C) NO. 13008 OF 2024
& WP(C) NO. 13072 OF 2024 16 2024:KER:84199
Chairperson of the Board to get permission to close down the unit
as per Section 33A of the Water (Prevention and Control of
Pollution) Act, 1974 and Section 31A of the Air (Prevention and
Control of Pollution) Act, 1981. It was after all these steps that the
closure orders were passed on 22.10.2024 again repeating that the
defects pointed out and which were stated in the closure intention
notices remain uncomplied and accordingly directed the Unit to be
closed down with immediate effect and report the action to the
office at the earliest and also not to resume operation without
obtaining written permission from the Board and without rectifying
the above defects. It is submitted that except for challenging
Exts.P1, P3 and P4, there is no challenge to any of the orders passed
subsequently including the closure orders.
9. The reply affidavits filed in these cases claim that they
were operating the units meeting all the requirements as mandated
by law. The said statements are wrong in view of the
affidavits/reports filed by the Pollution Control Board which clearly
WP(C) NO. 13008 OF 2024
& WP(C) NO. 13072 OF 2024 17 2024:KER:84199
mentions the deficiencies in the units starting from Ext.P1 issued on
15.12.2023, Annexure R3(c) closure intention notice dated
14.08.2024 and the closure order dated 22.10.2024, Ext.P6. As I have
already rejected the contention raised in the writ petition based on
the European standards, in the absence of a challenge to the
orders/actions issued by the board subsequent to the filing of the
writ petitions, the contention that the defects are cured also cannot
be accepted.
10. Though the learned counsel for the petitioner submits
the basis for issuing the notice was based on European Standards, as
stated above, there was no such plea taken either while replying to
Ext.P1 or while replying to the closure intention notices. It is trite
that a litigant cannot be permitted to make a volte-face, take
inconsistent positions, play fast and loose, blow hot and cold, to
approbate and reprobate, to the detriment of his opponent. The
doctrine of approbate and reprobate applies to the conduct of
parties and having replied to the notices of the Pollution Control
WP(C) NO. 13008 OF 2024
& WP(C) NO. 13072 OF 2024 18 2024:KER:84199
Board taking a position that the defects noticed are cured, the
contentions in the writ petition that they are not liable to cure the
defects in either Exts.P1 to P4 or in the notices seeking revocation
of consent, cannot be accepted at all. These are not contentions that
can be considered for the first time in these writ petitions, more so
when the petitioners had no such case at all before the Pollution
Control Board. The petitioners cannot be permitted to change after
taking a stand and then turn around and attack the same for the
purpose of securing some other advantage. I do not find any merit
in the contentions raised on behalf of the writ petitioners. It is
relevant to note that no malice/malafides are alleged against any
acts of the Pollution Control Board or its officials.
11. The conduct of the party not to close down the unit
despite the closure order also deserves mention and it is only after
the direction of this court to inspect the premises that the Board
also took steps to see that the unit stopped functioning defying the
closure order, which specifically directed the petitioner not to
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& WP(C) NO. 13072 OF 2024 19 2024:KER:84199
continue running the unit without express permission. Given the
number of opportunities granted by this Court through orders
dated 23-10-24, 5-11-24, and 7-11-24 to cure the defects and
intimate the Board and the conduct of the party referred to above, I
do not think that this is a fit case where any indulgence can be
shown invoking the discretionary jurisdiction.
Needless to say the above findings are rendered dealing
with the contentions raised in the writ petitions as regards the
orders impugned therein. Without prejudice to the right of the
petitioners to challenge the Closure Orders, if so advised, before the
Appellate Forums concerned, the writ petitions are dismissed.
Sd/-
MOHAMMED NIAS C.P.
JUDGE
DMR/-
WP(C) NO. 13008 OF 2024
& WP(C) NO. 13072 OF 2024 20 2024:KER:84199
APPENDIX OF WP(C) 13072/2024
PETITIONER'S EXHIBITS
Exhibit P1 TRUE COPY OF THE LETTER DATED
15.12.2023 ISSUED BY THE RESPONDENT NO.
Exhibit P2 TRUE COPY OF THE RELEVANT PAGES OF THE
PROJECT REPORT ON OPERATIONAL
EFFICIENCY OF INDUSTRIAL GAS BIOFILTERS
Exhibit P3 TRUE COPY OF THE LETTER ISSUED BY
RESPONDENT NO.3 DATED 06.02.2024
Exhibit P4 TRUE COPY OF THE LETTER ISSUED BY
RESPONDENT NO. 2 DATED 06.03.2024
Exhibit P5 TRUE COPY OF THE REPLY DATED 25.03.2024
Exhibit P6 CLOSURE ORDER ISSUED BY RESPONDENT NO.1
DATED 22.10.2024
Exhibit P7 A TRUE COPY OF ANALYTICAL REPORT DATED
24.11.2022 ISSUED BY THE INDIAN
INSTITUTE OF SPICE RESEARCH
WP(C) NO. 13008 OF 2024
& WP(C) NO. 13072 OF 2024 21 2024:KER:84199
Exhibit P8 A TRUE COPY OF THE LIST OF TECHNICIANS
EMPLOYED BY THE PETITIONER FIRM
Exhibit P9 A TRUE COPY OF THE PHOTOGRAPHS OF THE
PETITIONER FIRM
A TRUE COPY OF THE INVOICE DATED
Exhibit P10 06.11.2024 ISSUED TO THE PETITIONER
EVIDENCING THE PURCHASE OF A CRUSHING
MACHINE
RESPONDENTS' ANNEXURES
Annexure R3(a) TRUE COPY OF THE CONSENT TO OPERATE NO.
KSPCB/ESC/ICO/10041381/2023 DATED
1-12-2023, VALID UPTO 30-6-2028, ISSUED
BY THE POLLUTION CONTROL BOARD.
Annexure R3(b) TRUE COPY OF THE LETTER NO P.C.B./R.O
-E.K.M/GEN-13/11 DATED 6-7-2024 ISSUED
BY THE BOARD
TRUE COPY OF THE CLOSURE INTENTION
Annexure R3(c)
NOTICE NO PCB/ESC/CO-75/06 DATED
13-8-2024
WP(C) NO. 13008 OF 2024
& WP(C) NO. 13072 OF 2024 22 2024:KER:84199
Annexure R3(d) TRUE COPY OF THE REPLY DATED 27-8-2024
REF NO NBI/2024-25/01
TRUE COPY OF THE LETTER NO PCB/ESC/CO-
Annexure R3(e)
75/06 DATED 7- 9-2024 SENT TO THE
CHAIRPERSON OF THE BOARD
Annexure R3(f)
TRUE COPY OF THE MINUTES OF THE MEETING
HELD ON 15-10-2024.
TRUE COPY OF THE LETTER NO.
Annexure R3(g)
KSPCB/1637/2024-EE-1 DATED 21-10-2024
ISSUED BY THE CHAIRPERSON OF THE
POLLUTION CONTROL BOARD.
// TRUE COPY //
P.A. TO JUDGE
WP(C) NO. 13008 OF 2024
& WP(C) NO. 13072 OF 2024 23 2024:KER:84199
APPENDIX OF WP(C) 13008/2024
PETITIONER'S EXHIBITS
Exhibit P1 TRUE COPY OF THE LETTER DATED
15.12.2023 ISSUED BY THE RESPONDENT
NO.2
Exhibit P2 TRUE COPY OF THE RELEVANT PAGES OF THE
PROJECT REPORT ON OPERATIONAL
EFFICIENCY OF INDUSTRIAL GAS BIOFILTERS
Exhibit P3 TRUE COPY OF THE LETTER ISSUED BY
RESPONDENT NO.3 DATED 06.02.2024
Exhibit P4 TRUE COPY OF THE LETTER ISSUED BY
RESPONDENT NO. 2 DATED 06.03.2024
Exhibit P5 TRUE COPY OF THE REPLY DATED 25.03.2024
Exhibit P6 TRUE COPY OF CLOSURE ORDER DATED
22.10.2024.
A TRUE COPY OF ANALYTICAL REPORT DATED
24.11.2022 ISSUED BY THE INDIAN
Exhibit P7
INSTITUTE OF SPICE RESEARCH
Exhibit P8 A TRUE COPY OF THE LIST OF TECHNICIANS
WP(C) NO. 13008 OF 2024
& WP(C) NO. 13072 OF 2024 24 2024:KER:84199
EMPLOYED BY THE PETITIONER FIRM
A TRUE COPY OF THE PHOTOGRAPHS OF THE
Exhibit P9
PETITIONER FIRM
RESPONDENTS' ANNEXURES
Ext.R3(a) TRUE COPY OF THE LETTER NO. PCB/ESC/CO-
74/08 DATED 28-10-2024 ISSUED BY THE
POLLUTION CONTROL BOARD.
TRUE COPY OF THE COMMUNICATION NO.
Ext.R3(b)
DB/GENERAL-EDR/2024-25/128 DATED
1-11-2024 SENT BY THE KSEB, ELECTRICAL
SECTION, EDAYAR.
Annexure R3(a) TRUE COPY OF THE CONSENT TO OPERATE NO.
PCB/ESC/CO/IC-109/94/18 DATED 1-7-2018
ISSUED BY THE POLLUTION CONTROL BOARD.
TRUE COPY OF THE LETTER NO. PCB/RO-
EKM/JEN - 13/11 DATED 6-7-2024 ISSUED
Annexure R3(b)
BY THE BOARD
Annexure R3(c) TRUE COPY OF THE SAID CLOSURE INTENTION
WP(C) NO. 13008 OF 2024
& WP(C) NO. 13072 OF 2024 25 2024:KER:84199
NOTICE NO. PCB/ESC/CO-74/08 DATED
14-8-2024
Annexure R3(d) TRUE COPY OF THE REPLY LETTER DATED
27.08.2024 REF. NO. NI/2024-2025/02
TRUE COPY OF THE LETTER NO PCB/ESC/CO-
Annexure R3(e)
74/08 DATED 10-9-2024 SENT TO THE
CHAIRPERSON OF THE BOARD
Annexure R3(f) TRUE COPY OF THE MINUTES OF THE MEETING
HELD ON 15-10-2024.
Annexure R3(g) TRUE COPY OF THE LETTER NO.
KSPCB/1637/2024-EE-1 DATED 21-10-2024
ISSUED BY THE CHAIRPERSON OF THE
POLLUTION CONTROL BOARD.
// TRUE COPY //
P.A. TO JUDGE
