CHAPTER 1

INTRODUCTION

The atmosphere is a complex natural gaseous system that is essential to support life on

planet Earth. Air pollution means the presence in the atmosphere of any air pollutant.

Air pollutant means any solid, liquid or gaseous substance (including noise) present in the

atmosphere in such concentration as may be or tend to be injurious to human beings or other

living creatures or plants or property or environment.The substance can be solid particles,

liquid droplets, or gases.

A pollutant can be of natural origin or man-made. Pollutants are classified as primary or

secondary.

 Primary pollutants are usually produced from a process, such as ash from a volcanic

eruption. Other examples include carbon monoxide gas from motor vehicle exhaust,

or the sulfur dioxide released from factories.

 Secondary pollutants are not emitted directly. Rather, they form in the air when

primary pollutants react or interact. Ground level ozone is a prominent example of a

secondary pollutant.

 Some pollutants may be both primary and secondary: they are both emitted directly

and formed from other primary pollutants.

Hence, air pollution is the introduction of particulates, biological molecules, or other harmful

materials into Earth's atmosphere, causing diseases, death to humans, damage to other living

organisms such as animals and food crops, or the natural or built environment. Air pollution

may come from anthropogenic or natural sources.

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SOURCES OF AIR POLLUTION

There are various locations, activities or factors which are responsible for releasing pollutants

into the atmosphere. These sources can be classified into two major categories.

1. Anthropogenic (man-made) sources:

These are mostly related to the burning of multiple types of fuel.

 Stationary sources include smoke stacks of power plants, manufacturing facilities

(factories) and waste incinerators, as well as furnaces and other types of fuel-burning

heating devices. In developing and poor countries, traditional biomass burning is the

major source of air pollutants; traditional biomass includes wood, crop waste and dung. [10]
[11]

 Mobile sources include motor vehicles, marine vessels, and aircraft.

 Controlled burn practices in agriculture and forest management. Controlled or prescribed

burning is a technique sometimes used in forest management, farming, prairie restoration

or greenhouse gas abatement. Fire is a natural part of both forest and grassland ecology

and controlled fire can be a tool for foresters. Controlled burning stimulates the

germination of some desirable forest trees, thus renewing the forest.

 Fumes from paint, hair spray, varnish, aerosol sprays and other solvents

 Waste deposition in landfills, which generate methane. Methane is highly flammable and

may form explosive mixtures with air. Methane is also an asphyxiant and may displace

oxygen in an enclosed space. Asphyxia or suffocation may result if the oxygen

concentration is reduced to below 19.5% by displacement.

 Military resources, such as nuclear weapons, toxic gases, germ warfare and rocketry

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 2. Natural sources:

 Dust from natural sources, usually large areas of land with little or no vegetation

 Methane, emitted by the digestion of food by animals, for example cattle

 Radon gas from radioactive decay within the Earth's crust. Radon is a colourless,

odourless, naturally occurring, radioactive noble gas that is formed from the decay of

radium. It is considered to be a health hazard. Radon gas from natural sources can

accumulate in buildings, especially in confined areas such as the basement and it is the

second most frequent cause of lung cancer, after cigarette smoking.

 Smoke and carbon monoxide from wildfires

 Vegetation, in some regions, emits environmentally significant amounts of Volatile

organic compounds (VOCs) on warmer days. These VOCs react with primary

anthropogenic pollutants—specifically, NOx, SO2, and anthropogenic organic carbon

compounds — to produce a seasonal haze of secondary pollutants. [12] Black gum, poplar,

oak and willow are some examples of vegetation that can produce abundant VOCs. The

VOC production from these species result in ozone levels up to eight times higher than

the low-impact tree species.[13]

 Volcanic activity, which produces sulphur, chlorine, and ash particulates.

CHAPTER 2

AIR (PREVENTION AND CONTROL OF POLLUTION) ACT, 1981

The Scope and Application

Decisions were taken at the United Nations Conference on the Human Environment held in

Stockholm in June 1972, in which India participated, to take appropriate steps for the

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preservation of the natural resources of the earth which, among other things, includes the

preservation of the quality of air and control of air pollution. Therefore it is considered

necessary to implement the decisions aforesaid insofar as they relate to the preservation of the

quality of air and control of air pollution.

As a result of the Stockholm Conference, The Air (Prevention and Control of Pollution) Act,

1981 was enacted by an Act of the Parliament of India to control and prevent air pollution. It

was amended in 1987.

 Territorial extent : The whole of India

 Enacted by : Parliament of India

 Date enacted : 29 March 1981

 Came into force on : 16May 1981

The Act defines Air pollution under section 2(b). The Act states the following:

2(a) states, “Air pollutant means any solid, liquid or gaseous substance[(including noise)]

present in the atmosphere in such concentration as may be or tend to be injurious to human

beings or other living creatures or plants or property or environment.”

2(b) states, “Air pollution means the presence in the atmosphere of any air.”

The Act provides for the prevention, control and abatement of air pollution, for the

establishment, with a view to carrying out the aforesaid purposes, of Boards, for conferring

on and assigning to such Boards powers and functions relating thereto and for matters

connected therewith.

It is also a comprehensive legislation with more than fifty sections. It makes provisions,

interalia, for Central and State Boards, power to declare pollution control areas, restrictions

on certain industrial units, authority of the Boards to limit emission of air pollutants, power of

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entry, inspection, taking samples and analysis, penalties, offences by companies and

Government and cognizance of offences etc..

The Act specifically empowers State Government to designate air pollution areas and to

prescribe the type of fuel to be used in these designated areas. According to this Act, no

person can operate certain types of industries including the asbestos, cement, fertilizer and

petroleum industries without consent of the State Board

The Board can predicate its consent upon the fulfillment of certain conditions. The Air Act

apparently adopts an industry wide “best available technology” requirement. As in the Water

Act, courts may hear complaints under the Act only at the instigation of, or with the sanction

of, the State Board.

Objectives of the Act

The main objectives of the Act are as follows:

(a) To provide for the prevention, control and abatement of air pollution.

(b) To provide for the establishment of central and State Boards with a view to implement the

Act.

(c) To confer on the Boards the powers to implement the provisions of the Act and assign to

the Boards functions relating to pollution.

(d) to lay down standards to maintain the quality of air

Air pollution is more acute in heavily industrialized and urbanized areas, which are also

densely populated. The presence of pollution beyond certain limits due to various pollutants

discharged through industrial emission is monitored by the PCBs set up in every

state.Pollution Control Boards (PCBs) measure pollution levels in the atmosphere and at

certain sources by testing the air. This is measured in parts per million or in milligrams or

micrograms per cubic meter.

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The particulate matter and gases that are released by industry and by cars, buses and two

wheelers is measured by using air-sampling equipment. However, the most important aspect

is for people themselves to appreciate the dangers of air pollution and reduce their own

potential as polluters by seeing that their own vehicles or the industry they work in reduces

levels of emissions.

Also, the Air Act has provided for measures, in the cases of industries to be established; and

in the cases of industries already established, they are remedial. In case of established

industries, it insists on obtaining consent of the board, making the industry amenable to the

administrative control of the Board.This Act is created to take appropriate steps for the

preservation of the natural resources of the Earth which among other things includes the

preservation of high quality air and ensures controlling the level of air pollution.

PENALTIES AND PROCEDURE

General provisions

 Penalties for non-compliance (sec. 37)

Whoever fails to comply with the provisions of Section 21 or Section 22 or directions issued

under Section 31A, shall, in respect of such failure, be punishable with imprisonment for a

term which shall not be less than one year and six months but which may extend to 6 years

and with fine, and in case the failure continues, with an additional fine which may extend to

five thousand rupees for every day during which such failure continues after the conviction

for the first such failure.

If the failure referred above continues beyond a period of one year after the date of

conviction, the offender shall be punishable with imprisonment for a term which shall not be

less than 2 years but which may extend to 7 years and with fine.

 Penalty for contravention of provisions of this Act (sec. 39)

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Whoever contravenes any of the provisions of this Act or any order or direction issued there

under, for which no penalty has been elsewhere provided in this Act, shall be punishable with

imprisonment for a term which may extend to three months or with fine Rs. 10,000 or with

both, and in the case of continuing contravention, with an additional fine which may extend

to five thousand rupees for every day during which such contravention continues after

conviction for the first such contravention.

 Cognizance of offences (sec. 43)

No court shall take cognizance of any offence under this Act except on a complaint made by

a) A Board or any officer authorised in this behalf by it; or

b) Any person who has given notice of not less than sixty days,

in the manner prescribed, of the alleged offence and of his intention to make a complaint to

the Board or officer authorised as aforesaid. It is also provided in Sec. 19 of the Environment

(Protection) Act, 1986 and Sec. 49 of the Water Pollution Act, 1974

No court inferior to that of a Metropolitan Magistrate or a Judicial Magistrate of the first class

shall try any offence punishable under this Act.

Where a complaint has been made by any private citizen the Board shall, on demand by such

person, make available the relevant reports in its possession to that person.The Board may

refuse to make any such report available to such person if the same is, in its opinion, against

the public interest.

 Bar of jurisdiction (sec. 46)

No civil court shall have jurisdiction to entertain any suit or proceeding in respect of any

matter which an Appellate Authority constituted under this Act is empowered by or under

this Act to determine, and no injunction shall be granted by any court or other authority in

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respect of any action taken or to be taken in pursuance of any power conferred by or under

this Act.

Section 58 of the Water Pollution Act, 1974, Sec. 46 of the Air Pollution Act, 1981 bars the

jurisdiction of Civil Court relating to pollution cases and Sec. 22 of the Environment

(Protection) Act, 1986 also bar the jurisdiction of Civil Court.

Section 46 of the Act simply bars the jurisdiction of Civil Courts to entertain nay suit or

proceeding in respect of any matter which in Appellate Authority constituted under the Air

(Prevention and Control of Pollution) Act is empowered by or under this Act to determine.

This bar of jurisdiction does not apply to criminal Courts.

Provisions related to offence s committed by Companies, Government Departments and

Public servants

 Offences by companies (sec. 40)

The Act provides that,

“1.Where an offence under this Act has been committed by a company, every person who, at

the time the offence was committed, was directly in charge of, and was responsible to, the

company for the conduct of the business of the company, as well as the company, shall be

deemed to be guilty of the offence and shall be liable to be proceeded against and punished

accordingly:

Provided that nothing contained in this sub-section shall render any such person liable to any

punishment provided in this Act, if he proves that the offence was committed without his

knowledge or that he exercised all due diligence to prevent the commission of such offence.

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2. Notwithstanding anything contained in sub section (1), where an offence under this Act

has been committed by a company and it is proved that the offence has been committed with

the consent or connivance of, or is attributable to any neglect on the part of any director,

manager, secretary or other officer of the company, such director, manager, secretary or other

officer shall also be deemed to be guilty of that offence and shall be liable to be proceeded

against and punished accordingly.”

So, as per Sec. 40 provides that every person who at the time the offence was committed, was

directly, in charge of and responsible to the company for the conduct of the business of the

company, would also be liable to be punished for the said offence. The words “directly

incharge of” are significant in this regard and exclude persons who are indirectly responsible

for the business of the company. It is, therefore, possible to hold that the Chairman and

Deputy Chairman of the Company by virtue of office held by them cannot be prosecuted for

offences committed by the company as they are not the persons directly in charge of, and

responsible to the company as they are not the persons directly in charge of, and responsible

to the company for the conduct of the business of the company. It is, therefore, possible to

hold that the Chairman and Deputy Chairman of the Company by virtue of office held by

them cannot be prosecuted for offences committed by the company as they are not the

persons directly in charge of, and responsible to the company for the conduct of its business

as required under Sec. 40 of the Act.

The broad language of Sec. 482 of the Code of Criminal Procedure, would also justify that

view and suggest that High Court has all the powers to prevent misuse of the process of the

Court or secure ends of justice. Prosecution of Chairman and Deputy. Chairman quashed in

exercise of the powers under Sec. 482 of the Code of Criminal Procedure.

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Recourse to Art. 142 not to be taken to inflict punishment –.A fine is to be imposed upon the

person who is found guilty of having contravened any of the provisions of the Act. He has to

be tried for the specific offence and then on being found guilty, he may be punished either by

sentencing him to undergo imprisonment for the period contemplated by the Act or with fine

or with both. But recourse cannot be taken to Art. 142 to inflict upon him this punishment.

 Offences by Government Departments (sec. 41)

Where an offence under this act has been committed by any Department of Government, the

Head of the Department shall be deemed to be guilty of the offence and shall be liable to be

proceeded against and punished accordingly:

The Head of such Department shall not be liable to any punishment if :

a) He proves that the offence was committed without his knowledge or,

b) that he exercised all due diligence to prevent the commission of such offence.

Notwithstanding anything contained in sub section (1), where an offence under this Act has

been committed by a Department of Government and it is proved that the offence has been

committed

a) with the consent or connivance of, or

b) is attributable to any neglect on the part of, any officer, other than the Head of the

Department,

such officer shall also be deemed to be guilty of that offence and shall be liable to be

proceeded against and punished accordingly.

Similar provisions have been provided under Sec. 17 of the Environment (Protection) Act,

1986 and Sec. 48 of the Water (Prevention and Control of Pollution) Act, 1974.

 Protection of action taken in good faith (sec. 42)

The section provides that no suit, prosecution or legal proceeding shall lie against

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 a) the Government, or

b) any officer of the Government, or

c) any member or any officer or the employee of the Board

for the acts done or intended to be done in good faith by them, under this Act.

Section 42 of the Air (Prevention and Control of Pollution) Act, 1981 and Sec. 59 of the

Water (Prevention and Control of Pollution) Act, 1974 provides protection of action taken in

good faith. Section 18 of the Environment (Protection) Act, 1986, also provides the same

protection. This section seeks to grant exemption to the Government, officers of the

Government, the members and employees of the Board from the legal proceedings in respect

of the actions taken in good faith.

 Members, officers and employees of Board to be public servants (sec. 44)

All the members and all officers and other employees of a Board when acting or purporting to

act in pursuance of any of the provisions of this Act or the rules made thereunder shall be

deemed to be public servants within the meaning of Sec. 21 of the Indian Penal Code (45 of

1860). Section 44 of the Air Pollution Act, 1981 and Sec. 50 of the Water Pollution Act,

1974, provides that members, officers of the Board to be public servant within the meaning of

Sec. 21 of the Indian Penal Code, Sec. 21 of the Environment (Protection) Act, 1986 are

based on the above Act.

CHAPTER 3

LANDMARK CASES RELATED TO AIR POLLUTION IN INDIA

 Union Carbide Corporation v. Union of India (Bhopal Gas leak case)1

1
AIR 1990 SC 273

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The MIC in the Union Carbide Plant was primarily used for the production of carbaryl, which

is a pesticide. It is alleged that most of the safety systems were not functioning and that most

of the safety valves were in poor condition around the time the incident took place. During

the night of December 2-3, 1984, large amounts of water entered into the tank numbered 610

which contained about 42 tonnes of methyl isocyanate. At the time, workers were cleaning

out pipes with water, and some claim that owing to bad maintenance and leaking valves, it

was possible for the water to leak into tank 610. This resulted in an exothermic reaction

which caused the temperature and the pressure inside the tank to increase. Due to this urgent

venting of pressure, large volumes of MIC gas were released into the atmosphere. The gases

flooded the city of Bhopal, causing great panic as people woke up with a burning sensation in

their lungs. Thousands died immediately from the effects of the gas and many were trampled

in the panic. The long term health effects of the gas include visual impairment, blindness,

respiratory difficulties, immune and neurological disorders, lung injury, female reproductive

difficulties and birth defects among children born to affected women.

The Legal Battle: - In the February of 1985, the Indian Government filed a case in the U.S

Court for a claim of $3.3 billons against the Union Carbide Corporation. But by 1986 all of

these litigations in the U.S District were transferred to India on the grounds of forum non

conveniens. It means that the case should be transferred to a more convenient forum so that

the trial proceeds smoothly. Meanwhile in March 1985, the Bhopal Gas Leak Disaster

(Processing of Claims) Act was passed which empowered the Central Government to become

the sole representative of all the victims in all kinds of litigations so that interests of the

victims of the disaster are fully protected and the claims for compensation are pursued

speedily. In the year 1987, cases were filed in the Bhopal District Court which ordered the

Union Carbide Corporation to pay 350 crores as interim compensation. But the interim order

could not be decreed and therefore the UCC refused to pay the amount. Later on, at the High

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Court, this interim compensation amount was reduced to 250 crores. Both the Union of India

and the UCC preferred appeals by special leave against this High Court's order.

Judgement: All the accused were found guilty and were subjected to imprisonment and were

also liable to fine. But these orders could not be enforced as some of the accused did not

appear in the Court. Mr. Warren Anderson, who was the chairman of the UCC at the time the

disaster took place, is still absconding and all requests for his extradition still remain

unsuccessful as the U.S Government rejected it.

 M.C. Mehta v. Union of India (the Oleum Gas Leak case)2

This case was decided by a 5-judge bench of the Supreme Court in 1986. The case of M.C.

Mehta v. Union of India originated in the aftermath of oleum gas leak from Shriram Food and

Fertilisers Ltd. complex at Delhi. This gas leak occurred soon after the infamous Bhopal gas

leak and created a lot of panic in Delhi. One person died in the incident and few were

hospitalized. The case lays down the principle of absolute liability and the concept of deep

pockets.

Facts: Shriram Food and Fertilizers Industry a subsidiary of Delhi Cloth Mills Limited was

producing caustic and chlorine. On December 4th and 6th 1985, a major leakage of petroleum

gas took place from one of the units of Shriram Food and Fertilizers Limited in the heart of

the capital city of Delhi which resulted in the death of several persons that one advocate

practicing in the Tis Hazari Courts died.

The leakage was caused by a series of mechanical and human errors. This leakage resulted

from the bursting of the tank containing oleum gas as a result of the collapse of the structure

on which it was mounted and it created a scare amongst the people residing in that area.

Hardly had the people got out of the shock of this disaster when, within two days, another
2
(1987) SCR 1 819
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leakage, though this time a minor one took place as a result of escape of oleum gas from the

joints of a pipe.

Shriram Foods and Fertilizer Industries had several units engaged in the manufacture of

caustic soda, chlorine, hydrochloric acid, stable bleaching powder, super phosphate,

vanaspati, soap, sulphuric acid, alum anhydrous sodium sulphate, high test hypochlorite and

active earth. All units were set up in a single complex situated in approximately 76 acres and

they are surrounded by thickly populated colonies such as Punjabi Bagh, West Patel Nagar,

Karampura, Ashok Vihar, Tri Nagar and Shastri Nagar and within a radius of 3 kilometres

from this complex there is population of approximately 2, 00,000.

On 6th December, 1985 by the District Magistrate, Delhi under Section 133(1) of Cr.P.C,

directed Shriram that within two days Shriram should cease carrying on the occupation of

manufacturing and processing hazardous and lethal chemicals and gases including chlorine,

oleum, super-chlorine, phosphate, etc at their establishment in Delhi and within 7 days to

remove such chemicals and gases from Delhi. At this juncture M.C.Mehta moved to the

Supreme Court to claim compensation by filing a PIL for the losses caused and pleaded that

the closed establishment should not be allowed to restart.

Judgment: The court held that any enterprise that is engaged in an inherently dangerous

activity is `absolutely’ liable to compensate all those affected by an accident. They key

feature of the judgment was the principle of `absolute liability’, in which no exceptions (such

as an `act of God’) are brooked.

Impact: The case took place soon after the Bhopal Gas Tragedy and was keenly watched as

an instance of how the courts would deal with companies responsible for environmental

disasters. Unfortunately, the complex court litigation around the Bhopal Gas Tragedy was an

example of what not to do in such cases

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  MC Mehta v. UOI (Taj trapezium case) 3

In this case a petition was filed by lawyer M.C Mehta regarding the threat to the deteriorating

beauty of Taj Mahal to invoke the Air (prevention and control of pollution) Act 1981 and

Water (prevention and control of pollution) Act 1974 and Environment Protection Act 1986

for the purpose of relocation of industries to prevent emissions generated by coke or coal

consuming industries having a damaging effect on Taj and people living in the TTZ, and

further to direct them to change over to natural gas as industrial fuel.

According to the petitioner, the foundries, chemical/hazardous industries and the refinery at

Mathura were the major sources of damage to the Taj. The sulphur dioxide emitted by the

Mathura Refinery and the industries when combined with Oxygen-with the aid of moisture in

the atmosphere formed sulphuric acid called “Acid rain” which had a corroding effect on the

gleaming white marble. Industrial/Refinery emissions, brick-kilns, vehicular traffic and

generator-sets were primarily responsible for polluting the ambient air around Taj Trapezium

(TTZ).

Court took cognizance of this matter in January 1993. There were four NEERI reports, two

Varadharajan reports and several reports by the State pollution Control Board. After

examining all the reports and taking into consideration other material on the record, the court

had no hesitation in holding that the industries in TTZ were active contributors to the air

pollution in the said area. NEERI and Varadharajan (1978) reports had specifically

recommended the relocation of industries from the TTZ. Although the State Pollution Control

Board had placed on record list of 510 industries which were responsible for air pollution but

it confined the order only to 292 industries located and operating in Agra.

AIR 2002 SC 3696

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It further held that the Taj, apart from being cultural heritage, is an industry by itself. More

than two million tourists visit the Taj every year. It is a source of revenue for the country. The

Court monitored the petition for over three years with the sole object of preserving and

protecting the Taj from deterioration and damage due to atmospheric and environmental

pollution.

The Court ruled that “Once the activity carried on is hazardous or inherently dangerous, the

person carrying on such activity is liable to make good the loss caused to any other person

irrespective of the fact whether he took reasonable care or not. Consequently the polluting

industries are “absolutely liable to compensate for the harm caused by them to villagers in the

affected area, to the soil and to the underground water and hence, they are bound to take all

necessary measures to remove sludge and other pollutants lying in the affected areas”. The

“polluter Pays” principle as interpreted by this Court means that the absolute liability for

harm to the environment extends not only to compensate the victims of pollution but also the

cost of restoring the environmental degradation. Remediation of the damaged environment is

part of the process of “Sustainable Development”.

CONCLUSION AND RECOMMENDATIONS

The Air (Prevention and Control of Pollution) Act, 1981 aims to conserve and protect the

environment from Air Pollution and provide an pollution free environment to the citizens

which can be passed on to the future generations.

As we know air is the most important need of living things. When it becomes polluted, the

life of humans, plants and animals will be in danger. Air pollution means the presence of

harmful substances in the air which impure our environment .Air Pollution gives rise to

serious health hazards and responsible for various types of life threatening diseases. Hence it

is utmost important that proper attention should be given in controlling and minimizing those

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activities which causes this pollution and also appropriate restriction should be put in place in

using those means which contributes towards it. So, we should save our environment from

any pollution that can damage life of living beings.

Much is being done to control, monitor and rectify damage done by pollutants. The problems

are diverse and some are only being recognised so that we can maintain the environment in

an acceptable condition for future generations to promote sustinaable development. A

wonderful and quality environment must be achieved by continuous planning, governmental

policies, efforts of the enterprises and public participation.

Many state governments have their “Environmental Protection Advisory Committees” to take

effective measures for pollution control and these bodies also caution the government about

the adverse consequences if such measures are not taken on time. Also, the Indian Courts

have, from time to time used the Precautionary Principle and Polluter Pay Principle to make

the polluter compensate the victims of the pollution and also pay the cost for the damage

caused to the environment and to revive it to its original state.

However, the Air Act suffers from some shortcomings. The language was not all-inclusive

and the penalties are minimal. Also, public inputs are not sort and third party rights are

nonexistent. In addition, the administrative support for the act is also questionable. Although

the legislation provided for a separate enforcing network, the enforcement was placed under

the jurisdiction of the Water Boards. However, Water Boards are already resource starved

and in reality, could not cope with the burden of new responsibilities.

In light of above limitations, it is further recommended that the government should create an

environment reconstruction fund for facilitating research, standard setting, education and

related matters. The government should provide dedicated budgetary support for

environmental programs as a part of air purification project. In addition, a green awareness

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program needs to be sponsored including relating to environment in the primary and

secondary curriculum.

REFERENCES

Books:

 Bakshi, P.M., The Environment Protection Act, 1986, Indian Law Institute, New

Delhi, 1992.

 Jaiswal, P.S., Introduction, Environmental Law, Allahabad Law Publication, New.

Delhi, 2015

Webpages:

 http://nbaindia.org/uploaded/Biodiversityindia/Legal/23.%20Air%20(Prevention

%20and%20control%20of%20Pollution)%20Act%201981.pdf

 http://tripura.nic.in/tspcb/airact1981.pdf

 http://www.envfor.nic.in/legis/air/air1.html

 http://www.environmentallawsofindia.com/the-air-act.html

 http://www.indiaenvironmentportal.org.in/files/file/air%20act%201981.pdf

 http://www.legalserviceindia.com/article/l265-M.C.-Mehta-v.-Union-of-India.html

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 http://www.yourarticlelibrary.com/law/acts/summary-on-air-prevention-and-control-

of-pollution-act-1981-of-india/30191/

 http://www.youthkiawaaz.com/2011/01/taj-mahal-environment-pollution/

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