Global Vision Law Firm, led by Adv. Amarendra Kumar Dubey, represents individuals, businesses, industries and institutions in matters before the Commission for Air Quality Management (CAQM) — penalty notices, GRAP compliance directions, industrial emission and DG set disputes, construction and demolition dust control, and stubble burning notices — and in appeals against CAQM orders before the National Green Tribunal.
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The Commission for Air Quality Management in National Capital Region and Adjoining Areas was established under the CAQM Act, 2021, replacing the older Environment Pollution (Prevention and Control) Authority (EPCA) — a body widely seen as toothless because it had no penal powers. The CAQM was built differently.
The Act gives the CAQM exclusive jurisdiction over air quality matters in the NCR and adjoining areas — its directions prevail over conflicting orders of state governments, the CPCB, or state pollution control boards.
Unlike EPCA, Section 14 of the CAQM Act makes non-compliance with its directions a criminal offence — punishable with up to five years' imprisonment, a fine of up to ₹1 crore, or both.
The Commission can restrict activities affecting air quality, investigate pollution sources, frame codes and guidelines, and issue binding directions on inspections and regulation, through dedicated sub-committees.
The Act specifically excludes civil court jurisdiction over CAQM matters. Any challenge to a CAQM order or direction must be filed before the National Green Tribunal instead.
The Supreme Court has repeatedly pressed the CAQM to actually use its Section 14 powers rather than issuing show-cause notices alone — and complaints for prosecution have since been filed against officials for non-compliance. This tells you the Commission is under real pressure to enforce, not just warn. A CAQM notice today is far more likely to escalate to penalty proceedings than it once was, which is exactly why an early, well-documented response matters.
Adv. Amarendra Kumar Dubey, Founder & Managing Partner of Global Vision Law Firm, brings over 15 years of litigation experience, applying the same evidence-first, deadline-driven discipline from commercial litigation to CAQM matters — where timelines, documentation and hearing-readiness decide outcomes just as much as the underlying facts.
A CAQM show-cause notice or inspection report usually comes with a tight response window. Missing it, or replying without proper site evidence and compliance records, is what turns a manageable notice into a penalty proceeding. We prioritise an immediate first response over a perfect one.
Our practice covers the CAQM's full jurisdiction — Delhi and the adjoining NCR districts of Haryana, Uttar Pradesh and Rajasthan — along with representation before the NGT's Principal Bench in Delhi.
From a first show-cause notice to representation before the NGT on appeal.
Reviewing the notice, assembling site evidence and compliance records, and drafting a factually grounded, time-bound reply before the deadline the Commission has set.
Advising factories and facilities on stack emission norms, permitted fuel and DG set capacity rules, and representing clients where non-compliant units face closure or sealing orders.
Compliance advisory and notice defence for builders and developers on barricading, wetting schedules, debris handling, and GRAP-linked construction restrictions.
Representing farmers and agricultural entities facing environmental compensation demands or notices linked to crop residue burning under CAQM directions.
Advising fleet operators and businesses on PUC compliance, registration restrictions during GRAP stages, and responding to notices tied to vehicular emission violations.
Filing and arguing appeals before the National Green Tribunal against CAQM directions, penalty orders, or enforcement action — the only forum with jurisdiction to hear such challenges.
In-depth guides on CAQM matters, GRAP compliance, and the notices businesses face most often. Click "Learn More" on any topic for the full breakdown.
Matters before the Commission for Air Quality Management span everything from a first field inspection to penalty proceedings under Section 14 — and each stage has its own procedure and response window. We represent individuals, businesses and institutions at every stage, building a factual and documentary record that holds up whether the matter resolves at the Commission or moves on appeal to the NGT.
Learn More →A CAQM penalty notice typically follows an inspection or complaint alleging non-compliance with an existing direction — and under Section 14, contravention can attract imprisonment of up to five years, a fine of up to ₹1 crore, or both. We review the notice, the underlying inspection record, and your site's actual compliance status to build a response that addresses the allegation head-on rather than generically.
Learn More →Ongoing CAQM compliance means tracking which GRAP stage currently applies, what restrictions it triggers for your specific activity, and maintaining the inspection-ready documentation the Commission expects to see. We advise businesses, housing societies, schools and institutions on proactive compliance so a routine inspection doesn't turn into a notice in the first place.
Learn More →A show-cause notice gives you a narrow window to explain alleged non-compliance before further action is taken — and a generic or late reply can itself be treated as an admission. We draft show-cause replies backed by geo-tagged photographs, inspection logs, and compliance records, filed within the deadline the Commission has fixed.
Learn More →The Graded Response Action Plan sets out escalating restrictions across four stages tied to the Air Quality Index — and since November 2025, the CAQM has tightened the schedule so that curbs shift a full stage earlier than before. We advise businesses on exactly what applies at each current stage and defend clients where enforcement action follows a stage they say they weren't tracking.
Learn More →C&D sites face some of the most frequently enforced GRAP restrictions — barricading, water sprinkling, wheel-wash facilities, and debris handling norms that intensify as the GRAP stage rises. We advise developers and contractors on maintaining a defensible compliance record and represent them where enforcement action follows a site inspection.
Learn More →Crop residue burning notices under CAQM directions are treated differently from other violations — the Act excludes farmers from its criminal penalty provisions, but permits the Commission to levy environmental compensation instead. We advise agricultural clients on responding to such notices and on compensation demands linked to stubble burning.
Learn More →Vehicular restrictions escalate through the GRAP stages — from stricter PUC enforcement to entry restrictions on certain diesel and BS-III/BS-IV petrol vehicles at higher stages. We advise fleet operators and logistics businesses on compliance and represent clients facing penalties for registration or PUC violations tied to GRAP enforcement drives.
Learn More →Industrial units found operating without approved fuel, without emission control equipment, or beyond permitted stack limits can face closure directions in addition to Section 14 penalty proceedings. We help industrial clients respond to inspection findings, restore compliant operations quickly, and negotiate a path back to lawful running of the unit.
Learn More →Diesel generator sets above prescribed capacity face specific CAQM regulations on permitted use, especially during higher GRAP stages when DG set operation is curtailed except for essential services. We advise facilities on DG set compliance and defend clients issued notices for unauthorised or non-compliant DG set operation.
Learn More →Beyond criminal penalties, the CAQM and allied authorities can levy environmental compensation to recover the cost of pollution caused — a separate, often overlooked financial exposure distinct from any fine imposed under Section 14. We advise clients on contesting or negotiating environmental compensation demands tied to CAQM or SPCB findings.
Learn More →Air pollution in the NCR sits at the intersection of the Air (Prevention and Control of Pollution) Act, 1981, the Environment Protection Act, 1986, and the newer CAQM Act, 2021 — each administered by a different authority with overlapping but distinct enforcement powers. We help clients understand which law and which authority actually governs their specific situation before deciding on a response strategy.
Learn More →The CAQM Act excludes civil court jurisdiction over matters it covers — any challenge to a CAQM direction, penalty order, or enforcement action must go before the National Green Tribunal instead. We draft and argue such appeals, focusing on procedural fairness, factual accuracy of the inspection record, and proportionality of the action taken.
Learn More →The CAQM issues directions and can impose penalties at first instance, while the National Green Tribunal hears appeals against those directions and also handles broader environmental litigation outside the CAQM's specific NCR mandate. Understanding which body has jurisdiction over your specific grievance is the first strategic decision in any air pollution matter.
Learn More →Beyond CAQM appeals, the National Green Tribunal's Principal Bench in Delhi hears a wide range of environmental matters — pollution control board actions, environmental clearance disputes, and compensation claims for environmental harm. Our team represents clients before the NGT across these related matters, not only CAQM appeals.
Learn More →A clear, evidence-first process for handling any CAQM matter.
We review the notice or inspection report the moment we receive it, and calendar the response deadline before anything else — most CAQM matters are lost on time, not merit.
We assemble geo-tagged photographs, monitoring data, compliance certificates, and site records to establish the actual factual position, not just what the notice alleges.
Drafting and filing a factual, deadline-compliant reply or representation before the CAQM, addressing the specific allegation with supporting evidence.
Appearing before the Commission or concerned authority, and where appropriate, negotiating a compliance timeline rather than contesting every point.
Where the outcome at the Commission stage is adverse, filing and arguing an appeal before the National Green Tribunal within the prescribed limitation period.
Supporting clients through any Action Taken Report (ATR) requirements so the matter reaches a documented, verifiable closure rather than lingering open.
A general guide to the Graded Response Action Plan framework. Always confirm the current, official stage in force, since the CAQM revises thresholds and enforcement periodically.
| GRAP Stage | Air Quality Category | Typical Restrictions |
|---|---|---|
| Stage I | Poor | Public advisories, dust mitigation checks, stricter monitoring of construction sites and industrial units. |
| Stage II | Very Poor | Intensified traffic management, mechanised road sweeping, uninterrupted power supply push to cut DG set use. |
| Stage III | Severe | Halt on select construction/demolition activities, stricter industrial fuel and emission checks, curbs on certain DG sets. |
| Stage IV | Severe+ | Broader construction bans, restrictions on truck entry and certain vehicle categories, further industrial curtailment. |
The CAQM revised GRAP so that restrictions formerly triggered under a higher stage now apply a stage earlier — meaning Stage III curbs can now apply at what used to be Stage II territory, and so on. Businesses relying on older GRAP guidance risk being out of compliance without realising it. We confirm the current applicable stage and its specific restrictions as part of every consultation.
Litigation discipline applied to a fast-moving regulatory environment.
Over 15 years of litigation experience, bringing a deadline-first, evidence-first discipline to CAQM notices and NGT appeals alike.
From the current four-stage structure to the November 2025 tightening, we stay current so client compliance advice is never based on outdated thresholds.
Every reply we file is built around geo-tagged photographs, monitoring data, and compliance records — not general denials that carry no weight with the Commission.
You can visit our Delhi office, meet your lawyer, and walk through your compliance documentation face-to-face before we file anything.
We handle the full lifecycle of a CAQM matter — you don't need to find a new lawyer if the matter escalates to appeal.
Feedback from businesses we've represented in CAQM and air pollution matters.
"Our construction site got flagged during a GRAP-III inspection. The team pulled together our dust control logs and photos within a day and filed a reply that actually addressed what the inspector had noted — no closure order followed.
"We didn't realise our DG set usage during the winter months had fallen out of compliance until the notice arrived. Adv. Dubey's team handled the response and helped us set up a compliant protocol going forward.
"When our appeal went to the NGT, the team's evidence was already organised because they'd built the file properly from the first notice. That preparation made a real difference at the hearing.
Common questions about CAQM matters and air pollution compliance in Delhi NCR.
The CAQM is a statutory body set up under the Commission for Air Quality Management in National Capital Region and Adjoining Areas Act, 2021, replacing the earlier Environment Pollution (Prevention and Control) Authority (EPCA). It has exclusive jurisdiction over air quality matters in the National Capital Region and adjoining areas, and its directions override any conflicting order of a state government, the CPCB, or state pollution control boards.
Section 14 of the CAQM Act, 2021 makes non-compliance with the Commission's orders or directions a penal offence, punishable with imprisonment of up to five years, a fine of up to ₹1 crore, or both. Farmers are excluded from these penal provisions, though environmental compensation may still be levied for stubble burning.
Appeals against orders or directions of the CAQM lie before the National Green Tribunal (NGT), not before ordinary civil courts. The CAQM Act specifically excludes civil court jurisdiction over matters covered by the Act.
The CAQM's jurisdiction extends to the entire National Capital Region and adjoining areas, meaning it covers not just Delhi but also relevant districts of Haryana, Uttar Pradesh, and Rajasthan that fall within the NCR and adjoining areas, wherever air pollution sourced there affects the region.
Once the CAQM notifies a GRAP stage based on the Air Quality Index, restrictions apply automatically to activities such as construction and demolition work, use of diesel generator sets, industrial operations without approved fuel, and certain vehicle categories. Businesses or sites found non-compliant during inspections can receive show-cause notices or penalty proceedings even without a prior individual warning.
Visit our Delhi office for a free consultation, or connect with us online. Whether it's a first show-cause notice, a GRAP compliance question, or an appeal before the NGT — our team led by Adv. Amarendra Kumar Dubey is ready to help.
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