Bhopal Municipal Corporation vs Dr Subhash C. Pandey on 5 May, 2026

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    Supreme Court – Daily Orders

    Bhopal Municipal Corporation vs Dr Subhash C. Pandey on 5 May, 2026

    Author: Pankaj Mithal

    Bench: Pankaj Mithal

                                                                                  C.A. NO. 6174/2023
    
    
         ITEM NO.39                         COURT NO.9                     SECTION XVII
    
                                  S U P R E M E C O U R T O F         I N D I A
                                          RECORD OF PROCEEDINGS
    
                                        CIVIL APPEAL       NO. 6174/2023
    
         BHOPAL MUNICIPAL CORPORATION                                       APPELLANT(S)
    
                                                    VERSUS
    
         DR SUBHASH C. PANDEY & ORS.                                        RESPONDENT(S)
    
         [TO BE TAKEN UP AT 10.30 AM]
         (IA No. 113056/2025 - APPROPRIATE ORDERS/DIRECTIONS
         IA No. 141056/2024 - CONDONATION OF DELAY IN FILING
         IA No. 43110/2024 - CONDONATION OF DELAY IN FILING
         IA No. 198051/2023 - EXEMPTION FROM FILING C/C OF THE IMPUGNED
         JUDGMENT
    

    IA No. 141055/2024 – EXEMPTION FROM FILING O.T.
    IA No. 245823/2023 – PERMISSION TO APPEAR AND ARGUE IN PERSON
    IA No. 198050/2023 – STAY APPLICATION)

    WITH
    C.A. No. 7728/2023 (XVII)
    (IA No. 176665/2024 – EXEMPTION FROM FILING O.T.
    IA No. 196024/2024 – EXEMPTION FROM FILING O.T.
    IA No. 241136/2023 – STAY APPLICATION)

    SPONSORED

    Date : 05-05-2026 These matters were called on for hearing today.

    CORAM :

    HON’BLE MR. JUSTICE PANKAJ MITHAL
    HON’BLE MR. JUSTICE S.V.N. BHATTI

    For Appellant(s) Ms. Vanshaja Shukla, AOR
    Ms. Gunjan Chowksey, Adv.

    Ms. Ankeeta Appanna, Adv.

    Mr. Siddhant Yadav, Adv.

    For Respondent(s) Mrs. Aishwarya Bhati, A.S.G.
    Ms. Anupriya Srivastava, Adv.
    Ms. Gargie Boss, Adv.

    Mr. Gurmeet Singh Makker, AOR
    Mrs. Chitragda Rastvara, Adv.
    Mr. Balendu Shekhar, Adv.

    Signature Not Verified Mr. Udit Dediya, Adv.
    Digitally signed by
    GEETA AHUJA

    Mr. Harshvardhan Pandey, Adv.

    Date: 2026.05.06
    10:44:19 IST
    Reason:

    Mr. Raghavendra Pratap Singh, AOR
    Mr. Ram Kumar, Adv.

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    C.A. NO. 6174/2023

    Mr. Mahendra Pratap Singh, Adv.
    Mr. Akshat Kashyap, Adv.

    Mr. Arpit Gupta, AOR
    Mr. Dilpreet Singh, Adv.

    Mr. Divya Pratap Parmar, Adv.
    Ms. Akansha Agarwal, Adv.

    Mr. Aadil Yar Chaudhary, Adv.
    Mr. Shariq Yar Chaudhary, Adv.

    Mr. Pashupathi Nath Razdan, AOR
    Mr. Abhimanyu Singh, Adv.

    Mr. Abhinav Srivastav, Adv.
    Ms. Maitreyee Jagat Joshi, Adv.
    Mr. Astik Gupta, Adv.

    Ms. Akanksha Tomar, Adv.

    Mr. Shravan Bagora, Adv.

    Mr. Raghav Sharma, Adv.

    Mr. Salvador Santosh Rebello, AOR
    Mr. Jaskirat Pal Singh, Adv.
    Mr. Mridul Shukla, Adv.

    Mr. Pranjal Pandey, Adv.

    Ms. Moulishree Pathak, Adv.

    Mr. Saurabh Balwani, AOR
    Mr. Chirag Pathor, Adv.

    Mr. Vikramaditya Singh, AOR
    Mr. Qasim Ali, Adv.

    Mr. Arjun Singh, Adv.

    Ms. Yashika Gupta, Adv.

    Mr. R Venkat Prabhat, Adv.

    Ms. Pragati Neekhra, AOR
    Mr. Aryan Vaibhav Srivastava, Adv.

    Mr. Aaditya Aniruddha Pande, AOR
    Mr. Siddharth Dharmadhikari, Adv.
    Mr. Shrirang B. Varma, Adv.
    Mr. Sourav Singh, Adv.

    Ms. Chitransha Singh Sikarwar, Adv.

    Mr. Sameer Abhyankar, AOR
    Mr. Krishna Rastogi, Adv.

    Mr. Aryan Srivastava, Adv.

    Mr. Surjendu Sankar Das, AOR
    Ms. Yoovika Toor, Adv.

    UPON hearing the counsel the court made the following

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    C.A. NO. 6174/2023

    O R D E R

    1. This Earth and this Nation are what we all have in common. We are
    confident that a group of committed civil servants, officers, people’s
    representatives, and foot soldiers vested with the power to administer
    the SWM Rules, 2026, can spread the light of preserving this planet and
    this Nation from man-made destruction. The statutory framework
    introduced under the Environment (Protection) Act, 1986, will be the
    change for the progress and well-being of the Indian citizens. It should
    be the shared commitment to leave behind a tolerable planet for future
    generations. Their thanks for preserving the planet will not be heard by
    us, but our willingness to sacrifice, work tirelessly for them, and
    dedicate ourselves will leave the mark of our conscience for times to
    come.

    2. Apropos the order dated 29.04.2026, the (i) Secretary, Ministry of
    Environment, Forest and Climate Change (“MoEFCC”); (ii) Secretary,
    Department of Drinking Water and Sanitation, Ministry of Jal Shakti;

    (iii) Secretary, Ministry of Housing and Urban Affairs (“MoHUA”); (iv)
    Secretary, Ministry of Panchayati Raj; (v) Secretary, Ministry of Rural
    Development; and the Chief Secretaries of the States and Union
    Territories have participated in today’s hearing. A few Chief Secretaries
    contributed to the hearing, and others have appreciated the need of the
    hour to implement the SWM Rules, 2026, and the statutory obligations
    on the Executive and local bodies. Most of the State lawyers also
    attended the proceedings.

    3. During the hearing, this Court has made it clear that the current
    common effort by all stakeholders is to persuade Solid Waste generators
    to participate and prevent environmental pollution contrary to the law’s
    mandate. This Court, as intimated in its earlier orders, reposes trust in
    the local, state and central administration, and if the desired result is
    not achieved, decides to strengthen the administration within the

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    C.A. NO. 6174/2023

    framework of the Environment Protection Act, 1986, before finally
    declaring the inbuilt incompetency in the administrative set-up to
    handle the solid waste generated by human activity.

    4. Keeping the above in perspective, the MoEFCC is directed to issue a
    notification under Section 23 and delegate the powers under Section 5 of
    the Environment Protection Act, 1986, to the District Collectors across
    the country for a period of one year, exclusively for supervising,
    administering and implementing SWM Rules, 2026, within their
    jurisdictional limits. The District Collectors are directed to constitute
    and dedicate a ‘Special Cell’ not only to oversee the implementation, but
    in given circumstances, to issue directions for the stoppage of
    water/electricity to bulk generators of solid waste who disobey the
    directions or disregard the Rules. The District Collectors are directed to
    conduct virtual spot inspections of the dumping sites, implement the
    rules, and fortnightly prepare and forward the report to the designated
    Secretaries in the respective States. The directions, if any, issued by the
    District Collectors under the delegated authority are understood as
    directives issued in furtherance of the orders of this Court.

    5. The Regional Officers of the respective Pollution Control Boards shall
    also be included in the Special Cell directed to be set up under the
    supervision of the District Collector. The Regional Officers of the
    respective Pollution Control Boards are directed to conduct field
    inspections of authorised and unauthorised dump yards/sites within
    their jurisdictions and forward photographs to the District Collector and
    Local Bodies for further action and compliance. The District Collector
    issues directions to ensure that Solid Waste is transported, managed,
    and disposed of by vehicles authorised by the Local Bodies. This enables
    the Local Bodies not only to regulate but also to prevent unauthorised
    dumping along roadsides, railway tracks, lakes, foothills, etc.

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    C.A. NO. 6174/2023

    6. The District Collectors are directed to prepare a brief summary of the
    performance/progress of the implementation of the SWM Rules once a
    month and submit it to the respective secretaries. The respective
    secretaries, in turn, with an abstract, certifying assessment of progress
    and deficiency within their respective states, forward the report to the
    concerned Ministries, viz, (i) Secretary, MoEFCC; (ii) Secretary,
    Department of Drinking Water and Sanitation, Ministry of Jal Shakti;

    (iii) Secretary, MoHUA; (iv) Secretary, Ministry of Panchayati Raj; and (v)
    Secretary, Ministry of Rural Development for filing the abstract of the
    report in this Court.

    7. The first phase of monitoring by the Secretaries in the Union of India
    and the Secretaries in the State/UTs of municipal corporations,
    municipalities and gram panchayats is set out as follows:

    (1) The District Collectors are directed to communicate the orders of
    this Court dated 19.02.2026, 29.04.2026 and 05.05.2026 (the
    present order) through the respective Commissioners/Executive
    Officers/Panchayat Secretaries, who shall, in turn, communicate
    the same to the elected ward members/corporators/councillors.

    (2) The State Governments are directed to incentivise good
    performance by prioritising grants to which well-performing local
    authorities or local bodies are entitled. Conversely, defaulting local
    bodies shall attract penal consequences for non-compliance with
    the Rules.

    (3) The Secretary, Ministry of Panchayati Raj, and the Urban
    Development Secretary are directed to explore a roadmap to
    incorporate knowledge of and obligations under the Solid Waste
    Management Rules into the functioning of elected representatives
    as part of the representative process in local bodies.

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    C.A. NO. 6174/2023

    8. The Secretaries, viz, (i) Secretary, MoEFCC; (ii) Secretary, Department of
    Drinking Water and Sanitation, Ministry of Jal Shakti; (iii) Secretary,
    MoHUA; (iv) Secretary, Ministry of Panchayati Raj; and (v) Secretary,
    Ministry of Rural Development, are directed to deliberate upon and
    explore the inclusion of contributions under Corporate Social
    Responsibility (“CSR”) by industries for the establishment of
    Compressed Biogas plants or such other latest technology as may be
    available for converting waste into energy into the extant scheme and
    the modalities for availing the funds. Such contributions shall, to the
    requisite extent, compensate and follow principles similar to the Polluter
    Pays Principle for the overall upkeep of local bodies. This is not to
    strictly enforce the principle of the Polluter Pays, but for the
    amelioration of the environment, CSR funds shall be utilised exclusively
    for the improvement of local bodies within whose jurisdictions the
    contributing industries are located. We direct that such contributions
    be prioritised within the schemes operated by the Union of India.

    9. The Chief Secretaries are directed to circulate the Form IV under the
    SWM Rules, 2026, by 15th May, 2026; receive the filled data, collate it,
    and forward it to the Respective Secretaries of the Union of India for
    enhanced and efficient performance monitoring of the local bodies.

    10. The Chief Secretaries are directed to identify tourist-centric beaches,
    tourist places, and pilgrim centres, and to put in place a special
    mechanism for implementing the SWM Rules, 2026, at such locations.

    11. The Chief Secretaries are directed to conduct an inventory of the
    implementation of the Plastic Waste Management Rules, 2016 (as
    amended from time to time), in their respective jurisdictions and,
    through the Secretary, MoEFCC, submit a report on strict compliance
    with the Plastic Waste Management Rules, 2016. Including handholding

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    C.A. NO. 6174/2023

    of Gram Panchayats for identification and registration of Bulk Waste
    Generators’ activities related to EBWGR certification, Legacy waste,
    dumpsite remediation, etc., as applicable in rural areas. Presently,
    nearly 1,700 ULBs have registered on the CPCB’s EPR Portal. The State
    must advise all ULBs, giving a timeline in a graded manner, to register
    on the EPR Portal.

    12. Annexures 8 and 9 in the latest status report filed by the Union of India
    refer to the responses by States/Union Territories to the identified
    bottlenecks and the compilation of action plans submitted by
    States/Union Territories. The concerned Ministries in the Union take up
    these issues and respond to the bottlenecks within three weeks from
    today. The Secretary, MoEFCC, is treated as the nodal secretary for
    filing reports for and on behalf of all the departments. The supervision,
    administration and implementation of the SWM Rules, 2026, shall
    remain with the respective departments, and the Secretaries are called
    upon not to forward the reports sent by the States, but have them
    scrutinised or examined in the respective departments and submit an
    abstract to this Court.

    13. In the course of deliberation, it has been pointed out that, for the
    present, the administrative sanction for advancing Solid Waste
    Management Projects is being delayed, and may not be adhered to. Our
    attention is drawn to MoHUA guidelines for Swachh Bharat Mission-
    Urban (SBM-U). There are three levels, and considering the methodology
    adopted in SBM-U, we are of the view that Solid Waste Management
    Projects are undertaken and approved in accordance with SBM-U.
    Consequently, we direct that the 3 levels, from ULBs to State
    Governments to the Central Government, be integrated in a paperless
    manner through technology under the Swachh Bharat Mission – Urban.
    There is no requirement of any other approval at the Council or any
    other forum/authority. A similar paperless, technology-driven lean

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    C.A. NO. 6174/2023

    approval method could be used by all State Governments for all Solid
    Waste Management projects funded through sources other than SBM-U.
    Once the projects are approved by the National Advisor and Review
    Committee (“NARC”), the DPR preparations and technical sanctions
    must be delegated to competent authorities in the State, so that no
    more than three levels are involved in such sanctions for Solid Waste
    Management projects. The respective State General Financial Rules
    (GFRs) may be considered appropriately. Once the projects are approved
    by the NARC, the State matching share must also be kept ready to avoid
    any delay in providing it.

    14. The financial difficulties faced by the Union, the Union Territories and
    the States have been brought to our notice. We record the challenges
    and the views expressed by the States regarding the financial challenges
    to report compliance under the SWM Rules, 2026. With respect to
    addressing Financial Availability for SWM Rules 2026 implementation:

    14.1 SBM-U and SBM-Grameen funds are available to States for
    implementing SWM projects in local bodies. Timely and complete
    utilisation of these funds is a mandate of the State Governments.

    14.2 Many States have made their own State budget provisions to
    supplement the SWM & sanitation activities.

    14.3 Many States have effectively been able to mandate funds from the
    Finance Commission for sanitation spending.

    14.4 Large ULBs have also been able to bring in CSR support from
    corporates. The Bio-CBG is currently witnessing interest from many
    PSUs. States can fully leverage the same.

    14.5 Large PPP projects for SWM can also be prepared by State

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    C.A. NO. 6174/2023

    Governments on a regional/ cluster basis, and funds can be availed
    too from the recently launched Urban Challenge Fund (UCF) by
    MoHUA.

    14.6 States should plan sanitation and SWM projects by converging
    multiple funding sources. Especially in rural areas, States must make
    adequate provisions from their own resources so that Gram
    Panchayats can carry forward these activities.

    15. On the above, we direct the Secretary, MoHUA, to convene a meeting
    with all the Chief Secretaries and place before this Court, a resolution
    on how to address the financial problem faced by the local bodies, and
    the extent to which the Union of India can assist the States/UTs.

    16. The inadequate human resources in Local Bodies have been brought to
    this Court’s notice. We take note of the population growth in the
    Country and the increased density of population at all three levels –
    Villages, Municipal and Corporation.

    17. Presently, there is no material to appreciate the enhancement of human
    resources or wherewithal by the State Governments, commensurate
    and proportionate to the increased population, and the consequent
    increase in Solid Waste. Therefore, we direct the States/UTs to review
    the sanctioned and available manpower in urban and rural local bodies
    to fill the identified vacancies in a time-bound manner. States/UTs may
    also consider creating a dedicated cadre within rural local bodies,
    funded from their own resources, for SWM and sanitation service
    delivery, thereby developing the technical capacities of rural local
    bodies. Gram Panchayats are categorised by population size to assign
    appropriate staff, ensuring at least a full-time Panchayat Secretary and
    technical support in every Gram Panchayat. Over and above the State
    matching share under SBM-U, the State should provide necessary

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    C.A. NO. 6174/2023

    interventions for short-term and long-term capacity building of local
    bodies.

    18. The Secretary, MoEFCC, is directed to exclusively take up the legacy
    waste issues with the Chief Secretaries, receive their response and file a
    report on further direction noted on this behalf.

    19. The progress of the first phase is monitored on 25.05.2026 and,
    subsequently, on 15.07.2026. The establishment of mobile courts will
    be examined after hearing the parties on 15.07.2026.

    20. The Orders of this Court are translated into regional languages by the
    respective States, and along with the soft copy of this Order, the
    translated version is circulated to all concerned.

    21. On appreciating the compliance reports filed by the States, we notice
    that on the following points, the State Governments implement and file
    a status report to the Secretary, MoHUA and the Secretary, MoEFCC for
    further action at both ends:

    a. Local Self Governments (“LSGs”) must bring in source segregation
    with focus on BWGs. Door to door mapping of waste generators can
    be done with the Safai Supervisors challaning the non-compliant
    generators. The focus on BWGs needs to be complete and absolute.

    b. LSGs must upgrade their collection and transportation to have
    completely closed vehicles for secondary transportation.

    c. LSGs must use technology to map Garbage Vulnerable Points (GVPs)
    and ensure that there is no recurrence by using a mix of penalties
    and improved collection systems.

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    C.A. NO. 6174/2023

    d. All high footfall areas must be identified by that are garbage-prone
    and a mix of initiatives like – Swachhata Marshals (community
    patrollers), strict enforcement amongst vendors, twice-a-day
    sweeping, and additional manpower as per seasonality requirements,
    declarations of no-Single-Use Plastice zone and its enforcement, etc.

    e. Special Purpose Vehicle is set up only for Solid Waste Management
    with specialisation in the processing of all streams of waste. While
    primary collection and transportation of waste can be the ULBs’
    mandate, efficient operation of processing plants can be the SPVs’
    specialised domain. Even collection and transportation can be
    handed over to the SPV, as per well-structured KPIs.

    f. ULBs must designate at least 30 percent of their total funds for
    effective city cleanliness and solid waste management.

    g. City cleanliness being a priority, States/UTs must evolve Ward
    cleanliness ranking which must be a criteria for providing incentives
    to a Ward. The Ward member/councillor/corporator will lead these
    activities with the help of a Ward Swachhata Committee with select
    members of the Ward as voluntary members.

    h. The city must designate waste handling areas in all new areas of
    planned expansion.

    i. There should be no dumping of waste or legacy dumpsites. Only
    rejects should be allowed to sanitary scientific landfill. The
    decentralised waste management sites must also be used to educate
    children and other citizens.

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    C.A. NO. 6174/2023

    j. All wards should have a neighbourhood RRR centre (Reduce -Reuse-

    Recycle) Centre so that citizens can use this to donate their used
    materials, electronic products, clothes, books, etc.

    k. Each big city must tie up with industry so that the Material Recovery
    Facility is the pick-up point for industrial recycling, including
    plastics, and the city can generate Extended Producer Responsibility
    Certificates from the same.

    22. The Urban, Rural, and MoEFCC ministries are directed to set out
    ‘short’, ‘medium’, and ‘long-term’ objectives to be accomplished by the
    State/UTs and their Local Bodies. The concerned Ministries shall file
    separate abstract statements in the following format by 24th of May,
    2026 on the percentage of accomplishment by the State/UTs and their
    Local Bodies:

    Urban Local Bodies Phase I Targets

    State Target Percent Achieved Remarks

    Andaman
    and Nicobar
    Islands
    Andhra
    Pradesh
    Arunachal
    Pradesh

    Assam

    Bihar

    Chandigarh

    Chhattisgarh

    Dadra and
    Nagar Haveli

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    C.A. NO. 6174/2023

    and Daman
    and Diu

    Delhi (NCT)

    Goa

    Gujarat

    Haryana

    Himachal
    Pradesh
    Jammu and
    Kashmir

    Jharkhand

    Karnataka

    Kerala

    Ladakh

    Lakshadweep

    Madhya
    Pradesh

    Maharashtra

    Manipur

    Meghalaya

    Mizoram

    Nagaland

    Odisha

    Puducherry

    13
    C.A. NO. 6174/2023

    Punjab

    Rajasthan

    Sikkim

    Tamil Nadu

    Telangana

    Tripura

    Uttar
    Pradesh

    Uttarakhand

    West Bengal

    Rural Local Bodies Phase I Targets

    State Target Percent Achieved Remarks

    Andaman and
    Nicobar
    Islands
    Andhra
    Pradesh
    Arunachal
    Pradesh

    Assam

    Bihar

    Chandigarh

    Chhattisgarh

    Dadra and
    Nagar Haveli
    and Daman

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    C.A. NO. 6174/2023

    and Diu

    Delhi (NCT)

    Goa

    Gujarat

    Haryana

    Himachal
    Pradesh
    Jammu and
    Kashmir

    Jharkhand

    Karnataka

    Kerala

    Ladakh

    Lakshadweep

    Madhya
    Pradesh

    Maharashtra

    Manipur

    Meghalaya

    Mizoram

    Nagaland

    Odisha

    Puducherry

    Punjab

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    C.A. NO. 6174/2023

    Rajasthan

    Sikkim

    Tamil Nadu

    Telangana

    Tripura

    Uttar Pradesh

    Uttarakhand

    West Bengal

    23. The Registry is directed to communicate a copy of the Order dated
    19.02.2026 to the Registrar Generals/Registrars of High Courts for taking
    appropriate action as an institution of the Judiciary in implementing the
    SWM Rules, 2026.

    24. List on 25.05.2026 at 10.30 AM.

       (Nidhi Mathur)                                     (Geeta Ahuja)
    Court Master (NSH)                                   Deputy Registrar
    
    
    
    
                                            16
    

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