Vehicular Pollution and Environment Protection | Environment Law Research Paper |

Research Methodology
AIMS AND OBJECTIVES:
This research paper is an attempt to understand the pollution caused by the increasing vehicular traffic in India and its impact on the Environment around us.
RESEARCH ISSUES: 1. Meaning and Kindsof Pollution 2. Vehicular Pollution and its effects on health and the environment 3. Technical Measure (like Emission Standards) and Non Technical Measures(like prevention of Fuel Adulteration) 4. Fuel Economy Standards and phasing out old Vehicles.
SCOPE AND LIMITATIONS:
This research paper is limited in the sense that it tries to study the pollution caused to the environment by the vehicular traffic. Pollution is a broad and extensive topic but this topic tries to limit itself to such pollution caused by the environment and not all other kinds of pollution.
METHOD OF WRITING:
This paper has largely been written in an investigative and an analytical style.
SOURCES OF DATA:
The researcher has primarily referred to secondary sources such as books and articles while writing this research paper.
MODE OF CITATION:
A uniform mode of citation has been used throughout this research paper which is based loosely on the style prescribed in The Bluebook: A Uniform System of Citation(Columbia Law Review Ass’n et al. eds., 17th ed. 2000).
Table of Contents Sr No | Topic | Page No | 1 | Introduction | 3,4 | 2 | Pollution | 4 | 3 | Kinds of Pollution | 4 | 4 | Vehicular Pollution | 5 | 5 | Major vehicle/fuel pollutants | 6 | 6 | Health and environmental effects of vehicular pollutants | 6 | 7 | Various pollutants and its effects on Human health | 7 | 8 | Emission standards for Vehicles | 8 | 9 | Emission Standard for controlling pollution from new vehicles in India | 9 | 10 | Noise Standards for Vehicles | 10 | 11 | Non-Technical Measure | 10,11 | 12 | Control of Fuel Adulteration | 11,12 | 13 | Future Strategies for IndiaZero Emission Vehicles and Cleaner Fuels | 12,13 | 14 | Old vehicles phase-out programme and Development of guidelines for scrap page of old vehicles | 14 | 15 | Developing fuel economy standard | 15 | 16 | M.C. Mehta v. Union of India and Others | 15,16 | 17 | M.C.Mehta v. Union of India | 16,17 | 18 | State of West Bengal and Ors v. S.K Nurul Amin | 17 |
Introduction
Air pollution is one of the serious environmental concerns of the urban Asian cities including India where majority of the population is exposed to poor air quality. The health related problems such as respiratory diseases, risk of developing cancers and other serious ailments etc. due to poor air quality are known and well documented. Besides the health effects, air pollution also contributes to tremendous economic losses, especially in the sense of financial resources that are required for giving medical assistance to the affected people. The poor are often the most affected segment of the population as they do not have adequate measures to protect themselves from air pollution.
Most of the Indian Cities are also experiencing rapid urbanization and the majority of the country’s population is expected to be living in cities within a span of next two decades. Since poor ambient air quality is largely an urban problem this will directly affect millions of the dwellers in the cities.
The rapid urbanization in India has also resulted in a tremendous increase the number of motor vehicles. The vehicle fleets have even doubled in some cities in the last one decade. This increased mobility, however, come with a high price. As the number of vehicles continues to grow and the consequent congestion increases, vehicles are now becoming the main source of air pollution in urban India. Although, the air quality can be improved through a combination of technical and non-technical measures, legislative reforms, institutional approaches and market-based instruments, there are certain unique challenges which the country has to face in tackling the problem of urban air pollution. These include, the transport features which are different from the developed countries particularly in terms of the types of vehicles commonly used, the manner in which the road network is operated and sharing of the limited space by pedestrians and non-motorized modes with modern vehicles in Indian cities. Vehicles in India are often much older and usually comprise technologies considered as out-dated in the developed world. The institutions responsible for managing urban air quality are also not as well developed as those in the developed countries. The country has however taken a number of measures for the improvement of the air quality in cities. These include, right from the improvement in the fuel quality, formulation of necessary legislation and enforcement of vehicle emission standards, improved traffic planning and management etc. The non-technical measures taken include, awareness raising regarding the possible economic and health impacts of air pollution and available measures for improving air quality, increasing use of cleaner fuels and purchase of vehicles with advance emission control devices, increasing institutional framework and capacity building for the monitoring of vehicle emissions.
The research paper is in reference to a review of the vehicular emission problems in Indian cities, the various developments that have taken place in the past including the studies conducted for assessment of the air quality in cities, the legislation and standards adopted for the control of vehicle emissions, the role of the various concerned agencies, the steps taken for improvement in the quality of the automotive fuel, the overall impact of these measures and the future strategy to be adopted for vehicular emission reduction and related issues.

Pollution
Pollution can be defined as “limited to situations in which the outer ambient atmosphere contains materials in concentrations which are harmful to man and his environment.”
Pollution is the introduction of contaminants into an environment, of whatever predetermined or agreed upon proportions or frame of reference; these contaminants cause instability, disorder, harm or discomfort to the physical systems or living organisms therein. Pollution can take the form of chemical substances, or energy, such as noise, heat, or light energy. Pollutants, the elements of pollution, can be foreign substances or energies, or naturally occurring; when naturally occurring, they are considered contaminants when they exceed natural levels. Pollution is often classed as point source or nonpoint source pollution.
Kinds of Pollution * Air Pollution * Water Pollution * Soil Pollution * Noise Pollution * Radioactive Pollution * ThermalPollution
Vehicular Pollution
Motor vehicles have been closely identified with increasing air pollution levels in urban centres of the world. Besides substantial CO2 emissions, significant quantities of CO, HC, NOx, SPM and other air toxins are emitted from these motor vehicles in the atmosphere, causing serious environmental and health impacts. Like many other parts of the world, air pollution from motor vehicles is one of the most serious and rapidly growing problems in urban centres of India (UNEP/WHO, 1992). The problem of air pollution has assumed serious proportions in some of the major metropolitan cities of India and vehicular emissions have been identified as one of the major contributors in the deteriorating air quality in these urban centres The problem has further been compounded by the concentration of large number of vehicles and comparatively high motor vehicles to population ratios in these cities. Reasons for increasing vehicular pollution problems in urban India are as below: * High vehicle density in Indian urban centres. * Older vehicles predominant in vehicle vintage * Predominance of private vehicles especially cars and two wheelers, owing to unsatisfactory public transport system, thereby causing higher idling emissions and traffic congestion. * Absence of adequate land use planning in development of urban areas, thereby causing more vehicle travel and fuel consumption * Inadequate inspection & maintenance facilities. * Adulteration of fuel & fuel products * Improper traffic management system & road conditions * High levels of pollution at traffic intersections * Absence of effective mass rapid transport system & intra-city railway networks * High population exodus to the urban centres. * Increasing number Skyrocketing buildings in the urban areas causes stagnation of the vehicular emissions to the ground level and limiting its proper dispersion.

Major vehicle/fuel pollutants
Automotive vehicles emit several pollutants depending upon the type of quality of the fuel consumed by them. The release of pollutants from vehicles also include fugitive emissions of the fuel, the source and level of these emissions depending upon the vehicle type, its maintenance etc. The major pollutants released as vehicle/fuel emissions are: * Carbon monoxide * Nitrogen oxides * Photochemical oxidants * Air toxics namely benzene, aldehydes, 1-3 butadiene, lead, particulate matter, hydrocarbon, oxides of sulphur and polycyclic aromatic hydrocarbons.
While the predominant pollutants in petrol/gasoline driven vehicles are hydrocarbons and carbon monoxide, the predominant pollutants from the diesel based vehicles are Oxides of nitrogen and particulates.

Health and environmental effects of vehicular pollutants
Vehicular emissions have damaging effects on both human health and ecology. There is a wide range of adverse health/environmental effects of the pollutants released from vehicles. The effects may be direct as well as in-direct covering right from reduced visibility to cancers and death in some cases of acute exposure of pollutants specially carbon monoxide. These pollutants are believed to directly affect the respiratory and cardiovascular systems. In particular, high levels of Sulphur dioxide and Suspended Particulate Matter are associated with increased mortality, morbidity and impaired pulmonary function.

POLLUTANT | EFFECT ON HUMAN HEALTH | Carbon Monoxide | Affects the cardio vascular system, exacerbating cardiovascular disease symptoms, particularly angina; may also particularly affect foetuses, sick, anaemic and young children, affects nervous system impairing physical coordination, vision and judgments, creating nausea and headaches, reducing productivity and increasing personal discomfort. | Nitrogen Oxides | Increased susceptibility to infections, pulmonary diseases, impairment of lung function and eye, nose and throat irritations. | Sulphur Dioxide | Affect lung function adversely. | Particulate Matter and Respirable Particulate Matter (SPM and RPM) | Fine particulate matter may be toxic in itself or may carry toxic (including carcinogenic) trace substance, and can alter the immune system. Fine particulates penetrate deep into the respiratory system irritating lung tissue and causing long-term disorders. | Lead | Impairs liver and kidney, causes brain damage in children resulting in lower I.Q., hyperactivity and reduced ability to concentrate. | Benzene | Both toxic and carcinogenic. Excessive incidence of leukaemia (blood cancer) in high exposure areas. | Hydrocarbons | Potential to cause cancer |

Emission standards for Vehicles
Vehicle emission standards are the primary technical policy for controlling emissions from vehicles. The Motor Vehicles Act, 1988, and the Central Motor Vehicles rules (CMVR) 1989, are the principal instruments for regulation of motor vehicular traffic /emissions throughout the country. The implementation of various provisions of this Act rests with the state governments. The Ministry of Road Transport and Highways acts as a nodal agency for the formulation and implementation of various provisions of the Motor Vehicle Act and CMVR. The Ministry of Road Transport & Highways is advised by the CMVR–Technical Standing Committee on various technical aspects related to CMVR. This Committee has representatives from organizations such as the Ministry of Heavy Industries, Ministry of Road Transport and Highways (MoRT&H), Bureau of Indian Standards, testing agencies such as the Automotive Research Association of India, Vehicle Research and Development Establishment, Central Institute of Road Transport, and industry representatives from the Society of Indian Automobile Manufacturers and Automotive Component Manufacturers Association
Although the Air Act, 1981, and the Environment (Protection) Act, 1986 provide for the prescription of automobile emission standards by the CPCB (Central Pollution Control Board) or Ministry of Environment and Forests, implementation and enforcement of these standards is the responsibility of the Union Ministry of Road Transport and Highways or the Transport Commissioner at the state level. For issues related to the implementation of emission regulations the MoRT&H is advised by a separate committee the Standing Committee on Implementation of Emission Legislation. The MoRT&H has formed this committee to discuss future emission norms, related test procedures and the implementation strategy.

Emission Standard for controlling pollution from new vehicles in India
The first initiative to regulate vehicle emissions in India started in the year 1989 when Ministry of Environment & Forests constituted an expert committee to notify the emission standards for both new and in-use vehicles under the Environment (Protection) Act. The first Indian emission regulations were idle emission limits which became effective in 1989. These idle emission regulations were soon replaced by mass emission limits for both gasoline (1991) and diesel (1992) vehicles. From 1995 all new gasoline passenger cars in the four metros were required to compulsorily fit catalytic converters, which were further, made applicable to all metros, state capitals and Union Territories from 1998. Sooner the need for tighter emission norms surfaced owing to the growing problems of vehicular emissions particularly in the metro cities and in 1996 more stringent norms came into force. In year 1998 the Government notified emission norms for vehicles fitted with catalytic converters, which were over 50% stricter than the 1996 norms. In 2000, following the European model, Euro-I equivalent emission norms called India Stage-I were notified throughout the country which were overtaken by Euro-II equivalent Bharat Stage-II norms in the four metro cities by 2001. Bharat Stage II norms, were introduced in the National Capital Region (NCR) for passenger vehicles up to GVW 3.5T from 1 April 2000 and for heavier vehicles from 24 October 2001 in the National Capital Territory (NCT) of Delhi. In Mumbai, were extended from 1 January 2001 and 31 October 2001 respectively. For both Chennai and Kolkata, the corresponding dates are 1 July 2001 and 31 October 2001, respectively. Fitness norms for commercial vehicles were tightened with effect from 28 March 2001. The emission norms for CNG and LPG vehicles were notified in the year 2000 and 2001, respectively. The Central Motor Vehicles Rules have been frequently amended to take into account the changing requirements. The emission norms in India are behind European ones by four to five years for all categories of vehicles except for two- and three-wheelers. For them, Bharat 2000 norms are far stricter than the Euro II norms and are one of the most stringent in the world.

Noise Standards for Vehicles
The noise level in cities is rapidly increasing due to heavier traffic and more powerful engines. On top of that there is a growing number of vehicles which are much louder and do not adhere to Noise Standards. In the combustion engines fuel explodes in cylinders 1000 times/min (for 4-stroke, 2-cylinder engines at 1,000 rpm) creating sound with 16.7 Hz fundamental frequency and many harmonics. Without an engine block/enclosure and muffler these explosions will be very noisy (194 dB at close distance) and deadly. The vehicles with modified mufflers or straight pipes can produce sound levels which are deafening (up to 120 dB at 15.2 m distance) and are up to 40 dB louder than vehicles equipped with stock muffler. The noise limits for vehicles at manufacturing stage were notified by MoEF under the Environmental (Protection) Rules, 1986.

Non-Technical Measure
The non-technical measures in the form of Better Traffic Management system; Augmentation in public transport system, Implementation of Market based instruments i.e. fiscal instruments, generating mass awareness, drives for checking adulteration etc. have been taken up. Details on non-technical measures those have been taken up for controlling vehicular pollution are described in the subsequent paragraphs
Traffic pattern on Indian roads is highly heterogeneous in nature. The 23 metros contribute towards 35% of the total motor vehicles in the country. In terms of numbers on road two wheelers dominate the scene with about 65% of share in total number of vehicles whereas in terms of percent share of trips, buses cover the maximum passenger kms of about 36% of total. The total vehicles ownership is very low in our country with only 22 vehicles per thousand of population as against 675, 598, 517, 586, 272 and 222 motor vehicles per 1000 of population in U.S.A, France, U.K, Japan, Malaysia and Mexico respectively.
The penetration level of two wheelers (two wheelers/1000 persons) is much higher compared to developed countries

Traffic regulation is the sole responsibility of the traffic police of the area. Apart from these there are many other private and government organizations which act as support agencies. There are institutes like CRRI, VRDE etc. in India involved in the research work in the field of roads and automobile engineering. There are many studies done by the organizations like CRRI, CIRT, and RITES etc. on various aspects of Traffic and Transportation Planning in India which include Policies, planning, forecasting, public mass transport, personalized transport, Intermediate public transport and general studies.

Control of Fuel Adulteration
Adulteration of the transport fuels at the point of sale and during transportation has become an acute problem in the country. Transport fuels are often adulterated with other cheaper or by product or waste hydrocarbon stream for monetary gains. For example, gasoline (petrol) is believed to be widely adulterated with naphtha, natural gas liquids, kerosene, waste solvents, by product petroleum stream, etc. With large number of adulterants available in the market, both indigenous and imported, the magnitude of the problem of fuel adulteration has grown into alarming proportions in the past few years. Off late India has also taken some initiatives to tackle this problem.

As per the Ministry of Petroleum & Natural Gas (MoPNG) following Steps have been undertaken to control Adulteration of Fuel in the country. * Oil companies carryout filter paper test, density checks, blue dyeing of PDS kerosene and furfural doping of PDS kerosene.

MoPNG has also advised State/UT Government from time to time

* To ensure upliftment of kerosene by the whole sellers from oil companies as per upliftment pattern mentioned above. * To identify loopholes in the distribution system. * To review scale of distribution of kerosene to various cardholders, with regard to factors as availability of alternative fuels * MS/HSD control order has been amended for providing testing of MS/HSD for various parameters of specification apart from density like Octane No. of MS, Cetane No. of HSD, and any other parameter of MS/HSD specification indicated in the order. * The state Govt. authorities are empowered under the MS/HSD control order to conduct inspections at the retail outlets and take appropriate action against the erring dealers in case of any mal-practices/irregularities detected. * On October 31, 1998, MoPNG has amended the kerosene control order making it mandatory for the parallel marketers to file end use certificate from their industrial customers. * An independent fuel-testing laboratory has been set up at Noida during November 2000 as directed by Hon’ble Supreme court and as desired by EPCA for testing of samples drawn from retail outlets in the NCT/NCR. * MoPNG have issued two control orders namely (i) the solvent, Raffinate and Slop (acquisition, sale, storage and prevention of use in automobile) order, 2000 in order to prevent unauthorized usage of these products for adulteration of MS/HSD at retail outlets. * Other Measures includes: * Sealing of tank trucks with security locks * Increasing number of mobile laboratories

Future Strategies for India
Zero Emission Vehicles and Cleaner Fuels
Promotion of cleaner fuels, especially zero-emission technologies in the urban Indian context and to promote R & D leading to their commercialization, the available technology options should be evaluated with a view to identify vehicle technologies and fuels for the future. Eliminating emissions from the tailpipe goes even further to cut down on harmful air pollutants.
The conventional fuels in use contain significant amount of sulphur and other compounds, removing sulphur content from the fuel and cutting down on the amount of light hydrocarbons helps pollution control technology to work better and cut down on evaporative and refuelling emissions. The large scale reductions of other tailpipe emissions and CO2 can be accomplished with a shift away from conventional fuels to alternative fuels (inherently burn cleaner than diesel and petrol) such as natural gas, methanol, ethanol, hydrogen. The implementation of CNG as an automotive fuel in Delhi has been a landmark for implementation in other cities of the country as well for improving the air quality. It is also a fact that CNG alone cannot be implemented all over the country as solution for improving air quality. There is need to decentralize our policy on alternative fuels based on the resource availability at local level. While the government at national levels should assist and support technically as well as financially these initiatives at local levels.
Old vehicles phase-out programme and Development of guidelines for scrap page of old vehicles

There is no limit on the age of the vehicle that one can ply on the Indian roads. Given the progressive degeneration of the engines of these vehicles due to lack of proper maintenance as well as their being manufactured when emission norms were far more lax, they tend to emit inordinate levels of pollutants. Hence development of a rationale vehicle phase out programme all over the country hold an important place in future policies of the government. Further assessment of exact working life of a catalytic converter in vehicles is expected to be carried out for development of related policies.
Development of appropriate vehicle scrappage guidelines are very essential after implementation of old vehicle phasing out programme in India. Within this purview Government will direct automotive industry to strengthen its R& D endeavors for making most of its automotive components as recyclable and to be reused while scrapping a vehicle and generate least possible pollution (solid waste, water & air pollution) during scappage.

Developing fuel economy standard
Adopting fuel economy standards will not only help check the growing consumption of petrol and diesel, it will also reduce the transport sector's contribution to accumulation of CO2, not to speak of conventional air pollutants such as particulate matter, oxides of nitrogen and hydrocarbons. The less fuel burned/consumed per km travelled, the less will be the emissions.
The International Council on Clean Technology (ICCT) is working to improve the environmental performance and efficiency of cars, trucks, buses and transportation systems in order to protect and improve public health, the environment, and quality of life. The Japan has increased stringency of its fuel economy standards. In India, the Petroleum Conservation and Research Association (PCRA), an autonomous research body under the Union ministry of petroleum and natural gas, has signed a memorandum of understanding with the Bureau of Energy Efficiency to develop fuel economy standards under the Energy Conservation Act, 2001. The fuel efficiency standard is applicable for all types of vehicles, including cars, trucks and buses. According to government projections, the country could save up to $36 billion if fuel efficiency is improved by 50% by 2030 in all sectors. A committee of experts is now being set up by PCRA to set target values.

M.C. Mehta v. Union of India and Others

In this case it was held that:
a) all commercial/transport vehicles which are more than 20 years old (9,349) shall be phased out and not permitted to ply in the National Capital Territory Delhi after 2nd October, 1998;
b) all such commercial/transport vehicles which are 17 to 19 years old (3,200) shall not be permitted to ply after 15th November, 1998;
c) such of the commercial/transport vehicles which are 15 years and 16 years old (4,962) shall not be permitted to ply after 31st December, 1998.
This order shall apply to all commercial/transport vehicles whether registered in the National Capital Territory of Delhi or outside (but ply in Delhi) which are of more than the stipulated age.
This ban order shall also be applicable to all such vehicles which do not have any authority or permit to ply in the National Capital Territory of Delhi. Apart from the commercial/transport vehicles which are registered, as noticed above, we are informed that there are vehicles which are either not registered or no which road tax has not been paid in National Capital Territory of Delhi. We direct that all such commercial/transport vehicles which are being plied without payment of road tax or registration shall not be allowed to ply in the National Capital Territory forthwith and in any event not with effect from 2nd Oct. 1998.
The Motor Vehicles Department and the Traffic Department of Delhi Polic shall coordinate their efforts to carry out these directions faithfully and punctually. We further direct that an affidavit shall be filed by the Chief Secretary, Delhi Administration, undertaking to ensure that the directions hereinabove given are carried out in letter and in spirit. The affidavit shall be filed during the course of this week.

M.C.Mehta v. Union of India Notwithstanding the enactment of the Environment (Protection) act 1986 decline in the quality of environment continues.his prima facie shows a failure on the part of the authorities to perform their obligation under the Constitutional scheme and the mandate of the Act. Bhure Lal Committee, which was constituted by an order of this Court on 7th January, 1998, has been submitting its Reports from time to time and in the Report submitted to this Court on April 1, 1999, it was pointed out that the private (non-commercial) vehicles comprise 90% of the total number of vehicles plying in the NCR.The Report also indicated that more than 90% of Nitrogen Oxide (Nox) and respirable particulate matter (RSPN) from vehicles exhaust over Delhi is due to diesel emissions which is a serious health hazard. On 16th April, 1999, after taking note of the Report of Bhure Lal Committee, this Court had issued certain directions.
After considering the suggestions made by Bhure Lal Committee and in the application filed by the learned Amicus and hearing learned counsel for various parties (automobile manufacturers), it appears appropriate to us to issue the following directions :
1. All private (non-commercial) vehicles which conform to EURO II norm may be registered in the NCR without any restriction.
2. All private (non-commercial) vehicles shall conform to EURO I norm by 1st June, 1999. All private (non-commercial) vehicles shall conform to EURO II norm by 1st April, 2000. Vehicles may in the meanwhile be registered in the manner indicated below :
With effect from 1st May, 1999, 250 diesel driven vehicles per month and 1250 petrol driven vehicles per month may be registered on first-cum-first serve basis in the NCR till 1st April, 2000 only if they conform to EURO I noym. From 1st April, 2000 no vehicle shall be registered unless it conforms to EURO II norm.
The direction given by us apply both to diesel as well as petrol driven cars (private non-commercial vehicles).
These directions are made only as an interim arrangement till further orders.
3. So far as the ban on the registration of diesel driven taxis is concerned, that shall be strictly enforced, unless the taxis also conform to EURO II norm. In other words no taxi (diesel) shall be registered with immediate effect unless it conforms to EURO II norm.
4. With a view to facilitate registration in the manner indicated above, the registering authority may register the vehicle concerned on a certificate of the manufacturer, duly authenticated by the authorised officer certifying that the vehicle concerned conforms to EURO I/ERUO II norm.

State of West Bengal and Ors v. S.K Nurul Amin
In this case The respondent made two applications to the State Transport Authority, West Bengal ('Authority' for short) for grant of permanent stage carriage permit, the first on 7.11.1997 for a permit for the route Dhulian Bazar to Kolkata (via Raghunathganj and Barasat), and the second on 30.11.1998 for a permit for the route Raghunathganj to Kolkata (via Barasat). As the said applications were not disposed of, the respondent approached the High Court by filing separate writ petitions and the said petitions were disposed of with a direction to the Authority to consider and dispose of the pending applications of the respondent. Thereafter, the Authority, by communications dated 18.12.2000 and 3.11.2000, offered permits for the routes Dhulian Bazar to Barasat and Reghunathganj to Barasat respectively, by curtailing/excluding the last portion of the two applied routes from Barasat to Kolkata (26 kms.). Feeling aggrieved, the respondent filed two writ petitions which were disposed of by a learned Single Judge. The orders of the learned Single Judge were challenged by the respondent by filing intra-court appeals before a Division Bench. The Division Bench allowed the appeals by the impugned orders but held that the orders of the Authority violated Section 72(1) of the Act. The said orders are challenged in these appeals by special leave.
In this case, what the Authority has done is to grant the permanent stage carriage permits in regard to the routes for which the applications were made, but with a modification, by curtailing the routes for which the permits were applied, only up to Barasat. The Authority in effect therefore refused to grant the permit for the last leg (Barasat to Kolkata) of the two routes applied. Though the communications from the Authority to the respondent did not contain the reason for curtailing the routes, it is stated that the resolutions of Authority assigned the reason for curtailment. The reason was that in view of the heavy traffic congestion and vehicular pollution in Kolkata, there was restriction of entry of new passenger vehicles into Kolkata and, therefore, the permits were granted only up to Barasat.

--------------------------------------------
[ 1 ]. World Health Organisation
[ 2 ]. Local aspects of vehicular pollution by M. J. Clifford, R. Clarke and S. B. Riffat
[ 3 ]. The Automotive Research Association of India, August 2007, “Emission Factor development for Indian Vehicles “
[ 4 ]. Ministry of Road Transport and Highways, Notifications
[ 5 ]. Vehicular Pollution Control – Concept note by Dr.VinishKathuria
[ 6 ]. International Road Federation’s “World Road Statistics, 2008” except for India
[ 7 ]. accessed on 29/7/11
[ 8 ]. [1998] RD-SC 575
[ 9 ]. (1999) 6 SCC 12
[ 10 ]. AIR 2010 SC 2271