National Green Tribunal: Solid Waste Management Compliance
Summary
The National Green Tribunal reviewed the compliance status of the State of Nagaland regarding Municipal Solid Waste Management Rules, 2016. The Tribunal noted deficiencies in the progress report, particularly concerning the disclosure of legacy waste data for various Urban Local Bodies (ULBs).
What changed
The National Green Tribunal (NGT) reviewed the compliance of the State of Nagaland with the Municipal Solid Waste Management Rules, 2016, during a hearing on March 16, 2026. The NGT identified significant gaps in the six-monthly progress report submitted by the state, specifically noting that the tabulated data on legacy waste (Annexure-R/4) was incomplete, with information missing for numerous Urban Local Bodies (ULBs). The Tribunal also questioned the cut-off date of 2022 for legacy waste data provided for Kohima and Dimapur ULBs, deeming it insufficient for a current assessment.
Regulated entities, particularly state urban development and municipal affairs departments, must ensure comprehensive and up-to-date reporting on solid waste management. This includes providing complete data on legacy waste, clearly stating cut-off dates for such information, and addressing any deficiencies identified by the NGT. Failure to comply with reporting requirements and waste management rules can lead to further scrutiny and potential penalties from the Tribunal. Compliance officers should ensure that all required data is accurately collected and submitted according to NGT directives.
What to do next
- Ensure complete disclosure of legacy waste data for all ULBs in progress reports.
- Clearly state the cut-off date for all disclosed legacy waste information.
- Address deficiencies in waste management reporting as identified by the NGT.
Source document (simplified)
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Compliance Of Municipal Solid Waste ... vs . on 16 March, 2026
Item No. 32 Court No. 1
BEFORE THE NATIONAL GREEN TRIBUNAL
PRINCIPAL BENCH, NEW DELHI
Original Application No. 606/2018
(IA No 20/2025, IA No 539/2025, IA No 299/2024)
(In respect of State of Nagaland)
Compliance of Municipal Solid Waste Management Rules, 2016 And Other
Environmental Issues.
Date of hearing: 16.03.2026
CORAM: HON'BLE MR. JUSTICE PRAKASH SHRIVASTAVA, CHAIRPERSON
HON'BLE DR. AFROZ AHMAD, EXPERT MEMBER
Amicus Curiae: Ms. Katyayni, Advocate (Amicus Curiae)
Respondents: Ms. K. Enatoli Sema, Mr. Amit Kr. Singh & Mr. Prang Newmai, Advs. with
Mr. Kekhrievor Kevichusa, Commissioner & Secretary, Urban Dev. &
Municipal Affairs (Through VC),
Mr. Zarenthung Ezung, Secretary, Public Health Engineering (Through
VC),
Mr. Y. Atsase Thongtsar, Secretary, EF & CC (Through VC),
Ms. Kezhochole Rhetso, Jt. Director & SMD, Urban Development
(Through VC),
Ms. Khate-u Kezo, Jt. Director, Municipal Affairs (Through VC),
Ms. Mongna Konyak, Director, Rural Development (Through VC) &
Mr. Sangmai C Imlong, Additional Secretary, Rural Development, State of
Nagaland (Through VC)
Mr. Saurabh Balwani, Adv. for CPC B (Through VC)
ORDER 1. In this original application, Tribunal is considering the issue of solid
as well as liquid waste management as per orders of the Hon'ble Supreme
Court dated 02.09.2014 in Writ Petition No. 888/1996, [Almitra H. Patel vs.
Union of India & Ors.](https://indiankanoon.org/doc/339109/), with regard to solid waste management and order
dated 22.02.2017 in W.P. No. 375/2012, reported in ([2017) 5 SCC 326,
Paryavaran Suraksha vs. Union of India](https://indiankanoon.org/doc/190799178/), with regard to liquid waste
management (sewage).
- Today, matter has been taken up in respect of compliance by State
of Nagaland.
- The State of Nagaland has filed the six-monthly progress report
dated 02.03.2026. Another report dated 12.03.2025, wrongly mentioned
as filed on 13.08.2025, has been filed.
1
- We have heard learned Amicus Curiae and learned Counsel for the
State of Nagaland and Mr. Kekhrievor Kevichusa, Commissioner &
Secretary, Urban Development & Municipal Affairs virtually and perused
those reports. On examination of the report, we find the following status:
Solid Waste:
(i) The status of the legacy waste has been disclosed in the
tabulated chart Annexure-R/4 on page 603. A perusal of the
said chart reveals that the information has not been disclosed
in respect of various ULBs. Out of total 39 ULBs, the requisite
information has been disclosed only in respect of few ULBs.
(ii) We have taken up the example of Kohima and Dimapur ULBs.
In respect of Kohima and Dimapur ULBs, no cut of date of
quantity of legacy waste disclosed has been mentioned in the
chart, but the Commissioner & Secretary, Urban Development
& Municipal Affairs, appearing virtually has informed that the
cut of date of legacy waste disclosed for these two ULBs is year
2022. We failed to understand as to why the cut of date of 2022
has been taken. Whereas to give the current picture, status of
2026 ought to have been disclosed.
(iii) We also find that there is a gap in generation and treatment of
daily waste which is to the extent of 28 TPD in Kohima and
34.48 TPD in Dimapur. It is submitted by the Commissioner &
Secretary, Urban Development & Municipal Affairs that this
gap will be filled up within one year. It is strange that for filling
up the gap between the daily generation and treatment of
waste, one year time has been mentioned, whereas for clearing
the legacy waste in these ULBs, the timeline of October 2026
has been disclosed. If there is a gap in daily generation and
treatment of waste then every day untreated waste is added to 2 the legacy waste. Hence, unless the gap is filled up, the entire
legacy waste cannot be cleared.
(iv) In respect of above two ULBs, it has been disclosed that after
bio-mining and bio-remediation, 18.4% and 19% plastic and
rubber is received in these ULBs, but the manner of their
utilisation/disposal has not been disclosed.
(v) We also find that in respect of Tseminyu, Shamator, Meluri
and many such ULBs, no details of legacy waste or gap in daily
generation and treatment of waste have been disclosed in this
tabulated information.
(vi) The table on page 583 discloses the six-monthly progress from
July to December 2025 in respect of the daily generation and
treatment of waste. In respect of Kohima, it is noticed that 67
TPD is generated, whereas, the collection is only 43 TPD. There
is an unexplained gap between generation and treatment.
(vii) Similarly, in Dimapur, 78.3 TPD is generated, whereas
collection is only of 74.6 TPD. In respect of Mokokchung, the
waste generation is 13.5, whereas the collection is only 11.475
TPD and the transportation of the waste is zero.
(viii) The aggregate figure discloses that the total waste generated in
39 ULBs is 265.39 TPD, whereas the collection is only 181.476
TPD. Therefore, there is a gap of 83.914 TPD in the generation
and collection of waste.
(ix) The said chart further reveals that out of 181.476 TPD
collection, the transportation is only 150.617 TPD. Therefore,
there is unexplained gap of 30.859 TPD in the collection and
transportation of the solid waste. Once the waste is collected,
it is required to be transported or segregated and bio-mined,
bio-remediated.
3
(x) The chart on page 586 gives incomplete picture relating to the
waste processing. In respect of Kohima, the quality of
composting is not assessed. The capacity of plan stated to be
not available and similar is the situation in respect of Dimapur
and other ULBs.
(xi) The solid waste which is uncollected or un-transported after
collection may be going to the water bodies, therefore, the State
of Nagaland is required to disclose the details and status of the
water bodies in the State in the next report.
Liquid Waste:
(i) So far as the liquid waste is concerned, the chart on page 592
relates to the sewage waste management in Nagaland. The
chart discloses that there is one STP of 90 MLD in Kohima and
another of 25.43 MLD in Dimapur. The chart further discloses
that the utilization capacity of Kohima STP is nil. Therefore,
the inference is the Kohima STP is not working.
(ii) In the above chart, the utilisation capacity of Dimapur STP is
disclosed to be 18.4 MLD, but the chart on page 527 discloses
that this STP is damaged during monsoon 2025 and is not
operational. Hence, both the STPs, i.e., in Dimapur and
Kohima are non-operational and untreated sewage is being
discharged in the water bodies including rivers. In respect of
Dimapur, it has been disclosed that the discharge is in
Dhansiri River. Thus, the disclosure made in the chart reveals
that the order of the Hon'ble Supreme Court in the matter of Paryavaran Suraksha vs. Union of India, reported in (2017) 5
SCC 326 has not been complied with till now.
4
Ring Fence Account:(i) In respect of creating the ring fence account in terms of the
earlier order of the Tribunal, learned Counsel appearing for the
State submits that the approval of the Finance Department
has been taken and the ring fence account will be opened and
amount will be deposited within one month.
- In view of the above, the State of Nagaland is directed to file a fresh
status report disclosing the information in the tabulated chart which is
already provided earlier and also keeping in view the observations made
above.
- List the matter on 22.11.2026 for consideration of the report in
respect of State of Nagaland.
- For the State of Punjab, the matter be listed on 17.03.2026 as per
the earlier direction.
Prakash Shrivastava, CP
Dr. Afroz Ahmad, EM
March 16, 2026
Original Application No. 606/2018
(IA No 20/2025, IA No 539/2025, IA No 299/2024)
(In respect of State of Nagaland)
dv 5
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