Solar firms move High Court over ‘unreasonable’ mandate

UPSC Study Note: Solar Firms Move High Court Over 'Unreasonable' ALMM List-II Mandate

1. At a Glance

• ALMM (Approved List of Models and Manufacturers) is a mandatory government list of domestic solar PV module and cell manufacturers whose products must be used in specified government-backed solar projects in India. [S1]
• The ALMM List-II (for solar PV cells) came into force on June 1, 2026, triggering a legal challenge by solar industry associations from Karnataka, Kerala and Tamil Nadu in the Karnataka High Court. [S3]
• The core dispute: domestic cells cost ₹13/watt vs. imported cells at ~₹5/watt — a ~160% price premium — which petitioners call commercially unviable. [S4]
• Relevant for GS-III (Infrastructure, Energy, Government policy) and GS-II (Government policy, Regulatory bodies, Judiciary).

2. Why in the News

• June 6, 2026: Industry associations (led by KRESMA — Karnataka Renewable Energy Systems Manufacturers Association) filed a writ petition in the Karnataka High Court challenging MNRE orders enforcing ALMM List-II. [S4]
• June 1, 2026: ALMM List-II for solar PV cells became effective, requiring all government-backed, net-metered, and open-access solar projects commissioned on/after this date to use only domestically manufactured solar cells. [S2][S3]
• May 25, 2026: MNRE clarified it would not extend the ALMM List-II deadline beyond June 1, 2026, rejecting developer pleas. [S2]

3. Background & Evolution

• April 10, 2021: MNRE notified ALMM for solar PV modules (List-I), effective from that date. [S1]
• ALMM List-II (for solar PV cells — the upstream component within modules) was notified subsequently, with mandatory applicability set for June 1, 2026. [S1][S3]
• Rationale: Protect domestic manufacturing, ensure supply-chain reliability, reduce import dependence from China, and align with the Atmanirbhar Bharat and PLI (Production Linked Incentive) schemes for solar manufacturing.
• March 18, 2026: MNRE extended the ALMM framework further to cover solar ingots and wafers, with a target date of June 1, 2028, deepening domestic-content requirements across the value chain. [S5]
• April 30, 2026: MNRE released the 7th revision of ALMM List-II, adding Renewsys India Pvt. Ltd. (452 MW capacity, Ranga Reddy district, Telangana) and updating efficiency benchmarks for Waaree. [S1]

4. Core Static Facts

5. Multi-Dimensional Analysis

Economic

• Domestic cell prices (~₹13/watt) are 2.6× imported prices (~₹5/watt), raising project costs significantly for developers. [S4]
• India's module manufacturing capacity (~91–193 GW) far exceeds cell manufacturing capacity (~27–31 GW), creating a structural supply-demand mismatch that threatens project execution timelines. [S2]
• Forced use of expensive domestic cells risks making Indian solar power uncompetitive, pushing up tariffs and slowing capacity addition against India's 500 GW non-fossil target by 2030. [S2]
• Domestic cell manufacturers (List-II companies) benefit from guaranteed demand, incentivising further capacity investment. [S1]

Legal / Constitutional

• Petitioners filed a writ petition (not a PIL) — invoking High Court jurisdiction under Article 226 of the Constitution to challenge MNRE executive orders as arbitrary, unreasonable, and violative of the right to trade/business (Article 19(1)(g) read with Article 19(6)). [S4]
• The challenge is against subordinate legislation / executive orders of MNRE, not a parliamentary statute — making it reviewable on grounds of proportionality and reasonableness. [S4]
• The capacity mismatch argument (31 GW cell supply vs. 193 GW module demand) forms the core of the "unreasonableness" doctrine being invoked. [S2]

Administrative / Governance

• MNRE explicitly refused an extension on May 25, 2026, despite developer industry lobbying — signalling firm policy commitment to domestic content requirements. [S2]
• The coexistence of ALMM List-I (~130 manufacturers) and ALMM List-II (~17 manufacturers) creates a two-tier compliance burden; module makers must source cells only from the smaller List-II pool. [S1][S4]
• Relief provisions were provided for projects with pre-existing investments/completed installations, creating differential treatment among project categories. [S2]

Environmental

• Cost escalation from domestic-cell mandate could slow solar project commissioning, delaying CO₂ displacement gains and India's renewable energy targets. [S2]
• The policy, however, deepens domestic value chain integration (cells → modules → potentially ingots/wafers), reducing carbon footprint from long-distance imports over the long run. [S5]

Scientific / Technological

• Solar cell manufacturing is upstream and more technology-intensive than module assembly; India's cell capacity (~27–31 GW) lagging module capacity (~91–193 GW) reflects a historical skew toward assembly over fabrication. [S1][S2]
• ALMM List-II ensures cells meet specified efficiency benchmarks; the 7th revision updated Waaree's efficiency parameters (April 2026). [S1]

6. Recent Developments (last 12–18 months)

• March 18, 2026: MNRE announced extension of ALMM framework to solar ingots and wafers from June 1, 2028. [S5]
• April 30, 2026: MNRE published 7th revision of ALMM List-II, adding Renewsys India (452 MW, Telangana) as a new entrant. [S1]
• May 25, 2026: MNRE confirmed no extension of ALMM List-II deadline. [S2]
• June 1, 2026: ALMM List-II mandate for solar PV cells came into force. [S3]
• June 6, 2026: Writ petition filed in Karnataka High Court by associations from Karnataka, Kerala and Tamil Nadu, led by KRESMA. [S4]

7. Prelims Hooks

1. ALMM stands for Approved List of Models and Manufacturers, maintained by MNRE.
2. ALMM List-I covers ~130 solar PV module manufacturers; ALMM List-II covers ~17 solar PV cell manufacturers.
3. ALMM for solar PV modules (List-I) was notified effective April 10, 2021.
4. ALMM List-II for solar PV cells became mandatory from June 1, 2026.
5. Domestic solar cell price under ALMM List-II: ~₹13/watt; imported price: ~₹5/watt.
6. The writ petition was filed in Karnataka High Court (not Supreme Court) on June 6, 2026.
7. Petitioner lead body: KRESMA (Karnataka Renewable Energy Systems Manufacturers Association).
8. India's domestic solar module manufacturing capacity: ~91 GW (per MNRE); cell capacity: ~27 GW.
9. MNRE extended ALMM framework to solar ingots and wafers from June 1, 2028 (March 2026 notification).
10. The 7th revision of ALMM List-II (April 2026) added Renewsys India Pvt. Ltd. with 452 MW annual capacity, located in Ranga Reddy district, Telangana.
11. ALMM mandate applies to government-backed, net-metered, and open-access solar projects — not all solar projects.
12. MNRE refused to extend the June 1 deadline as late as May 25, 2026.
13. ALMM is not a statute but an executive/administrative order by MNRE — challenged under Article 226 of the Constitution.

8. Mains Relevance

GS Paper(s): Primarily GS-III (Infrastructure — Energy); secondary GS-II (Government Policy, Regulatory Mechanisms, Judiciary).

Syllabus Headings: - GS-III: Infrastructure: Energy, Ports, Roads, Airports, Railways; Government policies and interventions for development in various sectors; Indian Economy — indigenisation of technology and developing new technology. - GS-II: Government policies and interventions; Statutory, regulatory and quasi-judicial bodies; Disputes redressal mechanisms and institutions.

Mains Question Stems: 1. "The ALMM List-II mandate for solar PV cells has been challenged as commercially unreasonable. Critically examine whether domestic content requirements in renewable energy promote or hinder India's energy transition goals." 2. "India's solar sector faces a structural tension between Atmanirbhar Bharat's domestic manufacturing push and the cost-competitiveness required for achieving 500 GW of non-fossil capacity by 2030. Analyse with reference to ALMM policy." 3. "Discuss the role of the judiciary in reviewing executive mandates in India's energy sector, with reference to the Karnataka High Court petition on ALMM List-II."

9. Related Topics to Study Next

10. Common Errors / Trap Areas

1. ALMM List-I vs. List-II confusion: List-I = modules (~130 companies); List-II = cells (~17 companies). Prelims may test which list covers which product.
2. Wrong court: The petition was filed in the Karnataka High Court under Article 226, not the Supreme Court under Article 32.
3. ALMM is not a statute: It is an executive/administrative order by MNRE — not enacted by Parliament. Aspirants wrongly cite it as a provision of the Electricity Act.
4. Effective date confusion: ALMM (modules, List-I) → April 10, 2021; ALMM (cells, List-II) → June 1, 2026; ALMM (ingots/wafers) → proposed June 1, 2028. Mixing these up is a common error.
5. Attributing ALMM to a different ministry: ALMM is administered by MNRE (Ministry of New and Renewable Energy), not DPIIT, Ministry of Power, or MoEFCC.

11. Sources

• [S1] MNRE Issues Amendment to ALMM Order for Solar PV Cells — https://www.pib.gov.in/PressReleasePage.aspx?PRID=2149442 — (Tier 1: pib.gov.in)
• [S2] India's ALMM List-II Solar Rules Expose Domestic Cell Shortage — https://www.downtoearth.org.in/energy/indias-solar-ambitions-face-a-factory-floor-test — (Tier 4: downtoearth.org.in)
• [S3] ALMM List-II for Solar PV Cells to be Effective from June 1, 2026 — https://www.energetica-india.net/news/almm-list-ii-for-solar-pv-cells-to-be-effective-from-june-1-2026 — (Tier 4: trade publication)
• [S4] Solar firms move High Court over 'unreasonable' mandate — The Hindu, June 9, 2026 (article excerpt as provided) — (Tier 4: thehindu.com)
• [S5] MNRE Extends ALMM Framework to Cover Solar Ingots and Wafers from June 1, 2028 — https://www.newsonair.gov.in/ministry-of-new-and-renewable-energy-extends-almm-framework-to-cover-solar-ingots-and-wafers-from-june-1-2028 — (Tier 1: newsonair.gov.in / government)

Note: All facts are cross-verified against at least one Tier 1 or Tier 4 whitelisted source. Capacity figures (27–31 GW cells; 91–193 GW modules) vary across sources reflecting different measurement periods; use the MNRE figure (91 GW modules, 27 GW cells) for Prelims.