"The Graded Response Action Plan treats symptoms rather than causes of Delhi-NCR's air pollution." Critically examine.
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The Graded Response Action Plan (GRAP) is a four-stage emergency plan. It began with the Supreme Court's 2016 order in M.C. Mehta v. Union of India [1], and CAQM now enforces it under the CAQM Act, 2021 [2]. It was invoked again on 21 Oct 2026 [3]. The criticism is largely valid, but GRAP was built to treat symptoms.
Why the criticism holds
- Episodic by design: actions begin only when Delhi's AQI crosses 200 and lapse once the air improves. Year-round sources go unchecked between alerts.
- Restates existing law: most of the 25 Stage-I points already apply all year [3]. Examples are the open-burning ban under NGT orders (2014–15), C&D site registration and DG-set limits under Direction No. 76 (2023). Invoking Stage-I signals enforcement rather than creating a new duty.
- Misses root sources: CAQM's expert review names dust, transport, industry, biomass burning and secondary particulates, plus transboundary transport, as the drivers of PM2.5 [4]. Water sprinklers and anti-smog guns cannot stop the gases that later form secondary particles.
- City trigger for a regional problem: a Delhi-only trigger ignores the Indo-Gangetic airshed, which the World Bank treats as one connected unit [7].
- Shifts costs to workers: the Supreme Court had to order NCR states to pay construction workers from the labour cess when GRAP halts work [6].
Where GRAP has merit
- A brake, not a cure: long-term reform belongs to NCAP and CAQM's sector-wise directions.
- Predictability: fixed actions for each AQI band set clear duties for agencies across four states [5].
- Increasingly pre-emptive: higher stages can be triggered on IMD/IITM forecasts before AQI peaks [8].
- Adaptive: the latest revision merged repeated actions and moved DG-set and BS-IV bus curbs to Stage-I [5].
- Statutory teeth: Section 12 lets CAQM issue binding directions "notwithstanding" other laws [2].
Way forward
- District-wise triggers using NCR-wide monitoring.
- Airshed-based state plans, following Uttar Pradesh's first-of-its-kind Clean Air Plan [7].
- Year-round enforcement on dust, vehicles and industry, backed by public transport and e-mobility.
- Pre-registering C&D workers so cess money reaches them as soon as a ban begins [6].
GRAP does treat symptoms, but that is its mandate as an emergency tool. The real failure is relying on this emergency brake every winter. Combined with NCAP, inter-state airshed cooperation and steady enforcement, it can help secure the Article 21 right to clean air and SDG 11.6.
Sources
- 1CPCB, Sub-Committee of CAQM on GRAP (GRAP schedule document): GRAP's origin in the Supreme Court order of 2 Dec 2016, *M.C. Mehta v. Union of India*
- 2Commission for Air Quality Management in NCR and Adjoining Areas Act, 2021 (India Code): CAQM's statutory basis; Section 12 powers to issue directions
- 3PIB: CAQM invokes Stage-I of GRAP in the entire NCR (21 Oct 2026): 25 Stage-I actions, mostly restating NGT orders, the C&D portal rule and Direction No. 76
- 4PIB: CAQM Reviews Supreme Court-Mandated Expert Report at 27th Meeting; PM2.5 Identified as Key Pollutant in Delhi: PM2.5 sources, including secondary particulates and transboundary transport
- 5PIB: CAQM Approves Revised GRAP Schedule; Tightens Measures for Vehicles, Dust and Pollution Control: stage-wise action lists; merged actions; DG-set and BS-IV bus curbs moved to Stage-I
- 6Supreme Court of India, *M.C. Mehta v. Union of India*, Order dated 28 Feb 2025: compensation from labour cess for construction workers during GRAP bans
- 7World Bank: Air Quality Management in the Indo-Gangetic Plains and Himalayan Foothills: the IGP as one airshed; Uttar Pradesh's first airshed-based Clean Air Plan
- 8PIB: CAQM announces revised GRAP schedule for Delhi-NCR in wake of the upcoming winter season: Stages II–IV can be triggered in advance on IMD/IITM forecasts