Solar firms move High Court over ‘unreasonable’ mandate
In this note
Practice
3 questions on this article
Check the answer for each question, or reveal all at once.
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. [1]
- 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. [3]
- The core dispute: domestic cells cost ₹13/watt vs. imported cells at ~₹5/watt — a ~160% price premium — which petitioners call commercially unviable. [4]
- 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. [4]
- 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. [2][3]
- May 25, 2026: MNRE clarified it would not extend the ALMM List-II deadline beyond June 1, 2026, rejecting developer pleas. [2]
3. Background & Evolution
- April 10, 2021: MNRE notified ALMM for solar PV modules (List-I), effective from that date. [1]
- ALMM List-II (for solar PV cells — the upstream component within modules) was notified subsequently, with mandatory applicability set for June 1, 2026. [1][3]
- 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. [5]
- 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. [1]
4. Core Static Facts
| Parameter | Detail |
|---|---|
| Full form | Approved List of Models and Manufacturers |
| Implementing Ministry | Ministry of New and Renewable Energy (MNRE) |
| ALMM List-I | ~130 solar PV module manufacturers |
| ALMM List-II | ~17 solar PV cell manufacturers |
| Effective date (List-II) | June 1, 2026 |
| Domestic module capacity | ~91–193 GW (module); ~27–31 GW (cells) |
| Domestic cell price | ~₹13/watt |
| Imported cell price | ~₹5/watt |
| Price differential | ~₹8/watt (~160% premium) |
| Petitioners | Solar industry associations of Karnataka, Kerala, Tamil Nadu |
| Lead petitioner body | KRESMA (Karnataka Renewable Energy Systems Manufacturers Association) |
| Court approached | Karnataka High Court |
| Petition date | June 6, 2026 |
| Ingots & wafers mandate | Proposed from June 1, 2028 |
| Upstream extension | MNRE notification, March 2026 |
5. Multi-Dimensional Analysis
Economic
- Domestic cell prices (~₹13/watt) are 2.6× imported prices (~₹5/watt), raising project costs significantly for developers. [4]
- 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. [2]
- 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. [2]
- Domestic cell manufacturers (List-II companies) benefit from guaranteed demand, incentivising further capacity investment. [1]
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)). [4]
- The challenge is against subordinate legislation / executive orders of MNRE, not a parliamentary statute — making it reviewable on grounds of proportionality and reasonableness. [4]
- The capacity mismatch argument (31 GW cell supply vs. 193 GW module demand) forms the core of the "unreasonableness" doctrine being invoked. [2]
Administrative / Governance
- MNRE explicitly refused an extension on May 25, 2026, despite developer industry lobbying — signalling firm policy commitment to domestic content requirements. [2]
- 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. [1][4]
- Relief provisions were provided for projects with pre-existing investments/completed installations, creating differential treatment among project categories. [2]
Environmental
- Cost escalation from domestic-cell mandate could slow solar project commissioning, delaying CO₂ displacement gains and India's renewable energy targets. [2]
- The policy, however, deepens domestic value chain integration (cells → modules → potentially ingots/wafers), reducing carbon footprint from long-distance imports over the long run. [5]
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. [1][2]
- ALMM List-II ensures cells meet specified efficiency benchmarks; the 7th revision updated Waaree's efficiency parameters (April 2026). [1]
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. [5]
- April 30, 2026: MNRE published 7th revision of ALMM List-II, adding Renewsys India (452 MW, Telangana) as a new entrant. [1]
- May 25, 2026: MNRE confirmed no extension of ALMM List-II deadline. [2]
- June 1, 2026: ALMM List-II mandate for solar PV cells came into force. [3]
- June 6, 2026: Writ petition filed in Karnataka High Court by associations from Karnataka, Kerala and Tamil Nadu, led by KRESMA. [4]
7. Prelims Hooks
- ALMM stands for Approved List of Models and Manufacturers, maintained by MNRE.
- ALMM List-I covers ~130 solar PV module manufacturers; ALMM List-II covers ~17 solar PV cell manufacturers.
- ALMM for solar PV modules (List-I) was notified effective April 10, 2021.
- ALMM List-II for solar PV cells became mandatory from June 1, 2026.
- Domestic solar cell price under ALMM List-II: ~₹13/watt; imported price: ~₹5/watt.
- The writ petition was filed in Karnataka High Court (not Supreme Court) on June 6, 2026.
- Petitioner lead body: KRESMA (Karnataka Renewable Energy Systems Manufacturers Association).
- India's domestic solar module manufacturing capacity: ~91 GW (per MNRE); cell capacity: ~27 GW.
- MNRE extended ALMM framework to solar ingots and wafers from June 1, 2028 (March 2026 notification).
- 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.
- ALMM mandate applies to government-backed, net-metered, and open-access solar projects — not all solar projects.
- MNRE refused to extend the June 1 deadline as late as May 25, 2026.
- 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:
- "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."
- "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."
- "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
| Topic | Connection |
|---|---|
| PLI Scheme for Solar PV Modules | PLI (Production Linked Incentive) is the positive-incentive complement to ALMM's mandatory-demand mechanism for building domestic manufacturing. |
| Basic Customs Duty (BCD) on Solar Cells and Modules | 25% BCD on cells, 40% on modules — the tariff tool alongside ALMM to make domestic production viable. |
| National Solar Mission / PM Surya Ghar | Demand-side policies that specify use of ALMM-listed products. |
| Domestic Content Requirement (DCR) jurisprudence (WTO disputes) | India's DCR in solar was challenged by the US at WTO (DS456); ALMM is a successor mechanism with different legal architecture. |
| Article 19(1)(g) and Reasonable Restrictions | Constitutional law basis for challenging government mandates on trade/business. |
| 500 GW Renewable Energy Target by 2030 | The macro-policy goal that makes ALMM supply-constraint disputes existential. |
| Ingots, Wafers, Cells, Modules — Solar Value Chain | Understanding upstream vs. downstream manufacturing helps analyse why cell capacity lags module capacity. |
| Electricity Act, 2003 and Open Access | ALMM applies to open-access projects; Electricity Act governs open access framework. |
10. Common Errors / Trap Areas
- 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.
- Wrong court: The petition was filed in the Karnataka High Court under Article 226, not the Supreme Court under Article 32.
- 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.
- 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.
- Attributing ALMM to a different ministry: ALMM is administered by MNRE (Ministry of New and Renewable Energy), not DPIIT, Ministry of Power, or MoEFCC.
Sources
- 1MNRE Issues Amendment to ALMM Order for Solar PV Cellspib.gov.in · tier 1
- 2India's ALMM List-II Solar Rules Expose Domestic Cell Shortagedowntoearth.org.in · tier 4
- 3ALMM List-II for Solar PV Cells to be Effective from June 1, 2026energetica-india.net · tier 4
- 4Solar firms move High Court over 'unreasonable' mandate — The Hindu, June 9, 2026 (article excerpt as provided)tier 4
- 5MNRE Extends ALMM Framework to Cover Solar Ingots and Wafers from June 1, 2028newsonair.gov.in · tier 1
At the end · practice MCQs
3 questions on this article
Check the answer for each question, or reveal all at once.