CAQM invokes Stage-I of GRAP in Delhi-NCR with immediate effect amid sharp rise in AQI

1. At a Glance

• The Graded Response Action Plan (GRAP) is a tiered set of emergency anti-pollution measures for the entire NCR. Each stage is triggered by Delhi's daily average AQI [1][4].
• Stage-I ('Poor', AQI 201–300) was invoked on 21 Oct 2026, with 25 action points, "with immediate effect" across the whole NCR [1].
• GRAP is run by the CAQM Sub-Committee on GRAP. CAQM is a statutory body under the CAQM in NCR and Adjoining Areas Act, 2021 (Act No. 29 of 2021) [1][11].
• Why it matters: it covers air pollution governance, statutory bodies, the Supreme Court's role in environmental governance (M.C. Mehta), and cooperative federalism across Delhi, Haryana, UP and Rajasthan. It is a recurring Prelims and Mains (GS-II/III) theme.

2. Why in the News

• On 21 Oct 2026, Delhi's daily average AQI was 244 at 2 PM and 245 at 4 PM ('Poor'), per the CPCB daily AQI Bulletin [1].
• The CAQM Sub-Committee on GRAP reviewed the air quality and the IMD/IITM meteorological forecasts. It then invoked all 25 Stage-I action points across the NCR [1].
• This is the first invocation in the 2026 winter season under the revised GRAP schedule approved on 28 Sep 2026 [1][2].

3. Background & Evolution

• Origin: GRAP was notified by the Government of India following the Supreme Court order of 2 Dec 2016 in M.C. Mehta v. Union of India [12].
• 2021: Parliament enacted the CAQM in NCR and Adjoining Areas Act, 2021 (Act No. 29 of 2021), assented 12 Aug 2021 [11].

• Section 12 sets out the Commission's "Powers and functions": taking measures, issuing directions and entertaining complaints, "notwithstanding" other laws [11].

• 2023 revision: a revised GRAP came into force w.e.f. 01.10.2023 in the entire NCR [4].

• Stages: II 'Very Poor' (301–400), III 'Severe' (401–450), IV 'Severe+' (>450) [4].

• Dec 2024 revision: measures for the winter months were tightened [3].

• Stages II, III and IV can be invoked in advance, based on forecasts, if higher AQI levels are likely to persist [3].

• Nov–Dec 2024: the SC order of 18 Nov 2024 kept Stage-IV in force even if AQI fell below 450, until further orders [5].

• The SC later allowed Stage-IV to be revoked, but not below Stage-II for the time being [5].

• 28 Sep 2026: the 30th meeting of the Full Commission approved a revised GRAP schedule [2]. It has 48 actions in total: 25 (I) + 8 (II) + 10 (III) + 5 (IV) [2].

4. Core Static Facts

Item	Fact
Parent body	Commission for Air Quality Management in NCR & Adjoining Areas (CAQM) [11]
Enabling law	CAQM Act, 2021 (Act No. 29 of 2021); powers in Section 12 [11]
Judicial origin of GRAP	SC order of 2 Dec 2016, M.C. Mehta v. UoI [12]
Decision-making unit	CAQM Sub-Committee on GRAP [1]
Trigger metric	Delhi's daily average AQI (CPCB bulletin), plus IMD/IITM forecasts [1]
Stage I	'Poor', AQI 201–300; 25 actions (2026 schedule) [1][2]
Stage II	'Very Poor', AQI 301–400; 8 actions [2][4]
Stage III	'Severe', AQI 401–450; 10 actions [2][4]
Stage IV	'Severe+', AQI >450; 5 actions [2][4]
Geographic scope	Entire NCR, not just Delhi [1]
Cumulative nature	Stage-I actions continue and are intensified at higher stages ("intensify measures of the extant GRAP schedule") [1]

Key Stage-I actions (2026 schedule) [1]:

• C&D dust: C&D material must be stored covered and transported in covered vehicles. Anti-smog guns and water sprinkling are required.

• Projects with plot size ≥500 sqm that are not registered on the State/GNCTD web portal cannot carry out C&D activities. This flows from Direction Nos. 11–18 dated 11.06.2021.

• Waste: regular lifting of MSW, C&D and hazardous waste. Open burning of biomass and MSW is banned, with maximum Environmental Compensation (EC) under NGT orders of 04.12.2014 and 28.04.2015 (OA 21/2014). Strict vigil against landfill fires.

• Roads: mechanised sweeping and water sprinkling.
• Vehicles:
• Enforcement of PUC norms.
• Diversion of non-destined trucks via the Eastern & Western Peripheral Expressways, per the SC order.

• Ban on overaged diesel/petrol vehicles, per NGT/SC orders.

• Industry and power:

• Emission norms and approved fuels only for industries, brick kilns and hot mix plants.

• Enforcement of emission norms in thermal power plants.

• Firecrackers: enforcement of court and tribunal orders.

• DG sets: regulated under Direction No. 76 dated 29.09.2023.
• No restrictions: gas-based sets (LPG/NG/biogas/propane/butane), and sets up to 800 kW that meet GSR 804(E) of 03.11.2022.
• 41–800 kW: must run on dual fuel or have retrofitted ECDs.
• 19–41 kW: dual fuel only.

• Portable sets below 19 kW: allowed only for emergency services (lifts, hospitals, railways, Metro/MRTS, airports, etc.).

• DISCOMs: minimise power cuts so that DG sets are not used as a regular power source.

5. Multi-Dimensional Analysis

Environmental

• GRAP targets dust (C&D, roads), vehicles, industry, open burning and DG sets, which are the main local sources in Delhi-NCR [1].
• It is reactive and episodic: it is triggered by AQI thresholds and revoked once air quality improves [7][10]. It does not substitute for structural, year-round airshed management.

Legal / Constitutional

• GRAP has two layers of legal backing: its judicial origin (SC, M.C. Mehta, 2016) [12] and the statutory powers CAQM gets under Sec. 12 of the 2021 Act, which apply "notwithstanding" other laws [11].
• The judiciary stays closely involved. For example, the SC directed the Stage-IV continuation and the floor at Stage-II in 2024 [5]. This raises questions of judicial overreach versus enforcement of the Article 21 right to a clean environment.
• Stage-I also enforces NGT orders on environmental compensation, which shows how statutory and tribunal mandates overlap [1].

Administrative / Federal

• One central commission directs implementing agencies in several NCR states and GNCTD, a test case for cooperative federalism [1].
• Actions are "implemented, monitored and reviewed by all the agencies concerned". Weak enforcement capacity among ULBs, police and SPCBs is the usual bottleneck [1].
• The 2026 rationalisation merged repetitive actions and moved some to earlier stages, which simplifies compliance [2].

Economic

• C&D curbs, DG-set restrictions and controls on brick kilns and hot mix plants impose costs on construction workers, MSMEs and power-deficient businesses [1].
• The push towards dual-fuel DG sets and gas infrastructure requires capital investment [1].

Scientific / Technological

• Decisions draw on CPCB AQI bulletins and IMD/IITM forecasts. Higher stages can be invoked pre-emptively on the basis of forecasts [1][3].
• Remote monitoring of dust mitigation happens through web-portal registration of C&D sites [1].

Social

• Daily-wage C&D workers and vulnerable groups (children, the elderly) bear disproportionate costs, both from pollution and from the restrictions.

6. Recent Developments (last 12–18 months)

• 14 Oct 2025: Stage-I invoked at Delhi AQI 211. This was then a 27-point plan [8].
• 19 May 2026: Stage-I invoked at AQI 208 [9].
• 29 May 2026: Stage-I revoked after AQI improved to 123 [10].
• 28 Sep 2026: the 30th Full Commission meeting approved the revised GRAP [2]:
• It has 48 actions in total.
• Repeated actions on dust, MSW and transport in Stage-I were merged.
• Some actions on DG sets and on entry of BS-IV-and-below buses moved from Stage-II to Stage-I.

• Pothole repairs were relaxed under Stage-III.

• 21 Oct 2026: Stage-I invoked with 25 actions at AQI 244/245 [1].

• Earlier pattern, 2025:
• Invoked on 7 Mar (AQI 202) [6] and revoked on 15 Mar (AQI 85) [7].
• Revoked on 23 May (AQI 129, 'Moderate') [13].

7. Prelims Hooks

• GRAP stages are triggered by Delhi's daily average AQI, but the actions apply to the entire NCR [1].
• Stage-I = 'Poor' = AQI 201–300 [1].
• Stage-IV = 'Severe+' = AQI above 450 [4].
• The revised 2026 GRAP has 48 actions: 25/8/10/5 across Stages I–IV [2].
• Stage-I had 27 points before the Sep 2026 revision and has 25 now [8][2].
• The decision-maker is the CAQM Sub-Committee on GRAP, not CPCB or the Delhi government [1].
• CAQM was set up under Act No. 29 of 2021. Its powers and functions are in Section 12 [11].
• GRAP's origin is the SC order of 2 Dec 2016 in M.C. Mehta v. Union of India [12].
• The revised GRAP of 2023 came into force on 1 Oct 2023 [4].
• Since the Dec 2024 revision, higher stages can be invoked in advance on the basis of forecasts [3].
• Under Stage-I, C&D projects of ≥500 sqm must be registered on the State/GNCTD web portal [1].
• DG-set regulation under Stage-I is governed by CAQM Direction No. 76 (29.09.2023) [1].
• Gas-run DG sets (LPG/NG/biogas/propane/butane) face no restrictions [1].
• Non-destined trucks are diverted via the Eastern & Western Peripheral Expressways [1].
• AQI data comes from the CPCB daily bulletin. Meteorological forecasts come from IMD/IITM [1].

8. Why Stage-I Is Mostly Old Rules Announced Again

• Most of the 25 Stage-I points are rules that already apply all year
• The open-burning ban rests on NGT orders from 2014 and 2015. The C&D portal rule comes from directions of June 2021. DG-set limits come from Direction No. 76 of 2023 [1].
• PUC checks and the ban on overaged vehicles also come from existing NGT/SC orders [1].

• So invoking Stage-I creates almost no new legal duty. It is a signal that tells agencies to enforce what they should already be enforcing.

• A 'Poor' day is partly a sign that these rules were not being followed

• If covered C&D sites, no waste burning and working PUC checks were the norm, invoking them again would not be needed.

• The real question for Mains is not what Stage-I orders. It is why agencies need an AQI alarm before they act.

• The plan switches on and off too fast for the ground staff to keep up

• In 2025, Stage-I was invoked on 7 Mar and revoked on 15 Mar, just 8 days later [6][7].
• In 2026, it was invoked on 19 May and revoked on 29 May [9][10].
• Municipal and police staff cannot plan steady deployment for a rule that may last only one week.

9. Why a Delhi-Only Trigger Misreads a Regional Problem

• The air does not stop at Delhi's border, but the trigger does
• CAQM's own review of source studies from 2015–2025 found that Delhi's PM2.5 (very fine dust particles that enter deep into the lungs) comes from both local emissions and transboundary transport, meaning pollution blown in from outside [14].

• On one day in Oct 2024, IITM estimated that stubble burning made up about 15.9% of Delhi's PM2.5 [15]. Much of that burning happens outside the NCR.

• Other NCR towns are judged by Delhi's reading

• The stage depends only on Delhi's daily average AQI [1].

• So a town elsewhere in the NCR with dirtier air than Delhi still waits for Delhi's number to cross 200.

• The World Bank calls this an airshed problem

• An airshed is the whole area that shares the same air, shaped by weather and landforms. Think of it like a river basin, but for air.
• The World Bank treats the whole Indo-Gangetic Plain (Pakistan to Bangladesh) as one connected airshed [17].
• A city-based trigger cannot respond to an airshed-wide problem.

10. Stage-I Measures Mostly Miss the Biggest Sources

• Dust and vehicles are the largest local sources
• In summer, CAQM's analysis puts dust at 27% of Delhi's PM2.5, transport at 19%, secondary particulates at 17%, industry at 14% and biomass burning at 12% [14].
• Secondary particulates are not emitted directly. They form in the air when gases from vehicles, industry and farms react with each other.

• An expert report reviewed by CAQM in 2026 named the vehicle sector as one of the major contributors to PM2.5 in Delhi-NCR [16].

• Stage-I fights vehicle pollution only at the edges

• Its vehicle tools are PUC checks, diverting trucks that are not bound for Delhi, and banning overaged vehicles [1].

• None of these reduce the number of vehicles on the road every day. That needs public transport and electric mobility, which an emergency plan cannot deliver.

• Gases are hard to control with a quick fix

• Water sprinkling and anti-smog guns settle coarse road dust [1].
• They do nothing for the gases that later turn into secondary particulates [14].

11. The Case for GRAP: A Brake Is Not Meant to Steer

• The strongest defence: GRAP was never meant to be the cure
• GRAP is an emergency plan by design. It comes from an SC order meant to stop bad days from getting worse [12].
• The long-term work belongs to other tools, such as NCAP and source-wise CAQM directions. Blaming GRAP for not fixing the root causes is like blaming a car's brake for not steering.

• Since Dec 2024, higher stages can be invoked early on the basis of forecasts [3]. So the plan is learning to act before the peak, not only after it.

• What this defence gets right

• A fixed list of actions linked to AQI levels removes guesswork. Every agency knows in advance what it must do at each level [2].

• The 2026 revision merged repeated actions and moved some DG-set and BS-IV bus curbs to an earlier stage [2]. This is a sign that the plan keeps improving.

• Where the defence stops working

• In practice, GRAP has become the most visible part of NCR air policy. Each season's news is mostly about which stage is in force.
• If the emergency brake is pulled every winter, the problem is with the road, not the brake. Year-round sources (dust, vehicles, industry) [14] need year-round enforcement, not seasonal stages.

12. Who Pays When the Rules Stop Work

• Construction workers lose wages when higher stages ban building work

• Stage-I itself only stops unregistered sites of 500 sqm or more [1]. But GRAP is cumulative, so the costs grow as the stages go up.

• The Supreme Court has made the states pay

• In Feb 2025, the SC said NCR states must pay compensation to workers whenever GRAP closes construction, even without a fresh court order [18].
• The money comes from the labour cess, a 1% tax on construction cost that states collect for workers' welfare [18].

• If the cess fund is not enough, the states must still pay [18].

• Payment arrives late

• In Feb 2025, compensation for about 95,000 Haryana workers, for the Stage-IV closure of January 2025, was still being processed [18].
• A daily-wage worker needs money in the week work stops, not months later.
• Many workers are not registered with welfare boards, so they cannot claim at all.

13. What Should Change Next

• CAQM should trigger stages by sub-region, not by Delhi alone
• Delhi's AQI should not be the only trigger for towns across the NCR [1].

• CAQM already has the power to issue directions across the NCR and adjoining areas [11]. It can use NCR-wide monitoring to set stages district-wise.

• States should make airshed-based clean air plans, following Uttar Pradesh

• Uttar Pradesh has prepared India's first airshed-based Clean Air Plan with World Bank support. UP and Haryana are the first states with World Bank-financed operations under this programme [17].

• A World Bank report estimates that states and countries working together can cut pollution at about 45% lower cost than each acting alone [17].

• Parliament should use CAQM's annual report to check enforcement

• The Act requires CAQM to send an annual report to the Centre, which must be laid before both Houses of Parliament [19].

• This report could publish agency-wise compliance with GRAP: fines collected, sites inspected, PUC challans issued. That would make enforcement gaps public.

• NCR states should pay workers ahead of time

• The SC has already made compensation automatic [18]. States can register C&D workers before winter, so cess money is transferred directly to their bank accounts as soon as a construction ban begins.

14. Anchors for Answers

• Data: Delhi's summer PM2.5 sources: dust 27%, transport 19%, secondary particulates 17%, industry 14%, biomass burning 12% (CAQM meta-analysis, 2015–2025) [14]
• Data: IITM estimated stubble burning at about 15.9% of Delhi's PM2.5 on one day in Oct 2024 [15]
• Data: Compensation for about 95,000 Haryana construction workers for the Jan 2025 GRAP-IV closure was still being processed in Feb 2025 [18]
• Report/Committee: Report of Air Quality Experts, reviewed by CAQM in 2026, names vehicles as a major PM2.5 source [16]; World Bank, Striving for Clean Air (cooperation is about 45% cheaper) [17]
• Law/Case: M.C. Mehta v. Union of India: SC order of 2 Dec 2016 (origin of GRAP) [12] and SC order of 28 Feb 2025 (automatic compensation for workers from labour cess) [18]; CAQM Act, 2021, Sec. 12 [11]
• Comparison: World Bank Indo-Gangetic Plain programme treats air from Pakistan to Bangladesh as one airshed, unlike GRAP's Delhi-only trigger [17]
• Scheme: Uttar Pradesh's airshed-based Clean Air Plan, India's first [17]; NCAP is the year-round counterpart to the emergency GRAP

15. Mains Relevance

• GS-III: Conservation, environmental pollution and degradation, environmental impact assessment.
• GS-II: Statutory, regulatory and quasi-judicial bodies; Centre–State relations; the judiciary's role in governance.
• Possible question stems: 1. "The Graded Response Action Plan treats symptoms rather than causes of Delhi-NCR's air pollution." Critically examine. 2. Evaluate the role of the Commission for Air Quality Management as a model for inter-state airshed governance in India. 3. Discuss the role of judicial activism in shaping air quality governance in the National Capital Region.

16. Related Topics to Study Next

• National Clean Air Programme (NCAP): the long-term, city-level counterpart to episodic GRAP.
• National Air Quality Index (CPCB): the AQI categories and pollutants that drive GRAP triggers.
• Stubble burning and crop residue management: a seasonal driver of NCR AQI during GRAP months.
• Air (Prevention and Control of Pollution) Act, 1981 and Environment (Protection) Act, 1986: the parallel statutory framework.
• M.C. Mehta v. Union of India and the Article 21 right to a clean environment: the judicial genesis of GRAP.
• National Green Tribunal: its EC orders are enforced under Stage-I.
• BS-VI emission norms and the end-of-life vehicle policy: the vehicular restrictions in GRAP.
• Winter inversion and meteorology (IMD/IITM SAFAR/EWS): why AQI spikes in Oct–Jan.

17. NCERT Concepts to Revise

• Graded Response Action Plan (Geography): The note's central subject: the four-stage emergency plan triggered by AQI levels across the NCR.
• Commission for Air Quality Management (Geography): The statutory body under the 2021 Act whose Sub-Committee invokes GRAP and directs NCR states.
• National Air Quality Index (Geography): AQI bands (Poor, Very Poor, Severe) are the triggers that decide which GRAP stage applies.
• Particulate matter (Geography): PM2.5 is the key pollutant behind Delhi's air quality, including dust and secondary particulates discussed in the note.
• Right to a clean environment (Polity): Article 21 right underpinning the Supreme Court's M.C. Mehta orders that led to GRAP.
• Cooperative federalism (Polity): One central commission directs Delhi, Haryana, UP and Rajasthan, which tests Centre-state cooperation on air pollution.

18. Common Errors / Trap Areas

• Delhi AQI vs NCR scope: the trigger is Delhi's AQI, but enforcement covers the whole NCR [1].
• Wrong body: GRAP is invoked by the CAQM Sub-Committee, not CPCB, MoEFCC or EPCA. CPCB only supplies the AQI bulletin [1].
• Action counts: the 27-point Stage-I plan (2024–25) is outdated. Since Sep 2026 it is 25 points, with 48 actions in total [2][8].
• Stage thresholds: Stage III is 401–450 and Stage IV is above 450. Both are "Severe" bands, so they are easy to mix up [4].
• Origin of GRAP: it started with the 2016 SC order, not the 2021 Act. The 2021 Act created CAQM, which now runs it [11][12].