ORISSA STATE vs M/S. ORIENT PAPER MILLS

The Supreme Court held that the Orissa High Court erred in quashing the charges against Orient Paper Mills under Section 37(1) of the Air (Prevention and Control of Pollution) Act, 1981, for exceeding the prescribed air pollutant limits. The Court clarified that the absence of rules for declaring an area as an Air Pollution Control Area does not invalidate the notification made by the State Government, as the term 'may' in Section 19 indicates discretion rather than a mandatory requirement. Consequently, the Court reinstated the charges against the respondent, emphasizing the importance of compliance with environmental regulations.