M/S Eagle Sanitation vs Govt Of Nct Of Delhi & Anr.

Court
Delhi High Court

$~37& 38
* IN THE HIGH COURT OF DELHI AT NEW DELHI
Date of Decision : 25.04.2026
IN THE MATTERS OF:

+ W.P.(C) 7575/2025 & CM APPL. 33798/2025
M/S EAGLE SANITATION .....Petitioner
Through: Mr. Deevanshu Sharma, Ms.
Simran Chawla, Mr. Kartik
Wadhwa & Mr. Deeshant
Sharma, Advocates.

versus

GOVT OF NCT OF DELHI & ANR. .....Respondents

Through: Appearance not given.
38
+ W.P.(C) 7580/2025 & CM APPL. 33805/2025
M/S FIBA HARDWYN LOCKS LTD .....Petitioner
Through: Mr. Deevanshu Sharma, Ms.
Simran Chawla, Mr. Kartik
Wadhwa & Mr. Deeshant
Sharma, Advocates.

versus

GOVT OF NCT OF DELHI & ANR. .....Respondents
Through: Ms. Nitika Bhutani, Advocate
for R-1.
Mr. Balendu Shekhar with Mr.
Krishna Chaitanya and Mr.
Divyansh Singh Dev, Advocates
for DPCC.

CORAM:
HON'BLE MR. JUSTICE PURUSHAINDRA KUMAR KAURAV

Signed
By:PURUSHAINDRA
KUMAR KAURAV
Signature Not Verified
Signed By:PRIYA
Signing Date:06.05.2026
18:53:27
Signature Not Verified

JUDGEMENT

PURUSHAINDRA KUMAR KAURAV, J. (ORAL)
(The matter has been taken up today, as 03.03.2026 was declared as
a holiday.)

1. The prayer in the instant petitions is for the setting aside of the
orders issued by Respondent No. 2/ Delhi Pollution Control Committee
(“ DPCC ”), both of which are dated 01.05.2025. By way of the said
orders, Respondent No. 2 has imposed environment compensation of
Rs. 6,00,000/- upon the petitioners for environmental damage. The said
orders have been passed in furtherance of impugned Show Cause
Notices issued by Respondent No. 2, both of which are dated
10.01.2025.
2. The primary contention of the petitioners is that the impugned
orders have been passed without considering the reply filed by them,
and without affording a hearing opportunity, in violation of the
principles of natural justice.
3. At this stage, it may be appropriate to extract the relevant portion
of the impugned orders. The order dated 01.05.2025, passed by
Respondent No. 2 in W.P.(C) 7580-2025, records the following
observations vis-à-vis the reply filed by the petitioner:
“And whereas, the addressee unit has submitted a reply on 23/01/25
& 24/02/2025 which is found to be not satisfactory by the competent
authority”

4. Similarly, the order dated 01.05.2025, passed by Respondent No.
2 in W.P.(C) 7575-2025, records the following observations vis-à-vis
the reply filed by the petitioner:
“And whereas, the addressee unit has not submitted any reply to the
abovementioned SCN.”

5. A bare perusal of the above extracts shows that Respondent No.
Signed
By:PURUSHAINDRA
KUMAR KAURAV
Signature Not Verified
Signed By:PRIYA
Signing Date:06.05.2026
18:53:27
Signature Not Verified

2 has failed to give due consideration to the replies filed by the
petitioners, or even lay down the reasons as to why such reply was
found not satisfactory. Moreover, the Court finds that the observation
recorded in W.P.(C) 7575-2025, is entirely erroneous, considering that
the petitioner had, in fact, filed a reply, and the same was even
acknowledged by Respondent No. 2. Therefore, the impugned order
shows a complete non-application of mind on the part of Respondent
No. 2.
6. This Court, in Hi-Print Corporation v. Government of NCT of
1
Delhi & Anr . ; M/s India Navigation Company v. Government of
2
NCT of Delhi & Anr . ; and Mangolpuri Industrial Area Phase 1 & 2
3
CETP Society v. Delhi Pollution Control Committee & Ors . has set
aside similar actions of the DPCC. In Mangolpuri ( supra ), the Court
made the following observations:
“ 5 . The Court, thus, finds that the impugned orders, though record
the factum of issuance of the SCN and the consequent reply filed by
the petitioners, they, however, do not spell out any reasons as to why
the reply was not found to be satisfactory.
6 . The Supreme Court, in Siemens Engg.& Mfg. Co. of India Ltd.
6
v. Union of India , held that recording of reasons in support of an
order is a basic tenet of natural justice. It was further held that the
requirement of passing reasoned orders must be observed in its
proper spirit; a mere pretence of compliance would not be enough.
7
Further, in Union of India v. Ibrahim Uddin , the Supreme Court
made the following observations on the importance of passing
reasoned orders:

“ 44 . It is a settled legal proposition that not only
administrative order, but also judicial order must be
supported by reasons, recorded in it. Thus, while decidingan
issue, the court is bound to give reasons for its conclusion. It
is the duty and obligation on the part of the court to record
reasons while disposing of the case. The hallmark of order
and exercise of judicial power by a judicial forum is for the

1
Order dated 07.04.2026 in W.P.(C) 10987/2025.
2
Order dated 25.03.2026 in W.P.(C) 7357/2025.
3
Order dated 22.04.2026 in W.P.(C) 4302/2022 and W.P.(C) 6804/2022.
Signed
By:PURUSHAINDRA
KUMAR KAURAV
Signature Not Verified
Signed By:PRIYA
Signing Date:06.05.2026
18:53:27
Signature Not Verified

forum to disclose its reasons by itself and giving of reasons
has always been insisted upon as one of the fundamentals of
sound administration of the justice delivery system, to make
it known that there had been proper and due application of
mind to the issue before the court and also as an essential
requisite of the principles of natural justice. The reason is
the heartbeat of every conclusion. It introduces clarity in an
order and without the same, the order becomes lifeless.
Reasons substitute subjectivity with objectivity. The absence
of reasons renders an order indefensible/unsustainable,
particularly when the order is subject to further challenge
before a higher forum. Recording of reasons is the principle
of natural justice and every judicial order must be supported
by reasons recorded in writing. It ensures transparency and
fairness in decision-making. The person who is adversely
affected must know why his application has been rejected.
(Vide State of Orissa v. Dhaniram Luhar [(2004) 5 SCC 568
: (2008) 2 SCC (Cri) 49 : AIR 2004 SC 1794] , State of
Uttaranchal v. Sunil Kumar Singh Negi [(2008) 11 SCC 205
: (2008) 2 SCC (L&S) 1093] , Victoria Memorial Hall v.
Howrah GanatantrikNagrik Samity [(2010) 3 SCC 732 : AIR
2010 SC 1285] and Sant Lal Gupta v. Modern Coop. Group
Housing Society Ltd. [(2010) 13 SCC 336 : (2010) 4 SCC
(Civ) 904])”

7. Therefore, the Court finds that the impugned orders have been
passed in a mechanical and cryptic manner, reflecting non-
application of mind. In the absence of reasons, the petitioners would
be precluded from effectively seeking further remedy.”

7. The Court, therefore, observes that the„one-line rejection‟
approach adopted by Respondent No. 2 while passing the impugned
orders, does not withstand the scrutiny of law. The reasons for „non-
satisfaction‟ must be explicit and discernible from a perusal of the
order. In the instant petitions, however, no such reasons have been
recorded.
8. For all the above reasons, the impugned orders passed in the
instant petitions will also have to be set aside.
9. Liberty is granted to Respondent No. 2 to pass a fresh order after
considering the reply filed by the petitioners, and after affording them a
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Signed By:PRIYA
Signing Date:06.05.2026
18:53:27
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reasonable opportunity of hearing.
Signed
By:PURUSHAINDRA
KUMAR KAURAV

10. With the aforesaid observations, the instant petitions, along with
all pending applications, stand disposed of.
11. All rights and contentions of the parties on the merits are left
open.

PURUSHAINDRA KUMAR KAURAV, J
APRIL 25, 2026/SH/SV

Signature Not Verified
Signed By:PRIYA
Signing Date:06.05.2026
18:53:27
Signature Not Verified
Signed
By:PURUSHAINDRA
KUMAR KAURAV