APTEL

### Variable charge deductions for monthly availability shortfalls are invalid if not expressly prescribed by governing regulations.

HINDUJA NATIONAL POWER CORPORATION LIMITED (HNPCL) vs ANDHRA PRADESH ELECTRICITY REGULATORY COMMISSION & Ors

APTELJUDGMENT: July 03, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The Appellant, HNPCL, operates a 1040 MW coal-based thermal power plant in Andhra Pradesh

Source reference: p.2-3

Following a history of litigation regarding tariff determination, HNPCL filed O.P. No. 12 of 2024 before the Andhra Pradesh Electricity Regulatory Commission (APERC) for Multi-Year Tariff (MYT) determination for the Fifth Control Period (FY 2024-25 to FY 2028-29)

Source reference: p.4-5

APERC issued an Impugned Order on 30.12.2025, which included a graded penalty deducting variable charges if monthly plant availability fell below normative levels and failed to specifically adjudicate on Part Load Compensation (PLC) claims

Source reference: p.5

The Appellant challenged five issues, but by mutual consent, the Tribunal narrowed the adjudication to the legality of deductions from variable charges and the entitlement to PLC

Source reference: p.6
02

Issues

1. Whether the State Commission has the statutory or contractual authority to impose graded deductions on variable charges (energy charges) based on shortfalls in monthly availability

Source reference: p.6, para. 8

2. Whether the Appellant is entitled to Part Load Compensation (PLC) and if the State Commission failed to adjudicate upon the quantification of the same

Source reference: p.17, para. 25
03

Law Applied

The Tribunal applied the CERC (Terms and Conditions of Tariff) Regulations, 2024, and APERC Regulation 1 of 2008, which establish a two-part tariff system

Source reference: p.9, 12

Under these regulations, Capacity Charges (Fixed Costs) are linked to plant availability, while Energy Charges (Variable Costs) are strictly linked to actual scheduled energy supplied

Source reference: p.9, 14

a Regulatory Commission cannot deviate from the prescribed methodology of a Regulation through an adjudicatory order without a formal amendment to the Regulation

Source reference: p.14-15

Relevant precedents included PTC India Ltd. v. CERC regarding the binding nature of regulations

Source reference: p.16

CERC (Indian Electricity Grid Code) (Fourth Amendment) Regulations, 2016, regarding Part Load Compensation

Source reference: p.18
04

Reasoning

Regarding Issue 1, the Tribunal reasoned that both the statutory framework (CERC/APERC Regulations) and the PPA clearly bifurcate fixed and variable costs. Fixed costs already contain an "in-built deterrent" because they are reduced proportionately if availability is low

Source reference: p.10, 14

The Tribunal rejected the State Commission’s "gap-filling" argument, noting that the Commission cannot impose additional penalties on energy charges—which are intended only for fuel cost recovery—because such a mechanism does not exist in the Regulations or the PPA

Source reference: p.15

Even if DISCOMs face higher costs for replacement power, the Commission must act within the "regulated framework" and cannot substitute its own view for statutory prescription

Source reference: p.14

Regarding Issue 2, the Tribunal found that the PPA explicitly provides for PLC under Clause 1.2.5 of Schedule-F

Source reference: p.18

Since the Respondents did not dispute the entitlement but only the process (True-Up), and the Impugned Order lacked a final determination on the quantified claim, the Tribunal found a need for reconciliation and formal determination

Source reference: p.18-19
05

Holding

The Tribunal held that the graded deductions from variable charges were ultra vires the Regulations and the PPA; it set aside the Impugned Order on this point and directed Respondents to refund withheld amounts with carrying cost within four weeks

The Tribunal affirmed the Appellant’s entitlement to PLC and remanded the matter to the State Commission for the specific purpose of determining and finalizing the amount payable in accordance with Regulation 6.3B of the IEGC

Source reference: p.19-20
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HINDUJA NATIONAL POWER CORPORATION LIMITED (HNPCL)vsANDHRA PRADESH ELECTRICITY REGULATORY COMMISSION & Ors

APTEL · July 03, 2026

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