To the Prime Minister of India & the Union Minister for Environment and Forests

On behalf of over 1 crore residents living in a 30 km radius of wind borne contaminants from Pithampur, including the populous city of Indore and Dr Ambedkar Nagar Mhow, a sensitive military cantonment town which houses three premier category A training institutions of the Indian Army, we appeal to you to order a stop to the incineration of 307 metric tonnes of  “Hazardous Union Carbide Waste” from Bhopal at Pithampur in Dhar District of MP. 

Eminent cancer specialist Dr S S Nayyar of Indore has described this incineration as a “Slow Bhopal”. The alumni association of MGM Medical College Indore is also of the same opinion.

The eminent independent scientist Dr Pushpa Bhargava, founder of the CCMB (Centre for Cellular & Molecular Biology) Hyderabad, and India’s leading incinerator Company Thermax stated that no incinerator in India, including the Ramky incineration plant, had the sophisticated technical capability of dealing with the ‘Hazardous UC Bhopal waste’. Thermax flatly refused, in a conscionable decision, to incinerate this waste in its own incinerator, the best in the country.

Both the monitoring agencies being consulted currently, i.e. the Madhya Pradesh Pollution Control (MPPCB) and Central Pollution Control Board (CPCB) are government agencies. There is a serious conflict of interest here and hence an urgent need for truly independent and unbiased evaluation of the processes involved and the trial run results by a team of independent international experts.

In 2010 the then Union Environment Minister Shri Jairam Ramesh had taken cognizance of the protests of the residents of Pithampur and had promised them that the planned incineration would be cancelled. 

In the first four trial runs conducted during 2010 and 2012 the emission of dioxins and furans were above permissible limits. These are extremely dangerous chemicals which can cause immense harm to humans and animals. These tests were conducted using industrial waste (non hazardous) from industries in Madhya Pradesh other than Union Carbide (UCIL) Bhopal. Please note, the Hazardous UC waste contains Persistent Organic Pollutants (POPs) listed as banned substances, under the Stockholm Convention, to which India is a signatory. They pose severe risks to the environment and human and animal health. Despite using industrial and non hazardous waste for the trial, all four trails still failed on important points. In an order dated 01 Aug 2012, the MPPCB had ordered Ramky to close the incinerator and to not take any hazardous wastes from any industry.

In 2012 the then MP Chief Minister Shri Babulal Gaur and environment minister Shri Jayant Malaiya had promised the people of Madhya Pradesh that the incineration would not take place at Pithampur. 

Yet, in 2013, the Hon’ble Supreme Court allowed a trial run of 10 metric tonnes using so-called hazardous waste from HIL Kochi. Was the Hon’ble Supreme Court misled in this matter in 2013 given that it allowed a trial using non-equivalent hazardous waste from HIL Kochi, not Hazardous UC Bhoplal waste? To reiterate, there is no equivalence between any waste from Kochi and the Hazardous UC waste from Bhopal. And based on this trial run was it further misled into allowing the first ever trial run in 2015, the 6th, using hazardous UC Bhopal waste? Both trial runs of 2013 and 2015 failed nevertheless.

The results of the trial run of Aug 2015 of 10 metric tonnes showed that emission of Nickel was above permissible limits and the PM 2.5 test which measures  particulate matter below 2.5 microns (which has the ability to enter the lungs and the bloodstream of humans) was not conducted. 

And yet, between 28 Feb to 12 March 2025, the MP High Court at Jabalpur gave permission for 3 trial runs of 10 metric tonnes each. The results have been white-washed by overseeing Government agencies without independent scientific analyses. This position suddenly emerging after the complete earlier failures between 2010-2015 raises justifiable doubts and is without logic. 

It gets even more questionable when in the hearing of March 27, 2025, the State was given the go-ahead by the Hon’ble Court to incinerate the remaining 307 metric tonnes of hazardous Union Carbide Bhopal waste in a period of 72 days. In the light of the 6 trial runs from 2010-2015, followed by the 3 trial runs of Feb-March 2025, how has the MP State Govt so misled the Hon’ble High Court to deliver such an Order? 

There is a complete lack of transparency here, with regard to data and analyses in the public domain. In the face of serious failures with all 6 previous trial runs, 5 of them using substitute waste, how was it then decided to incinerate the remaining 307 Metric Tonnes at the Ramky incineration facility at Pithampur? This is unconscionable. 

Since it is the public that is at risk and at the receiving end of these Government decisions, it is constitutionally mandatory to make the full data public including that of the recent 3 trial runs in Feb-March 2025, that has led to Toxic Ash at the site. Incineration results in tripling the amount of residual waste or Toxic Ash.

Furthermore, in response to the mandate by the Hon’ble MP High Court, the MP State Govt and Ramky have stated that they would resume incineration after a four week period which is needed to rectify “certain faults” at the incineration plant. This confirms our stand and belief that the facility is hardly competent to conduct the incineration.  

In addition to this, the decision to incinerate is itself a dangerous decision to deal with this Hazardous UC Bhopal waste:

i) Incineration releases harmful toxins like dioxins, mercury, NOx, PM2.5, and PM10, which studies show are linked to cancer, respiratory diseases, congenital anomalies, and cardiovascular risks.  

ii) Incinerators pollute more than coal plants, releasing 28 times more dioxins, 2.5 times more CO₂, twice as much CO, three times more NOx, 6–14 times more mercury, nearly six times more lead, and 70% more SO₂.  

iii) More than 1000 MT of toxic residue ash from incineration will be buried in landfills, risking groundwater contamination and long-term environmental damage.

iv) European Commission policies since 2017 discourage incineration, favouring waste reduction and alternatives like bioremediation, plasma arc gasification, and chemical neutralization, which minimize pollution.

Due to the documented history of lack of safety of  the Ramky Incineration Unit, lack of any independent monitoring body to track the effect of the incineration process and analyse the resultant toxic waste, the arbitrariness of this decision, and extreme risk to public health and environmental safety, we request you to STOP THIS INCINERATION WITH IMMEDIATE EFFECT. 

Please, do not turn Pithampur into another Bhopal.