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Festivals: A Time of Celebration or Impending Environmental Disaster

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India is a country having varied festivals celebrated round the year. But all this comes with a price which cannot be accounted for. The environmental damage caused by festivals is irreversable and in …

India is a country having varied festivals celebrated round the year. But all this comes with a price which cannot be accounted for. The environmental damage caused by festivals is irreversable and in long turn sustanability is endangered. Come let us not pollute our environment by taking a pledge I will protect the environment I live in come what ever may.


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  • 1. Festivals: A Time of Celebration or Impending Environmental Disaster (A Comprehensive Analysis on Degradation of Indian Environment) Sujoy Chatterjee* and Dr. Prashant Mehta** *Student III Semester B.Sc. LL.B. (Hons.), National Law University, Jodhpur (Raj.) ** Assistant Professor, Faculty of Science, National Law University, Jodhpur (Raj.) Email: prashantmehta1@rediffmail.com ABSTRACT In India with the advent of spring season just after monsoons, it is the season of festivals and festivities for different communities, where a spectrum of culturally very different rituals and mode of festival celebrations are witnessed. The whole gamut of festivals like Ganesh Chaturthi, Durga Puja, Diwali, and Holi are occasions for great joy and celebrations across the length and breadth of our country With festivals season comes a disaster. Pollution of various types is generated in large amounts all across the country, thereby adding an even greater load pollutants and contaminants to our already over polluted environment, overburdened rivers, lakes, and seas. This coupled with inadequate waste collection and waste disposal knowledge the devastating impact is far reaching is felt for longer duration of time. Immersion of idols made of plaster of paris, lime, cement contain toxic substances like lead paints, silt the water bodies leading to wide scale pollution and degradation of natural environment and thus threatning sustainability of many species. KEY WORDS: POLLUTION, FESTIVALS, AIR, WATER, SOIL, ENVIRONMENT INTRODUCTION On the onset pollution is a small word, but its impact is very broad, far reaching, and very specific. It can be described as change or alteration in physical, chemical, and biological characteristics of air (atmosphere), water (hydrosphere), and land (lithosphere) that is harmful to human beings and other forms of life. With unprecedented growth in population, growing urbanization, and rapid industrialization,
  • 2. the pollution has sky-rocketed all over the globe thus posing a serious threat to human health and environment particularly so in developing countries like India. In India, strict enforcement of environmental laws is lacking. Pollution of various types is generated in large amounts all across the country which is mostly untreated. This coupled with inadequate waste collection and waste disposal knowledge not only leads to devastating consequences but also have irreversible and far reaching impact and the consequences of such environmental degradation magnify with the passage of time and are felt for longer duration of time. A wide spectrum of culturally very different rituals and mode of festival celebrations are witnessed in India. Nature’s rhythm, seasonal changes and the cycle of life and death have found religious and spiritual re-enforcement through a number of traditional Indian festivals. However, with festivals come environmental disasters. During festival season, air and water pollution increases manifold. We have so many festivals and their increasing commercialization (a growing economy is turning every celebration into a grand occasion to splurge) has led to depletion or pollution of natural resources. In this scenario we should all be aware of what such large-scale unbridled celebrations are doing to our environment. WATER POLLUTION Even though safe drinking water1 is a problem in all the developing countries and limited fresh water resources, India has been polluting these precious treasures at an alarming rate. We are especially careless during festivities. Based on the theme of resurgence and rejuvenation, many festivals involve immersion of idols into water bodies as a symbol of returning the elements which give life, back to the earth for a new cycle to begin. In the recent years, the practice of immersion has become a growing cause for concern on account of its adverse environmental impacts, particularly on the water bodies. Toxic exposure of the larger community through deadly chemicals and heavy metals used for making idols is now being placed under the scanner 1 Safe Drinking Water – The need, the problem, solutions and an action plan – Report of Third World Academy of Sciences, July 2002
  • 3. of authorities and civil society groups with great focus. At the core of this concern is the issue of toxic materials and chemicals that have been added to the centuries old process of making idols for immersion. With a general deterioration of the water bodies due to growing population pressure and burgeoning pollution, the practice of immersion in its current form and volume is posing a serious hazard to life and environment. The festivals of Ganesh Chaturthi and Durga Puja witness a massive community involvement. To match the contemporary ethos, new materials are being used for ‘modernising’ the representation of these idols without much thought being given to the issue of toxicity and its impact on the environment. The festivities surrounding Ganesh Chaturthi and Durga Puja culminate with idols being immersed in various ponds and lakes, painting a picture of ecological disaster. Mumbai’s sea beaches take in 1.5 lakhs of Ganesh idols every year whereas in West Bengal, over 50,000 idols are immersed in the Ganges river after Durga Puja. Thus the problem is spread countrywide. Immersion of idols in these natural aquatic ecosystems destroys the whole ecological balance. The problem becomes more acute when dissolution of input in the environment exceeds the decomposition, dispersal, or recycling capabilities. These enhanced toxics from anthropogenic inputs not only alter the natural fresh waters, but also have detrimental effects whose impact can be felt for long time. The looming environmental crisis is due to the non-biodegradable materials used for making such idols and also the fact that the number of idols has gone up dramatically over the years implies that the concentration of such materials will increase in our natural resources. After examining the water before and after immersion the scientists found that the concentration of substances like calcium, magnesium, molybdenum and silicon concentrations increased significantly. Also, it was found that concentrations of heavy metals like arsenic, lead and mercury had increased. Metals like lead and mercury are particularly worrisome as they are dangerous to health and can damage the heart, kidneys, liver, circulatory system and central nervous system. A joint survey by the West Bengal Pollution Control Board and Indian Toxicology Research Institute found that each gram of colour used for painting the goddess has a high
  • 4. quantity of lead, ranging from 6 to 10 micrograms. “It should ideally be zero. Even in our body, zero micrograms per deciliter is the permissible limit for lead,” a committee member said.2 A. HEAVY METALS The rampant use of harmful paints on idols during Durga Puja and Anant Chaturthi and the culmination of a ten-day long Ganesh festival have triggered the fear of a health hazard and environmental pollution all across the country. Instead of traditional eco-friendly colours, harmful chemical paints are used in most of these idols (lead, cadmium and chrome). Heavy metals like lead, cadmium and chrome are not easily assimilated in an aquatic environment and this leads to contamination of water bodies there by affecting various fish and prawn species. Besides polluting the water, they reach humans via the food chain when humans consume the fish and other sea food. High levels of lead and other heavy metals can damage the heart, kidneys, liver, circulatory and central nervous system. Table 1: Changes in Concentration (mg/l) of some chemical pollutants after idol immersion in water bodies3 Chemical Mean Concentration before Concentration after Pollutants Concentration In Immersion of Idols Immersion of Idols Water Calcium 25.14 43.77 68.4* Magnesium 7.785 6.590 10.02* Molybdenum 0.090 0.149 0.534* Silicon 3.537 2.954 3.826** Arsenic 0.124 0.121 0.497 Iron 0.212 0.125 0.22** Lead 0.289 0.351 0.45** Mercury 0.689 0.553 0.778** Threshold Limit Value (TLV)4: *TLV=0.01; **TLV=0.05 Heavy metals like lead and chrome are not easily assimilated in an aquatic environment and can lead to the massive hurt of flora and fauna of the river, pond, lake and coastal areas. As the same river, pond and lake water is used for bathing and drinking purpose high levels of lead can damage the heart, kidneys, liver, 2 http://timesofindia.indiatimes.com/articleshow/3326576.cms ( as visited on 19/02/2009) 3 Goel, P.K. and Sharma, K.P., Environmental Guidelines and Standards in India, (Technoscience Publications, Jaipur) 4 TLV: The permissible level of a toxic pollutant to which a healthy person is exposed during an eight hour day without any adverse effect.
  • 5. circulatory system and central nervous system, the environmentalist warned. Toxic heavy metals are the cause of memory loss, increased allergic reactions, high blood pressure, depression, mood swings, irritability, poor concentration, aggressive behavior, sleep disabilities, fatigue, speech disorders, high blood pressure, cholesterol, triglycerides, vascular occlusion, neuropathy, autoimmune diseases, chronic fatigue and many other deadly diseases.5 B. PLASTER OF PARIS The growing size of idols and the desire for making them more and more colourful has forced idol-makers to shift from clay to Plaster of Paris as the base material. The increased use of Plaster of Paris is done because it is more malleable, dries faster and is stronger as compared to clay. Immersion of hundreds and thousands of idols made of this material is wreaking havoc on these water bodies. Plaster of Paris is a building material based on Calcium Sulphate Hemihydrates, and is created by heating Gypsum to about 150◦C. It is the same material that is used for making casts for broken bones. When an idol made of Plaster of Paris is immersed in the water, it changes form to gypsum, thus adding a large amount of material to the water that breaks down very slowly, while adding to the hardness of water, both of which deteriorate the life carrying capacity and quality of the water. it is an insoluble powder and contaminates water bodies by forming an impermeable layer on the bottom of pond or lake. The major exposure route is through inhalation, ingestion, skin and eye contact and common symptoms are watering of eyes, skin irritation, and trouble in breathing incessant coughing affecting organs like eyes, skin, and respiratory system. EFFECTS ON WATER QUALITY The water bodies are in a very poor state every year after Ganesh and Durga puja is over. Along with idols flowers, banana leaves, coconuts etc are immersed in various water bodies, resulting in alarming increase in pollution levels. It is mainly caused by dissolution of wastes coming from silting of clay, Plaster of Paris and the cheap toxic coloured paints (chemical dyes), painted on the idols which comes in contact with water. Once these idols are immersed, the clay along with Plaster of Paris (Calcinated Gypsum) 5 http://www.incrediblehorizons.com/toxicity%20&%20Autistic-symtoms.chelating.htm (as visited on 20/02/2009)
  • 6. slowly dissolve and accumulate at the bottom of the water body, whereas the toxic paints form a thin film on the surface of water. This cuts down the oxygen supply for aquatic animals and fish as decomposition of organic wastes uses oxygen in water making it impossible for aquatic animals to survive. Table 2: Impact of various items on aquatic environment during idol immersion6 S. No. Material Contributed by Immersion Impact on the Aquatic Body 1 Plaster of Paris Increases dissolved solids, contribute metals and sludge. 2. Decoration material viz. clothes, Contributes Suspended Particulate Matters (SPM), polish, paint, ornaments, cosmetic trace metals (Zinc, Lead, Iron, Chromium, Arsenic, items. Mercury, etc.), metalloids and various organic and inorganic matter, oil and grease, etc. 3. Flowers, garlands, oily substances Increase floating suspended matter, organic contamination, oil and grease and various organic and inorganic matter. 4. Bamboo sticks, beauty articles Pieces float in water or settle at the river bottom inhabiting river flow. 5. Polythene bags / plastic items Contribute suspended matter, settled matter and hazardous material to water and choke the aquatic life. 6. Eatables, food items, etc. Contribute oil and grease, organics to water bodies. The measured parameters of water quality standard show marked deviations from the established standards. Data collection and analysis was done for chemical and biological parameters. It showed that pH of water increased after the immersion of idols i.e. it led to acidification of the waters. There was a substantial increase in the Total Dissolved Solids (TDS) content. The TDS increased by nearly 100% after the immersion.7 The oxygen levels in the Mumbai water bodies fall by about 50% immediately after the 10-day Ganesh utsav festival. The result of a scientific study done on Hussain Sagar lake in Andhra 6 http://cpcb.nic.in/oldwebsite/ar2003/ar2-3ch7.htm (as visited on 19/02/2009) 7 http://www.indiatogether.org /2004/sep/ (as visited on 19/02/2009)
  • 7. Pradesh shows that in the water before and after immersion, scientists found that the concentration of substances like calcium, magnesium, silicon concentrations increased significantly. Also concentration of heavy metals like arsenic, lead and mercury had increased. Water soluble toxic organic paints resulted in depletion of Dissolved Oxygen (DO) 8 in these ancient ponds. This deprives fish and other aquatic inhabitants of oxygen. The impact was more than three trucks load of dead fish found floating on the surface of water. It not only led to water pollution but indirectly air was also polluted due to foul smell of dead fish. The other impacts of such pollution are notably color, turbidity, taste, odor etc. After such disasters we question our civic and administration authorities that should we allow immersion of idols in water body and deprive ourselves of fresh water, a scare commodity (0.003% of hydrosphere). In terms of health impacts, paints are a greater source of hazard and most of those used for decorating idols are chemical-based. They contain heavy metals like Mercury, Cadmium and Lead, which are neurotoxin and nephrotoxin. These metals are bio-accummulative, implying that once they enter marine life forms like fish; they pass up the food chain and end up in the food that we eat. Incidentally, the brighter the colour, the greater is its toxicity. Red, blue, orange and green colours are known to have higher content of mercury, zinc oxide, chromium, and lead. Concentration of Arsenic, a noxious trace element, increase nine-fold as compared to BIS and ICMR standards, in water bodies after idol immersions every year. After lot of hue and cry made by public and environmentalist the civic authorities decided to clean this old water reservoirs and they removed tones of mud, clay and plaster of paris from these water bodies just before the monsoons. With good monsoons these reservoirs received good amount of fresh water. But to the utter surprise the same old story was repeated during the festival of Ganesh and Durga puja when permission was given to immerse the idols this year and thereby polluting the water bodies once again. Although there are organisations working towards creating awareness about the benefits of using eco- 8 DO-An important water quality parameter. The oxygen dissolved in water is consumed by aquatic life for respiration and it helps in oxidising organic matter. Low DO indicates water pollution. The optimum value for good water quality is 4-6mg/l.
  • 8. friendly idols, and state governments do issue guidelines about immersions, not much is happening on the ground. Politicians are afraid of taking tough actions as they are afraid of upsetting the public as this is a religious issue. It is essential to put in place laws to make it compulsory to make idols out of eco-friendly materials. AIR POLLUTION Air pollution levels in big cities are appalling at the best of times and are a growing cause for concern. The Respirable Suspended Particulate Matter (RSPM) in dust, fumes, smoke, and gases is way above permissible limits in many of our big cities. This level sees a quantum jump during festivals, the main culprits being crackers, inflammable substances, and artificial colors. The burning of Ravana during Dussehra festival increases the air pollution due to evolution of smoke from fire crackers and burning idols. The main toxics which are discharged in to the atmosphere are Oxides of Nitrogen (NOx), Oxides of Sulphur (Sox), acidic gases, hydrocarbons, Oxides of Carbon (CO and CO2) compounds etc. Particulate dispersal also increases the pollution load in air. Crackers are sometimes manufactured using barium sulphate, sodium nitrate, sulphur and potassium chlorate. When burnt during Diwali and other festivals, they emit gases such as sulphur dioxide, oxides of nitrogen, oxides of heavy metals and particulate matter that pollute the air and cause eye irritation, respiratory disorders and allergies. The seemingly harmless, “pleasing to eye” colourful sparkles are synthetic and toxic because of the presence of cheap materials like mica, acids, alkalis and pieces of glass, which not only induce skin disorders like abrasion, irritation, itching but can also cause respiratory problems and even cancer. Studies by the Centre for Science and Environment (CSE) around Delhi conclude that in 2008, RSPM levels during Diwali doubled compared to2006. A Chandigarh Pollution Control Committee (CPCC) study last year showed a 06-10% percent increase in air pollution during Diwali. In a survey of ambient air quality during Kali Puja and Diwali days in 2004 the levels of nitrogen and sulpher dioxides were much higher than any normal day. The total Suspended Particulate Matter (SPM) and Respirable Particulate Matter (RPM) exceeded the permissible limit on Diwali in 2004 and 2003.
  • 9. Table 3: Comparison of Ambient Air Quality on Diwali during 2006 & 20089 Parameter (ug/m3) Recording in 2006 Recording in 2008 Normal residential standard SPM 246 243 200 RPM 133 129 100 The impact of these air pollutants is wide spread. They alter visibility; affect human health and vegetation in many ways. Air pollution can lead to lung cancer, cardiovascular diseases, chronic respiratory diseases, and allergies in adults. It can also cause acute respiratory infections in children. Suspended particulate matter can cause asthma, bronchitis, and other respiratory disease  Sulfur dioxide can damage lungs and lead to lung disorders like wheezing and shortness of breath.  Oxides of Nitrogen can cause skin problems, eye irritation, and cause respiratory problems in children.  Chemicals used in crackers like Lead, Magnesium, Cadmium, Nitrate, Sodium and others cause mental retardation and act as enzyme inhibitors.10 Clearly environmental groups and eco-clubs are fighting a losing battle. They come up with awareness campaigns and slogans like “Diwali is a festival of lights, not crackers”, “celebrate an eco-sensitive Diwali this year”, but nobody seems to take notice. The State Pollution Control Boards have given a wide publicity to the Supreme Court’s direction on the use of fireworks only between 6.00 a.m. and 10.00 p.m. through electronic and print media. In addition, request made to the cellular operators for sending an awareness message “Say No to Crackers”. Celebrate Deepavali with lamps, candles and fireworks.’ to their customers have also been made, with the hope of creating awareness. IMPACT ON AIR QUALITY STANDARDS11 9 Goel, P.K. and Sharma, K.P., Environmental Guidelines and Standards in India, (Technoscience Publications, Jaipur) 10 http://www.window2india.com/cms/admin/article.jsp?aid=2250 (as visited on 19/02/2009) 11 http://timesofindia.indiatimes.com/Cities/Delhi/Festivals-record-steep-rise-in- airpollution/articleshow/msid-1261864,curpg-2.cms (as visited on 19/02/2009)
  • 10. Air quality is known to suffer every time the festive season draws close. According to the Central Pollution Control Board (CPCB), the concentration of air pollutants - Sulphur dioxide (SO2) and Nitrogen dioxide (NO2) increases massively during this period. While the average concentration of sulphur dioxide and nitrogen dioxide recorded is 07 ug/m3 and 91 ug/m3, a startling 10 ug/m3 and 101 ug/m3 is recorded after the festive season. This means a considerable increase in air pollution. "The maximum fire crackers are burst because of Lanka Dahan. The increase is air pollution is not an unusual phenomenon as every year during Dussehra the air pollution increases manifold due to this. As a result, public health is known to suffer." Other air pollutants also record an increase. The Respirable Suspended Particulate Matter (RSPM) also sees a record jump. RSPM increases from the average concentrations of 213 ug/m3 to 310 ug/m3 by the end of the festive season. LACUNAE IN THE LAW It is high time our policy makers shrug off concerns of hurting religious sentiments by enforcing certain regulations during festivities. It will lead to disastrous results if we are continue to play with our environment and disturb the natural balance when we know that India is rated as one of the most polluted countries of the world. Waste management, waste segregation and control have to be initiated at all levels and the public must be made aware of how to dispose domestic wastes. A total ban on all festival extremities is not the answer. Rules and regulations should be imposed on festive activities which have drastic impact on our environment. This will help us to address an ever growing problem of pollution in and around our cities and localities. The government, NGOs, and the education system along with public awareness campaigns have to contribute towards tackling this fast spreading problem. Pollutants are produces by natural ecosystems as well as by human beings in form of agricultural and industrial activity. As the twentieth century comes to close the sheer volume of wastes has increased manifold. There is no way to curtail the pollution entirely, but there are many ways to cut the amount of pollution and reduce the harmful impact. Pollution control must receive some high priority and government should be encouraged to devise a clear and effective policy formulation for pollution abatement. Also State Pollution Control Boards should be
  • 11. instructed to frame guidelines banning the immersion of idols containing hazardous paints or plaster of Paris in public water bodies. Greater public awareness along with development of legal and regulatory framework backed by strong public opinion would be necessary to bring about substitution. The problem has to be treated under the Air (Prevention and Control of Pollution) Act 1981 and Environment (Protection) Act 1986 and certain directives have to be passed to that effect. Though it is still upto the Police and local administration to implement it - but at least the legal steps have to be taken in the right direction. THE REMEDIES We need to have laws enforcing prevention of air and water pollution. If needed, cases are to be fought in the Courts to prevent further misuse during festivities. The legal fraternity needs to come forward and accept their responsibility in this regard. Abroad, in countries like UK, several laws and steps have constantly been taken to ensure celebrations don’t cause large-scale havoc. For example, it was seen in England on and around Bonfire Night (November 5th), there is often a noticeable increase in pollution from particulates and dioxins. Approximately 14% of UK dioxin emissions are produced around bonfire night most of this coming from bonfires and fireworks. Authorities have recognized that fireworks are the cause of noise and air pollution. The following rules have been put into place under Fireworks Regulation 200412 in England.  It prohibits anyone under 18 from possessing fireworks, and anyone except professionals from possessing display fireworks.  These regulations also prohibit the use of fireworks at night (11pm–7am) in England and Wales, with extensions for the following festivals:  Until 1am following the first day of Chinese New Year  On November 5th until 12am  Until 1am on the day following Diwali day  Until 1am on the day following December 31st 12 http://www.opsi.gov.uk/si/si2004/20041836.htm (as visited on 19/02/2009)
  • 12. RETURN TO ECO-FESTIVALS Do all our festivals and celebrations have to be at the cost of our environment, health and life? No! CLEAN-India has these simple, cheap yet beautiful environment and human friendly suggestions with which we can celebrate our festivals:  Religiously only metal, stone or unbaked clay idols are worshipped.  Idols made of metal or stone are best as they can be worshipped every year. Some people sprinkle a little water on the idols as symbolic immersion.  If idols have to be immersed make sure they are made of unbaked mud or clay.  Do not buy idols painted with chemical colours or those having non-biodegradable material (thermocol, plastic, etc) as decorations.  Smaller clay idols can be immersed in clean water in a vessel at home. Leave for sometime and when clay mixes with water give it to your plants, especially Tulsi.  Or simply place the clay idols in a potted plant. The clay from the idol will mix with soil gradually when the plant is watered.  You can even make idols yourself by using clay or mud from your home. Or make dough using turmeric powder or flour and make symbolic shapes of idols and worship.  Such idols can be coloured using natural colours like haldi, chandan, kesar, kumkum etc.  Flowers and other biodegradable material used in worship may be used for mulching by spreading them on the top soil around plants or trees. They can also be composted. Similar stringent laws are required to be passed and implemented in India, in order to ensure that festivities are in proper concordance with acceptable environmental standards. CONCLUSION Festivals like Ganesh Chaturthi, Durga Puja, Diwali, and Holi are occasions for great joy and celebration. But unfortunately they also add an even greater load to our already polluted air and water. But all our festivals and celebrations do not have to be at the cost of degrading our environment and jeopardizing
  • 13. personal health. Simple measures can be taken to ensure that Indian festivals become environment and human friendly. The government, police, pollution control boards are suggesting many alternative ways to celebrate festivals which does not pollute the environment. Even strict and stringent warnings are also given to public to refrain from purchasing ‘toxic’ idols and bursting harmful crackers. But it is all solely depend on the “change of mind”. Some suggestions regarding reduction of water pollution are – • Stone idols are worshipped. Idols made of stone are best as they can be worshipped every year. Sprinkling a little water on the idols as symbolic immersion is a common practice in many households. • Immerse only those idols which are made of unbaked mud, clay or other biodegradable material. • Avoiding manufacture and purchase of idols painted with chemical colours or those made with non- biodegradable material (thermocol, plastic, plaster of paris etc). • Smaller clay idols can be immersed in clean water in a vessel at home. Leave for sometime and when clay mixes with water give it to your plants, • Place the clay idols in a potted plant. The clay from the idol will mix with soil gradually when the plant is watered. • Idols can be coloured using natural colours like haldi, chandan, kesar, kumkum, etc, which are biodegradable and do not cause persistent pollution after immersion. • Flowers and other biodegradable material used in worship may be used for mulching by spreading them on the top soil around plants or trees. They can also be composted. In order to tackle avoid air pollution: • Fireworks and colours must be bought from registered sources who sell non-toxic products. • Items containing harmful chemicals should be avoided strictly. • Regulate manufacture, purchase as well as use of harmful crackers.
  • 14. • Avoid letting off fireworks in unsuitable weather. Cloudy and misty weather implies air quality will be worsened by bursting of crackers. As the twentieth century comes to close the sheer volume of wastes has increased manifold. There is no way to curtail the pollution entirely, but there are many ways to cut the amount of pollution and reduce the harmful impact. Pollution control must receive some high priority and government should be encouraged to devise a clear and effective policy formulation for pollution abatement. Also state pollution control board should be instructed to frame guidelines banning the immersion of idols containing hazardous paints or plaster of Paris in public use water bodies. Greater public awareness along with development of legal13 and regulatory framework backed by strong public opinion would be necessary to bring about substitution. It is estimated that one liter of waste water pollutes eight liters of fresh water. If this is the rate the day is not far when we are deprived of fresh water all together. The Government has the responsibility to implement strict regulation of environmental standards during festivities. But society at large must also share this burden of keeping the environment clean and healthy. Let us take the initiative and ensure a less polluted festival season 13 Water (Prevention) Pollution Control Act, 1974 and the Environment Protection Act, 1986.