PLI Act explained: this guide covers what it means, who it applies to, the step-by-step process, documents required, fees, due dates and penalties in India — so you can stay compliant with confidence and avoid costly mistakes.
Since 1 April 2024 the PLI Act punishes failure to insure and failure to obey directions by civil penalty, not imprisonment. Section 14 sets a penalty tied to the annual premium for contravening the insurance duties in section 4. Section 15 penalises non-compliance with directions and obstruction. Section 15A appoints an adjudicating officer, and section 15B gives an appeal to the National Green Tribunal.
This article is current as amended up to the Jan Vishwas (Amendment of Provisions) Act, 2023 (in force for this Act from 1 April 2024). That Act substituted sections 14 and 15 with sections 14, 15, 15A and 15B. Until 31 March 2024 these contraventions were offences punishable with imprisonment. Later amendments and notifications should be checked. If you face a penalty inquiry, our legal dispute resolution team can help.
Section 14: contravening the insurance duties in section 4(1), (2), (2A) or (2C) attracts a penalty equal to the amount of the annual premium and which may extend to twice that premium, with an additional monthly penalty not exceeding the premium. Section 15: not obeying a section 12 direction, or a section 9 direction, or obstructing under section 10 or 11, attracts a penalty of not less than ten thousand rupees, up to fifteen lakh rupees, with a daily additional penalty. An adjudicating officer imposes the penalty after a hearing. Appeal to the NGT within sixty days with ten per cent deposited.
Section 14: penalty for contravention of section 4
Section 14(1). "Where any person contravenes any of the provisions of sub-section (1), sub-section (2), sub-section (2A) or sub-section (2C) of section 4, he shall be liable to penalty equal to the amount of annual premium for insurance policy and may extend to twice the amount of such premium."
Section 14(2). "Where contravention under sub-section (1) continues, an additional penalty may be imposed by the adjudicating officer, which shall not exceed the amount of premium to be paid, for each month or part thereof during which the contravention continues."
The penalty is measured by the premium, not by a fixed sum. The sub-sections of section 4 it covers are the duty to insure before handling (1), to renew (2), to insure for not less than paid-up capital (2A) and to pay the further Relief Fund amount (2C); see sections 3 and 4.
Section 15: penalty for non-compliance of directions
Section 15(1). "Where any person does not comply with any direction issued under section 12, he shall be liable to penalty which shall not be less than ten thousand rupees which may extend to fifteen lakh rupees."
Section 15(2). Where non-compliance continues, "he shall be liable to additional penalty to be imposed by the adjudicating officer, which shall not be less than ten thousand rupees for every day during which such non-compliance continues".
Section 15(3). "Where any owner does not comply with the direction issued under section 9 or obstructs any person in discharge of his functions under section 10 or under sub-sections (1), (2) or (3) of section 11, he shall be liable to penalty which shall not be less than ten thousand rupees but which may extend to fifteen lakh rupees."
Section 15(4). Where non-compliance continues under sub-section (3), "he shall be liable to additional penalty of ten thousand rupees for every day during which such non-compliance continues".
Note two features of the printed wording. In sub-section (2) the daily additional penalty "shall not be less than ten thousand rupees", a floor; in sub-section (4) it is "of ten thousand rupees", a fixed figure. The directions and inspection powers are in sections 9 to 13.
Section 15A: the adjudicating officer
Section 15A(1). The Central Government, for determining the penalties under sections 14 or 15, "may appoint the District Magistrate having jurisdiction over the area or an officer not below the rank of Director to the Government of India or an officer not below the rank of Joint Secretary to the State Government, to be the adjudicating officer, to hold an inquiry and impose penalty in the manner, as may be prescribed". The proviso lets it appoint as many adjudicating officers as required.
Section 15A(2). The adjudicating officer "may summon and enforce the attendance of any person acquainted with the facts and circumstances of the case to give evidence or to produce any document", and if satisfied on inquiry that the person has failed to comply with section 4(1), (2), (2A) or (2C) and section 12, "he may determine such penalty as he thinks fit under the provisions of sections 14 and 15". The proviso: "no such penalty shall be imposed without giving the person concerned a reasonable opportunity of being heard."
Note that, unlike the Environment (Protection) Act and the Air Act, section 15A here does not contain a sub-section saying the penalty is in addition to relief or compensation under the NGT Act. The manner of inquiry is "as may be prescribed", and the PLI Rules are not explained in this series. For the matching adjudication scheme in the EP Act see sections 15C and 15D of the EP Act.
Section 15B: appeal to the National Green Tribunal
| Sub-section | Rule |
|---|---|
| (1) | Whoever is aggrieved by the order passed by the adjudicating officer under section 15A may prefer an appeal to the National Green Tribunal established under section 3 of the NGT Act, 2010 |
| (2) | The appeal must be filed within sixty days from the date on which the copy of the order is received by the aggrieved person |
| (3) | After giving the parties an opportunity of being heard, the Tribunal may pass such order as it thinks fit, confirming, modifying or setting aside the order appealed against |
| (4) | The appeal "shall not be entertained by the Tribunal unless such person has deposited with the Tribunal ten per cent. of the amount of the penalty imposed by the adjudicating officer" |
Penalties at a glance
| Section | Contravention | Penalty as printed | Additional penalty |
|---|---|---|---|
| 14(1) | Section 4(1), (2), (2A) or (2C) | Equal to the annual premium; may extend to twice the premium | 14(2): may be imposed, not exceeding the premium to be paid, for each month or part of a month |
| 15(1) | Direction under section 12 | Not less than ten thousand rupees; may extend to fifteen lakh rupees | 15(2): not less than ten thousand rupees for every day |
| 15(3) | Direction under section 9; obstruction under section 10 or 11(1) to (3) | Not less than ten thousand rupees; may extend to fifteen lakh rupees | 15(4): ten thousand rupees for every day |
Section 3 of the Jan Vishwas (Amendment of Provisions) Act, 2023 provides that fines and penalties in the enactments in its Schedule increase by ten per cent of the minimum amount after the expiry of every three years from its commencement. The figures above are as printed.
What follows
Penalties under sections 14, 15 and 17 are credited to the Environment Relief Fund under section 17A; failure to pay within ninety days is an offence under section 17B. See sections 16 to 17B.
Practical points
- Insure and renew on time. The section 14 penalty is calculated on the annual premium and grows monthly while the contravention lasts.
- Answer directions. Daily penalties can run under section 15(2) and (4).
- Use the hearing. No penalty may be imposed without a reasonable opportunity of being heard.
- Diarise sixty days from receipt of the order, and plan the ten per cent deposit.
An example
Kunda Fertilisers Limited handles a notified hazardous substance but lets its policy lapse for several months. The adjudicating officer, after a hearing, imposes a penalty under section 14(1) measured on the annual premium, and an additional monthly penalty under section 14(2) for the months the lapse continued. The company deposits ten per cent of the penalty with the Tribunal and appeals within sixty days of receiving the copy of the order.
Need help with a penalty inquiry?
A penalty tied to the premium and to monthly or daily periods depends on the dates you can prove. Our legal dispute resolution team can help you assemble the policy history, prepare for the hearing and file an appeal on time.
Key takeaways
- Section 14 penalises contravention of the insurance duties in section 4 at the annual premium, up to twice the premium, with an additional monthly penalty.
- Section 15 penalises non-compliance with directions and obstruction at ten thousand to fifteen lakh rupees, with a daily additional penalty.
- An adjudicating officer, who may be the District Magistrate, imposes the penalty after a hearing.
- Appeal lies to the NGT within sixty days, with ten per cent deposited.
- Until 31 March 2024 these contraventions were offences punishable with imprisonment.
Read next
- Sections 16 to 17B: Government Departments, Relief Fund credit and failure to pay
- Sections 9 to 13: information, entry, directions and injunction
- Sections 15C and 15D of the EP Act: adjudicating officer and appeal
- Public liability insurance compliance for industries
Disclaimer: Based on the Environment (Protection) Act, 1986, the Air (Prevention and Control of Pollution) Act, 1981 and the Public Liability Insurance Act, 1991 as amended by the Jan Vishwas (Amendment of Provisions) Act, 2023 (in force for these Acts from 1 April 2024), the Water (Prevention and Control of Pollution) Act, 1974 as amended by its Amendment Act of 2024 (which applies only in the States and Union territories it names and in States that adopt it), and the National Green Tribunal Act, 2010 as amended by the Tribunals Reforms Act, 2021, as consulted on 3 October 2026. Later amendments, rules and notifications should be checked. This article is general information, not legal advice; check the official text before acting.
