A critical analysis of legal responses to water pollution in Pakistan

Abstract Water pollution faces an environmental crisis that makes water unhealthy or decreases the availability of water resources. Water pollution refers to the presence of dangerous chemical compounds and biological agents in water that may exceed certain compounds in water, which may endanger freshwater resources, human health, and the environment as well. Water is a necessary component for all living things to survive. Fresh water exists in the form of groundwater, lakes, and rivers. Apart from the physical scarcity of water, Pakistan is a country facing economic disaster. With the growing population, the pressure on the limited source of fresh water is increasing every day and the state of affairs is getting worse. Water quality and quantity are decreasing with the growing populace and due to climate change. In Pakistan, water quantity has decreased by 400 from 5,600 cubic meters in 1947 to 1,038 cubic meters in 2021. In these situations, water pollution is a threat to water resources. In this context, our study has been conducted to assess the national laws and regulations for water pollution prevention in Pakistan and to establish their extent and effectiveness. This study points out their flaws and barriers and offers potential solutions.


Introduction
Pakistan is facing an economic crisis along with a physical shortage of water.Water demand is increasing significantly as a result of a growing population, increasing urbanization, and rapid industrialization (Bhat, 2014).With a growing population, stress on confined freshwater assets is growing each day and the state of affairs is getting worse (Khoso et al., 2015).
Pakistan faces an increasing risk of water scarcity, overuse of water, and deterioration of water quality.Having a lower capacity for water storage, Pakistan is losing water from its canals and rivers in the Arabian Sea.There are three major water reservoirs in Pakistan, i.e.Mangla which was constructed in (the year 1967), Tarbela which was constructed in (the year 1978) and Chashma which was established in (1971).The said dams were constructed and designed to have a storage capacity of 15.75 MAF but now with time storage capacity of these dams is reducing and presently the storage capacity of these dams has been reduced to 13.1 MAF due to sedimentation and other factors (Basharat, 2019).
In many parts of Pakistan, people get water for domestic purposes from surface sources such as streams, rivers, lakes, etc.In Pakistan, surface water reservoirs depend on the flow of the Indus River and its five tributaries (Ali et al., 2009).The Indus Basin depends on glaciers.The Karakoram and western Himalaya glacier melting water falls into the Indus Basin and 268 million people use it for domestic purposes, including hydropower, industry, and irrigation.These glaciers and ice have considered being water towers, but due to climate change, the earth's temperature has risen and these glaciers are thinning and retreating (Hasson et al., 2017).
Pakistan will pass through the phase of excessive water stress by 2020.If this situation continues, Pakistan will join the list of 33 countries under extreme water stress by 2030 (Luo et al., 2015).According to the Washington-based magazine, the International Monetary Fund (IMF) Pakistan has ranked at 3 rd position within the list of nations experiencing extreme water scarcity (Akbar et al., 2021).In these situations, water pollution is a threat to water resources.
Pakistan Council of Research in Water Resources (PCRWR) implements a countrywide programme for monitoring water quality.The Water Quality Monitoring Program of 2020 has been implemented in 29 cities.Tube wells, taps, Water Supply Schemes, bores, hand pumps, injection pumps, filtration plants, wind mills, dams, karez, springs, wells, rotters, storage tanks, springs, and some surface resources in all four provinces, Azad Jammu and Kashmir and Gilgit-Baltistan were monitored.A comparison of water quality data with national standards revealed that out of 435 sources, 168 (39%) were safe for consumption while 267 (61%) were unsafe (Rasheed et al., 2021).Water quality data related to 29 cities in Pakistan are presented in the Table 1.
According to the PCRWR report the underground water has been contaminated with different waste materials such as arsenic, iron, fluoride, and bacteria.The report reveals the spread of bacteriological contamination (39pc), followed by arsenic (8pc), nitrate (4pc) and fluoride (4pc), etc (Farooqi et al., 2007).The inorganic arsenic contamination in underground water, lead to long run bad effect on human life such as skin disease including pigmentation changes, skin lesions and hard patched on the palms and soles of the feet, and skin cancer, also a cause of cancers of the bladder and lungs (Isangedighi & David, 2019).Data on groundwater quality are shown in Table 2.The examination and monitoring of the quality of Pakistan's ground waters have been discussed in light of the reported source of contamination, sample location, and pollutant parameters.
In Pakistan, sewage effluents discharge into surface water resources.Sewage is a community's used water, with its liquid element serving as a carrier for waste transfer in sewers.Sewage effluent is not treated before disposal.There are two main sewage disposal systems.One method is direct discharge into veggies and vegetation, while the other is into the rivers or lakes (Shafqat, 2011).Data on surface water quality are shown in Table 3.The examination and monitoring of the quality of Pakistan's ground waters have been discussed in light of the reported source of contamination, sample location, and pollutant parameters.
The Ministry of Health, the Government of Pakistan, and the World Health Organization (WHO) reviewed the drinking water quality standards in Pakistan, revised them in conformity with WHO drinking water quality criteria, and finalized them.Table 4 shows data related to Water quality standards of WHO and PAK-EPA

Sources and status of water pollution in Pakistan
The pollution of water resources including rivers, lakes, and underground reserves is a result of untreated sewage water from large cities, industrial chemical waste, and agricultural drainage.The main reasons for declining water quality in Pakistan are:

Municipal wastewater
Municipal waste significantly contributes to water pollution.Municipal wastewater is directly released into storm drains and nullahs, where it reaches rivers, canals, and streams without being treated.In Pakistan, Sewage effluent is not treated before disposal.Sewage is a community's used water, with its liquid element serving as a carrier for waste transfer in sewers.In Pakistan, there are two main sewage disposal systems.One method is direct discharge into veggies and vegetation, while the other is into the rivers or lakes (Shafqat, 2011).
According to Pak-SECA (2006) account for 2,000 million waste water has been dumped into the water reservoir each day in Pakistan.Wastewater has turned out to be a highlighted trouble in all fundamental commercial cities, consisting of Karachi, Lahore, Faisalabad, Multan, Hyderabad, Rawalpindi, Sheikhupura, and Kasur.Only 8 cities have minimum remedy facilities.According to the Pakistan Water Situation Analysis, in Islamabad, out of three wastewater treatment plants, only one is operational.There are some screening and grit removal systems in Lahore and Karachi, but they hardly work.There is a wastewater treatment facility in Faisalabad where wastewater is given initial treatment (Murtaza & Zia, 2012).Table 5 presented the data regarding total wastewater generation and collection in large cities in Pakistan.

Industrial waste
Water quality around industrial areas in Punjab, Sindh, and KPK provinces is being adversely affected by a discharge of industrial wastes in the form of radioactive materials, toxic chemicals, and other solids and liquids.There are more than 6,000 industrial sites in Karachi alone, and all discharge their waste directly into waterways.This waste includes heavy metals, hazardous compounds, toxic solids, and toxic liquids (Aslam et al., 2021).Industrial units including textile, chemical, food processing, pulp and paper, poultry, dairy, plastic, paint, pesticides, leather, tanneries, and pharmaceuticals discharge their waste directly into the canal system, which contaminates groundwater as well (Raza, 2014).Only 1% of wastewater is treated before being released into the water bodies by industry.Sindh Industrial Trading Estate (SITE) and Korangi Industrial and Trading Estate (KITE) in Karachi, there isn't any waste remedy plant in the two biggest industrial estates of Pakistan.A fertilizer manufacturing unit in Multan has dumps waste into the crops, killing cattle and raising human health risks (Shahid, 2005).Only 3 of the 100 industries in Lahore that use unsafe chemicals deal with their effluent.Like all huge cities Karachi dumps 600 million tons of sewage into the ocean every day.Lahore released approximately 2 hundred million tons of liquid and 100 million tons of solid waste into the Ravi River (Jabeen et al., 2015).
In DG EPA vs Sheikh Yousaf (2019) CLD 155, the accused was fined Rs 500,000, around £ 2,500, for disobeying EPO directives.This instance concerned with pollution caused by a tannery, the tannery exceeded the NEQS by releasing untreated effluent wastewater casue pollution.The respondent admitted that he had failed to comply with EPO orders, he had no system in place for safe wastewater disposal but his tannery was no longer operating.Chairperson Shazab Saeed ordered an inspection of the site, which found that the tannery was still in operation.

Agricultural run-off
The quality of water is also impacted by agricultural practices that utilize pesticides and fertilizers to grow crops.Every year, almost 5.6 million tonnes of fertilizer and 70,000 tonnes of pesticides are utilized in Pakistan.The usage of fertilizers is rising in Pakistan and these fertilizers affect the surface and groundwater, which ultimately contaminates the lakes and rivers.This has been emphasized in numerous studies, including the investigative report by the Pakistan Council of Research in Water Resources (PCRWR), which took a few samples of water from agricultural runoff and tested them.They discovered that one-fifth of the samples contained traces of residue from fertilizers and pesticides.According to the research, Punjab's water system has chemical pollution well above the WHO's recommended standards owing to fertilizers and pesticides (Aslam et al., 2021).Table 6 presented the sector wise estimated wastewater production in Pakistan.

Methodology
The investigation process began with an assessment of water pollution problems in the country.This study will be based on doctrinal research.Hence, primary and secondary sources of law will be made use of.The research design of this work is a descriptive collection of data through Secondary sources like journals, articles, and newspapers; primary sources like books will be used.

Legal and institutional framework in Pakistan
In Pakistan, both federal and provincial governments will enact laws related to the conservation of natural resources (Upadhyay & Alam, 2014).Before 1997, there was no comprehensive law to protect freshwater sources from pollution (Naureen, 2009)  public springs or water reservoirs.The Canal and Drainage Act, 1873, according to section 70 of the CDA imposes a fine and three months' imprisonment for polluting the water of any canal in such a way that it is no longer suitable for the purpose for which it is normally utilized.The Factories Act, 1934 section 14 requires factory owners to create efficient plans for the disposal of waste generated during the production process.Polluters are also penalized.The Forest Act, of 1927, according to section 26(I) if any person, in violation of the rules, poisons the water of a forest area has been punishable.The Sind Fisheries Ordinance, 1980, section 8 states that before being dumped into the waterways, sewage and industrial waste must be treated.Easement Act, 1882, section 7 Illustrations (f) and (h) deal with water pollution (Fazil, 2014).Pakistan was the first country to adopt the Sustainable Development Goals (SDGs) 2030 through a unanimous resolution of the National Assembly in 2016.This contains Objective 6.1, which aims to provide universal and equitable access to safe and affordable drinking water for all.Pakistan reaffirmed its commitment to the 2030 Agenda for Sustainable Development by adopting the Sustainable Development Goals (SDGs) as its national development (Ishaque et al., 2023).
Municipal Wastewater is the primary contributor to the problem of water pollution.Poor wastewater discharge quality is to cause the deterioration of receiving surface water bodies (Edokpayi et al., 2017).In Pakistan, there are several institutions involved in wastewater collecting, disposal, and treatment (Cooper, 2018).Water and Sanitation Agencies (WASAs), Karachi Water and Sewerage Board (KWSB), Water and Sanitation Services Peshawar (WSSP), and Capital Development Authority (CDA) are now in charge of water and sanitation in metropolitan regions of Pakistan (Khalid & Khaver, 2019).Tehsil Municipal Administrations (TMAs) and Municipal Corporations govern small and medium-sized cities across the country (Nawab & Nyborg, 2009).Public Health Engineering Departments (PHEDs) in Khyber Pakhtunkhwa, Balochistan, and Sindh to construct and run water and sanitation projects in rural regions.PHEDs prepare plans in Punjab, which are subsequently administered by community-based organizations (CBOs) (Cooper, 2018).
Water and Sanitation Agencies (WASAs), which encompass 44% of Pakistan's urban population, are in charge of wastewater management activities in major city metropolitan regions (Fawad & Khalid, 2008).Water and sanitation agencies (WASAs) have been established in five main Punjab cities: Lahore, Multan, Gujranwala, Faisalabad, and Rawalpindi, one in Quetta, Baluchistan as well (Khalid & Khaver, 2019).

Critical analysis: Gaps and barriers
The PEPA of 1997, the Punjab EPA of 2012, the Sindh EPA of 2014, the Balochistan EPA of 2013, and the KPK-EPA of 2014 all create a comprehensive regulatory framework to safeguard, maintain, protect, treat, or restore the environment, prevent pollution.However, pollution crises are remaining.Many techno-legal challenges remain in it.In Pakistan, the Protection of freshwater resources from domestic and industrial pollution is limited by poor legal and institutional frameworks and impediments in the implementation of laws.
• Pakistan follows a dualist approach to the implementation of international law at the domestic level.
The international treaties, conventions, and agreements that Pakistan has ratified do not immediately become a part of its domestic legislation.Therefore, national legislation is required to implement the international agreement.The subjects of environmental pollution are mentioned in the concurrent legislative List.This means that both federal and provincial governments have the power to legislate.The International Union for Conservation of Nature [IUCN] observes that effective environmental pollution control depends in large part on a uniform protection regime across the country.Additionally, the IUCN pointed out that while executing treaties and accords remained a federal responsibility, the issue of Pakistan's international duties under multilateral environmental treaties needed to be handled at the federal rather than the provincial level (Lau, 2018).
• World Wide Fund for Nature [WWF] (2018) observes that the lack of public awareness about filing a complaint as well as the non-functioning of some environmental tribunals and environmental magistrates is a major obstacle to the legislative process.In Pakistan, insufficient investment in professional cadres of environmental managers, attorneys, and specialists for the administration and enforcement of these laws is a key contributor to inefficient compliance with current legislation.Pakistan continues to lack managerial, professional, and techno-legal competencies to ensure successful compliance with the Act as a result of the EPA's under-resourcing (Sial et al., 2018).
• Ahsan and Khawaja (2013) examine the capacity building of enforcement agencies and judiciary to remove pollution crimes in Pakistan.Neither the judges nor the lawyers are informed about this subject and law schools do not provide any environmental courses.Furthermore, there is no environmental law component in the district judiciary's judicial training.There is no mandatory requirement for higher judiciary training in Pakistan.They are, nevertheless, introduced to specific themes through conferences and seminars.Another factor is that there are few financial incentives in this sector, which leads to a lack of knowledge and enthusiasm among attorneys.There are currently very few PIL attorneys and most of them work on human rights claims rather than environmental protection cases.A few landmark decisions were made in the domain of water conservation and improvement.Another comment in this regard is that the specialized environmental tribunals complicate the superior courts' writ authority.These courts frequently decline to consider cases involving environmental damage, instead directing them to environmental tribunals.
• For a variety of reasons, the administrative structure of EPAs is flawed, resulting in inefficiency, ambiguity, and a lack of transparency.Ahsan and Khawaja (2013) observe that the federal or provincial director-general has absolute powers under these laws.Power concentration is problematic because it offers an individual too much discretion makes decision-making subjective and lacks group knowledge.Additionally, it causes unnecessary delays in necessary operations, slowing down the implementation and performance process.Furthermore, concentrating authority on a single individual impedes the institution's growth and development.Furthermore, none of the five acts specify any qualification or appointment requirements for the director general, instead saying that the director general would be chosen on the terms and circumstances that the Federal/ Provincial Government determines.None of the five statutes set any criteria for the director general's eligibility or appointment.The acts simply stipulate that the director general would be chosen on terms and circumstances set by the federal/provincial governments.Furthermore, except for the post of Director General, they do not create any other office or position.They have no criterion for appointing additional workers; the statute merely stipulates that the federal government will select administrative, technical, and legal staff.This legal flaw has major consequences for institutional growth and the quality of persons nominated to key posts.
• A sustainable water pollution mitigation strategy involves public and industry education and awareness.The majority of Pakistanis are unaware that pollution is the main cause of freshwater scarcity in the future.It is difficult and expensive to restore the quality of freshwater after it has been polluted.Peoples are not aware of the causes of water pollution and its negative impact on human life and Pakistan's economy as well.The EPAs is responsible to promote public education and awareness regarding environmental issues through mass media and other means including seminars and workshops.However, the existing environmental pollution laws do not offer any mechanism for a successful public awareness campaign to educate the masses.According to an article titled "World Water Day goes Unnoticed in Pakistan" (published in The News International in 2022), World Water Day is being celebrated on March 22 across the world.A day dedicated to recognizing water pollution, highlighting the importance of freshwater, and focusing on issues related to access to clean water worldwide.However, in Pakistan, where there is a severe scarcity of water, this day, like other international days, goes unnoticed.Shezad and Siegmann (2006) observe that in Pakistan, many people are unaware of the connection between water and sanitation infrastructure and human health.World water awareness day is celebrated on March 22 every year in Pakistan.But little progress has been made in this area.Murtaza et al. (2010) examine that the freshwater resources for crop production activities are dwindling, while wastewater volumes from cities of Pakistan are rapidly increasing.Raising awareness among all segments of society, including the general public, business owners, and farmers is essential.Nabi et al. (2019) observe that water is free in Pakistan, so people have not paid any attention to its conservation.Water conservation requires public awareness in both print and electronic media.In this situation, it is difficult to encourage compliance with such a law.Environmental Impact assessment (EIA) will be submitted to the federal/provincial government to get approval if the project has negative effects on the environment.The EPAs has the right to accept the plan with or without conditions, to request that the EIA be resubmitted with revisions, or to eject the plan if it is incompatible with the environmental goals.It will conduct an EIA evaluation with public input before approval.No information will be shared at the person's request during a public engagement in trade, manufacturing, or business operations, processes, or procedures, as well as financial, commercial, scientific, or technological concerns.The agency will communicate for permission after submitting a first environmental investigation or environmental impact assessment.If the agency does not communicate within four months after submitting the initial environmental examination or environmental impact assessment, it will be presumed accepted, as long as it does not contradict the requirements of this act and the rules and regulations promulgated thereunder.
The federal/provincial government may prolong this four-month timeframe.The federal/provincial government will keep a separate register for the initial environmental evaluation and an environmental effect assessment plan.It will contain an overview of the project as well as brief explanations of the choices taken on it, and it will be available to the public under certain conditions.According to section 6 of PAK-EPA 1997, Punjab-EPA 2012, Sindh-EPA 2014, Khyber-Pakhtunkhwa-EPA 2014, Balochistan-EPA 2012, EPAs implement monitoring, measurement, examination, investigation, research, inspection, and auditing procedures to prevent and control pollution, and to estimate the costs of cleaning up pollution and rehabilitating the environment in various sectors.
The failure to comply with IEE and EIA regulations and EPAs directives is regarded as a severe violation, and the Environmental Tribunals have the authority to prosecute such cases and impose fines, as well as additional fines for each day that the violation persists under section 17 of PAK-EPA 1997, Punjab-EPA 2012, section 22 of Sindh-EPA 2014, section18 of Khyber-Pakhtunkhwa-EPA 2014, section 25 of Balochistan-EPA 2012.
• Initial Environmental Examination (IEE) and Environmental Impact Assessment (EIA) are useful for reducing water pollution caused by industrial effluents.In IEE and EIA existing practices are not being examined; reports are required only for new projects.The absence of coordination among the key agencies, namely EPAs and P&DDs, contributes to inadequate execution of the environmental assessment process at both the national and provincial levels.The EIA was first implemented in Pakistan in 1983.This procedure is ineffective, and the authorities responsible for its implementation have failed to do their part (Saeed et al., 2012) • All environmental protection laws have provisions regarding environmental tribunals in Pakistan.Now the question is whether these tribunals have been established or not.The government has established two environmental tribunals one in Karachi and one in Lahore.The Karachi Tribunal with the jurisdiction of the provinces of Sindh and Balochistan, whereas the Lahore Tribunal has authority over Punjab and KPK.These special courts are not established in any other part of the country.These tribunals and people living in Sindh and Punjab can easily approach these tribunals.But it is very difficult for the people of Balochistan and Khyber Pakhtunkhwa to reach them.Traveling from one province to another is extremely difficult for a litigant.Second, a litigant must bear the costs of travel.This attitude clearly shows that the government of Pakistan does not prioritize pollution control laws.At this point, another question arises whether the judges appointed to these tribunals are fully qualified to deal with the complex issue of pollution.The answer is no.The judges of these tribunals have no expertise in environmental pollution cases.They are simple law graduates, and the subject of environmental pollution control law is not taught as a compulsory subject at the graduate level.
• Ahsan and Khawaja (2013) explain that the lack of mechanisms for collecting evidence is an obstacle to the implementation of these laws.These tribunals are endowed with the power to accept and record extensive evidence.The Environmental Sample Rules of 2001 lay out the process for gathering evidence.The environmental tribunal can dismiss a suit for lack of evidence if the aggrieved or the EPAs fail to present evidence after being given a reasonable chance to do so.It should be highlighted that owing to a lack of knowledge and limited resources, the quality of evidence collected and other inspection methods are inadequate.A lack of evidence collecting is one of the key difficulties at the environmental tribunal level, preventing the tribunal from taking proper action.
• In Pakistan, these laws do not provide severe penalties for polluting the water bodies.For first-time offenders, the aforementioned penalties are insufficient and ineffective because they only provide for the imposition of fines, which are sometimes disproportionate to the violations committed, without assessing the actual damages and without requiring the accused to make appropriate environmental improvements.
• The legislative schemes of these Acts are such that most of their provisions can be implemented only by way of rules made and regulations made thereunder.According to the laws, EPAs have to establish pollution standards.They specify two kinds of standards: water ambient standards and NEQS.However, ambient water standards do not yet establish, and NEQS has restricted applicability.Without ambient standards, it is impossible to enhance or preserve quality only through NEQS.
• The EPA is responsible for implementation and prevention, as well as providing guidelines and information.But there is no complete data on violations, so the exact position of violations cannot be determined.No proper data is available regarding pollution cases decided by tribunals, and higher courts for the guidance of lawyers and judges as well as for public information.
• Khan (2015) examines that the water pollution issue is a cross-provincial nature that requires the cooperation of all provinces.However, these laws make no effective provision for such cooperation, which is crucial for the protection of water resources at the national level.
• The EPAs will recommend to incorporate environmental courses, topics, literature and books into curriculum and syllabus of educational institutions, is also responsible for collaboration with the education institutes.Ullah (2013) explain that there is a communication gap between HEC, EPAs, and universities, that causes difficulties in strategic decision-making with regard to environmental courses.They also explain that there is a lack of sustainable initiatives from EPA.The Ministry of Climate Change and EPAs should communicate and cooperate with Higher education institutions bearing the burden of sustainable development.These institutions can also represent sustainable initiatives of Pakistan at any international forum.However, the current position is not as strong as it needs to be.
• There is a lack of environmental pollution research as well as teaching facilities in Pakistan.
Pakistani universities have a limited teaching faculty to teach environmental pollution law.Environmental pollution law is not taught as a compulsory subject at the graduate level.Ahsan and Khawaja (2013) express that in Pakistan, three types of law programs are currently available.Environmental protection law is not a compulsory course in any of these three systems and is only offered as an optional subject.Environmental protection law courses are offered at the postgraduate level in a few universities.In the Law College of the University of Punjab, there is a postgraduate diploma in environmental laws (Punjab University Law College [PULC], 2022, Programs).
EPAs are responsible for enforcing the environmental laws and regulations, including ensuring compliance with environmental standards by industries and other entities.The EPAs receive an annual budget from the federal/provincial government for environmental compliance and enforcement, but these may vary from year to year based on government objectives and available funds.Azizullah et al. (2011) describes that Laboratories have been established in all provinces to monitor environmental quality, however they are not completely operational due to a lack of manpower and insufficient funding.The country has laws and a system to monitor pollution, but they are not being implemented.The main barriers to implementation are inadequate budgetary allocations and a lack of effective coordination and communication among competent authorities such as federal and provincial entities.Political involvement cannot be ruled out as a factor hindering the implementation of environmental regulations.
The EPA is responsible for reviewing environmental laws as well as preparing and publishing an annual National Environment Report on the state of the environment.According to World Wide Fund for Nature [WWF] Pakistan (2007) although The Government of Pakistan has approved ordinances, acts and policies from time to time but no clear strategy for their implementation has been formulated yet.Despite having the necessary administrative capabilities on paper, its effectiveness is severely limited in practise.For example, NEQS for industrial and municipal discharges were developed in 1993 but have not yet been implemented.Industries do not follow national pollution guidelines in their waste discharge.To control pollution caused by industrial waste, the government has implemented several programs such as pollution charge system, self-monitoring and reporting, cleaner production in industry, and common effluent treatment plants.However, due to ineffective law enforcement, no one is properly implemented, and the issues persist.

Conclusion
Water pollution is the result of the degradation of the water quality of rivers, lakes, streams, and groundwater.There are several causes of this, including untreated municipal, industrial, and agricultural wastes and effluents.Pakistan's existing water supply is not only scarce but also unpredictable.Pollution and climate change pose serious concerns to overall availability.On the other hand, water demand is increasing rapidly as a result of increasing population and urbanization.As a result of this imbalance, the country is suffering from a severe water shortage.Although Pakistan has a robust national and institutional framework, its implementation capability is rather low.Strong law enforcement and compliance are required to safeguard freshwater resources.Urgent actions and steps must be taken to protect the available water resources; otherwise, these waters will become drains.

Way forward
Some recommendations are made to improve performance.
• A national wide campaign/program should be initiated to raise awareness about the existing water situation in Pakistan and the importance of freshwater resources.This initiative should not be limited to developed areas only.Less developed areas should also be included.Public awareness campaigns should be commencing in schools, colleges, universities, different government departments, industries, and community levels.To teach people about their environmental rights and how to seek justice if these rights are infringed, awareness campaigns should be done across all channels, including electronic and print media, as well as social media.Most importantly, protection and awareness regarding water resources should be an important feature of the curriculum from primary school, especially in legal and technical institutions.Billboards with messages to protect water resources from pollution should be placed on highways, and pamphlets should be distributed to the masses.World water day on the 22 nd of March of every year should also be made part of this nationwide campaign/program.This day should be celebrated with enthusiasm in various cities and institutions.The program should be broad in scope and designed in such a way even a common man can understand well.
• The government should encourage the industrial sector to use modern methods and technologies for the treatment of wastewater and effluents.Fiscal incentives for industries to import components of treatment plants for individual industries or combined, in different areas of the country may be considered for this purpose.
• The government should disclose pollution reports and develop a moderate ranking system to provide incentives/rewards/tax exemptions to the concerned industrial undertakings based on legislative compliance.
• Water and Sanitation Agencies (WASAs), Environmental Protection Agencies (EPAs), and other relevant public sector entities should convene in a single platform to promote compliance coordination and collaboration through staff training and cooperative research.
• The Pak-EPA and other provincial environmental protection agencies should set industry-specific criteria rather than generic or universal requirements, taking into account the geographical and ecological condition of the area, where the industry is located.
• The water issue has a cross-provincial nature, which requires cooperation between the provinces.By amending the laws of each province and federal to introduce such cooperative provisions as are necessary for the protection of water resources of the country.
• By amending the laws, district environmental protection agencies should be established with the provincial agency empowered to transfer responsibilities to each district.
• Mobile laboratories should be introduced for testing, analysis, and monitoring of the quality of water.
• Because of the seriousness of pollution-related offenses, environmental tribunals should be set up at the divisional level at the earliest and on an emergency basis in Quetta, Balochistan, and Peshawar, KPK.mobile courts should also be established in remote areas.The cases must be decided by presiding officers who have knowledge and experience in environmental pollution issues.If there is a shortage of judges and lawyers with adequate knowledge of environmental pollution cases, law graduates and professionals can be appointed as presiding officers of these tribunals through legislative amendments.By amending the law, suo moto powers under the suo moto modus operandi can be conferred to the Tribunal to take notice, adjudicate, prosecute, or punish offenders/violators/defaulters.
• Penalties should be severe in case of violation by offenders/violators/defaulters.There is a need to introduce amendments that provide penalties that are proportionate to the violation.The judiciary's discretion in imposing fines in cases of infringement may be limited through amendments in laws.
• Develop provincial quality standards for industrial, commercial, and municipal wastewater.
• A separate environmental pollution police or force should be constituted with powers to register FIRs, conduct raids and arrest violators.If Pakistan takes steps to establish an environmental pollution police force, funds from developed countries can be provided to support this positive action.
• Capacity building of the judiciary, enforcement wing, prosecution wing, and supporting judicial staff of tribunals is essential for the proper implementation of laws in Pakistan.
• Complete data on violations should be organized monthly and should be available online for the general public.A journal containing cases decided by tribunals, and higher courts should be published monthly for the guidance of lawyers and judges as well as for public information.Institutional reports should be published monthly.
• For the proper implementation of the laws, the rules and regulations mentioned in the laws should be established as soon as possible.According to the needs rules and regulations may be made as well.The necessary amendments may be made according to the circumstances and needs of society.
• A compulsory course on Environmental Pollution Law should be included in the LLB syllabus.Both the Higher Education Commission of Pakistan and the Pakistan Bar Council can play a vital role in this regard.Universities may offer LL.M in Environmental Pollution Law.This will encourage research on complex problems of environmental pollution.Experts and professionals can be hired as faculty members in universities.Environmental pollution laws should be made a compulsory subject in Pakistani judicial academies for law officers.
• The ambient water quality standards should be established by the environmental protection agency and environmental council.
• A standardized computerized system should be developed to collect, maintain and use data related to compliance and implementation of laws and regulations by industries at the provincial and national levels.
• Speedy justice in pollution cases would not only help in the implementation of laws in Pakistan but would also increase public trust in the judicial system.ADR system can also be introduced for this purpose.The ADR process can be used to help pollution victims find a solution and improve the efficiency of the problem without going through lengthy formal litigation procedures.
• The federal and provincial governments should form a panel of environmental lawyers capable of initiating environmental pollution lawsuits in the public interest to seek guidance for the implementation/compliance of environmental pollution laws.
• Environmental protection councils and agencies should be introduced modern and relevant guidelines and legal frameworks to control water pollution.
• For this purpose, moral and religious awareness is necessary.Faith-based organizations can play a vital role in addressing the problem of water pollution at regional and local levels so that the general public considers the conservation of natural resources as an integral part of religious faith.
• Environmental courses should be introduced at the school level so that through the process of environmental education in schools, children can learn about environmental problems, solve them and take steps to protect the environment at an early age.
• If there is good governance and law and order in the country, natural water resources can be protected from pollution for present and future generations.
Furthermore, a number of water policies and guidelines have been established by the Pakistan government.In November national standards for drinking water quality were introduced in 2002.Similarly other policies including National Environment Policy 2005, National Sanitation Policy 2006 and National Drinking Water Policy 2009 have been approved.The National Environment Policy 2005, provides a framework for various environmental issues, particularly pollution of fresh water bodies.It recognizes the need to meet international obligations effectively and in accordance with national objectives and public health and environmental concerns.In addressing water supply and management, it lays down a number of guidelines that the government can follow to ensuring sustainable access to safe water resources.The main objective of the National Drinking Water Policy 2009 is to provide clean drinking water to the entire Pakistani population by 2025, including both urban and rural areas, at an affordable cost (MOE-PAK, 2005; 2009; 2006).The Ministry of Water Resources announced the National Water Policy in April 2018 to address water resource management concerns in Pakistan and anticipated important targets to be met by 2030.It emphasised more sustainable water resource utilisation and promoted the concept of "producing more crop per drop" (National Water Policy of Pakistan, 2018).

Table 5 . Total wastewater generation and collection in large cities in Pakistan
Other general laws in Pakistan relating to the prohibition of Water Pollution are Pakistan Penal Code, 1860 section 268 Water Pollution Nuisance, 277 levies fine and imprisonment for fouling (Alam, 2016)to the International Union for Conservation ofNature (2005), the issue of water pollution falls underPakistan Environmental  Protection Act (1997).Section 11 of PEPA, (1997) describes that no one shall have the right to discharge the effluents or release any waste and pollutant that exceeds the national Environmental quality standards.If a person does not comply with the national environmental quality standards will impose pollution charges on a person by the federal government.At the provincial level, The Punjab Environment Protection (Amendment) Act (2012), Balochistan Environmental Protection Act (2012), KPK Environmental Protection Act (2014), and Sindh Environmental Protection Act (2014) prohibit the discharge of domestic or industrial effluents above provincial environmental quality standard.Each province has its environmental protection agency in charge of pollution control(Alam, 2016).

Table 6 . Sector wise estimated wastewater production in Pakistan
Source: Pakistan's Wetlands Action Plan, 2000, prepared by NNCW and WWF.

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Environmental Impact Assessment (EIA) and Initial Environmental Assessment (IEE) are conducted in Pakistan for various projects including industrial and infrastructure development.The submission of EIAs and its approval from EPAs and federal/provincial government is mandatory for any new projects that have the potential to have a negative impact on the environment.According to section 12 of PAK-EPA 1997, section 12 of Punjab-EPA 2012, section 17 of Sindh-EPA 2014, section 13 of Khyber-Pakhtunkhwa-EPA 2014, section 15 of Balochistan-EPA 2012, no one shall commence or operate the project until the EPAs conducts an initial Initial Environmental Examination (IEE).An