Council on Energy, Environment and Water Integrated | International | Independent
Suggested Citation: Tyagi, Niharika and Om Prakash Singh. 2026. Whose Air? Assessing Equity in India’s Air Quality Policies. New Delhi: Council on Energy, Environment and Water.
India faces some of the highest levels of air pollution globally: 14 of the world's 20 most polluted cities are in India, and 99.9 per cent of the country's population lives in areas where air quality falls below World Health Organization (WHO) standards. In 2019 alone, air pollution was linked to roughly 1.6 million premature deaths and USD 95 billion in economic losses, equivalent to 3 per cent of India's GDP. In response, the government has introduced several air quality management programmes in past years, including the National Clean Air Programme (NCAP), launched in 2019, and the Graded Response Action Plan (GRAP), which targets the National Capital Region. Despite substantial funding, these initiatives have delivered mixed results and have paid limited attention to the unequal impacts of air pollution on marginalised and vulnerable groups, including women, children, the elderly, indigenous communities, low-income households, and people with disabilities.
This report presents a systematic Gender Equity and Social Inclusion (GESI) analysis of 19 Indian air quality policies, spanning five sectors: energy access and power generation, low-emission transport, waste management, air quality management, and air pollution and health. The study examines whether these policies acknowledge and substantively address gender-differentiated impacts and the needs of socially excluded groups, as well as how they define vulnerability to air pollution.
The analysis classifies selected policies as GESI-blind, GESI-aware, or GESI-responsive. It also examines the specific drivers of vulnerability- socioeconomic status, occupational exposure, age, and disability; that leave some groups more exposed and less safeguarded than others. Based on these findings, the report identifies gaps in India's air quality governance and offers a set of targeted recommendations to build more inclusive and equitable policy options.
The State of Global Air 2025 report estimates that approximately 143,000 deaths among children under five in India in 2023 were attributable to air pollution, which translates to more than one death every five minutes. India faces one of the most severe air pollution crises globally, with millions suffering each year from its adverse health and environmental impacts (Jiang 2023). In response, the Government of India has implemented air quality management programmes and policies aimed at mitigating pollution, reducing exposure, and improving public health. For instance, the National Clean Air Programme (NCAP), launched in 2019, is a five-year initiative that has set ambitious targets for India’s most polluted cities, while the Graded Response Action Plan (GRAP), 2023 specifically addresses the National Capital Region. Despite receiving substantial funding, these programmes have had mixed results. These initiatives overlook a critical dimension – the disproportionate impact on marginalised and vulnerable groups, including women, the elderly, children, indigenous communities, low-income households, and the differently abled. Economic and social inequities, along with gender and cultural dynamics, exacerbate the vulnerability of these groups to the health impacts of air pollution (Kumar et al. 2023). Addressing the crisis requires solutions that extend beyond introducing regulations and technological fixes and instead embrace a more inclusive approach that integrates the lens of gender equity and social inclusion (GESI) into air quality management policies and practices.
Recognising this need, we systematically evaluate Indian air quality management policies’ compliance with GESI norms. Through a set of selection criteria, 19 policies across five key sectors were identified: energy access and power generation, low-emission transport, waste management, air quality management, and air pollution and health. While the primary focus was on policies formulated from 2010 to 2024, critical policies from before 2010 are also considered if they are still applicable (e.g., The Air (Prevention and Control of Pollution) Act, 1981, and Guidelines for Ambient Air Quality Monitoring, 2003). Erstwhile policies are excluded from the review.
Our analysis underscores gender-differentiated access to resources and healthcare, emphasising how socioeconomic status, traditional gender roles, and biological differences, particularly in relation to reproductive health, shape the varied impacts of air pollution across different genders.
For example, evidence shows that expectant mothers are especially vulnerable to the adverse effects of air pollution, which can increase the likelihood of negative birth outcomes. Yet, only one was found out of the selected policies (National Programme on Climate Change and Human Health) substantively acknowledging and addressing this specific vulnerability. Moreover, many policies fail to account for age and socioeconomic disparities, leaving some vulnerable groups under-protected. A notable gap is the limited consideration of individuals with disabilities, who face compounded challenges due to both physical barriers and the lack of policy attention. This analysis reveals a significant gender bias and social exclusion in the current policy landscape, emphasizing the need for a GESI-integrated approach. By employing an intersectional framework, we identify key drivers of marginalisation – including factors such as socioeconomic status, geographic location, and political powerlessness – that drive vulnerability to the impacts of air pollution. As a result, we present a more informed and nuanced understanding of how these compounded vulnerabilities amplify the effects of air pollution on marginalised communities.
The selected policies have been analysed for their GESI-responsiveness, focusing on whether they acknowledge and substantively address both gender equity and social inclusion, and how they define and assess vulnerability to air pollution. A GESI-responsive policy explicitly acknowledges and addresses GESI concerns by recognising the differentiated impacts of air pollution on various genders and socioeconomic groups and integrating measures to address them. This includes implementing targeted measures such as prioritising healthcare access for women and children, ensuring equitable distribution of resources and benefits, incorporating gender-sensitive language and perspectives, and actively engaging marginalised communities, including those with disabilities, in decision-making and policy-implementation processes. Using the methodologies of content and discourse analyses, along with tools like NVivo 14, we critically examine the language and context of these policies and the impact these entail on ground.
Figure 1 Highlights of the air quality management policy analysis, highlighting the degree to which they factor in gender equity and social inclusion
Our analysis emphasises the need to integrate gender equity and social inclusivity into air pollution regulations to mitigate health disparities and achieve equitable outcomes. Implementing GESI-responsive policies can ensure a smooth transition to a net-zero-inclusive and equitable future, leaving no one behind.
To enhance the GESI-responsiveness of policies addressing air pollution in India, CEEW recommends the following:
GESI-responsive policies and programmes hold the key to formulating transformative solutions. Policies have the potential to push gender-responsive climate action that addresses both environmental and societal concerns and can contribute to the realisation of India’s National Determined Contributions (NDCs) and NCAP goals.
GESI is a framework for evaluating whether policies recognise that people experience the impacts of air pollution differently depending on their gender, age, disability status, occupation, and socioeconomic position. Research shows that women, children, the elderly, low-income households, and people with disabilities are disproportionately exposed to air pollution's health effects, often due to how they cook, work, travel, and access healthcare. A policy that is GESI-blind risks channeling resources and protections toward those already better positioned to access them, while leaving the most vulnerable groups underserved.
The study identified policies through targeted keyword searches (for example, "air quality and policy" and "gender equity or social inclusion and air pollution regulation") across the FAOLEX and ECOLEX databases and nodal ministry websites. It focused on guidelines, regulations, acts, and schemes formulated from 2010-2024, while also including few older but still-applicable policies, such as The Air (Prevention and Control of Pollution) Act, 1981. The resulting 19 policies span five sectors: energy access and power generation, low-emission transport, waste management, air quality management, and air pollution and health. Each policy was analysed using content and discourse analysis, supported by NVivo 14 software, to assess how - and how substantively -it engages with gender equity, social inclusion, and vulnerability.
These are the three categories used to classify each policy's engagement with gender equity and social inclusion. GESI-blind policies do not consider gender or social inclusion at all and may inadvertently reinforce existing inequalities. GESI-aware policies recognise that different groups have different needs but stop short of actively addressing them within the policy design. GESI-responsive policies go furthest: they actively target gender and social inequalities through specific interventions, such as prioritising healthcare access for women and children or engaging marginalised communities in decision-making. A related category, social-equity-targeted, describes policies that address the needs of specific social groups without engaging with gender concerns.
Only two of the 19 policies- the Pradhan Mantri Ujjwala Yojana (PMUY) and the National Programme on Climate Change and Human Health (NPCCHH)- were classified as GESI-responsive. Both explicitly address the health risks of traditional cooking fuels and identify specific vulnerable populations, such as pregnant women and children under five. At the other end, seven policies were found to be entirely GESI-blind, including the National Ambient Air Quality Standards, The Air (Prevention and Control of Pollution) Act, the Commission for Air Quality Management Act, the FAME-2 electric vehicle scheme, and the Environment (Protection) Amendment Rules, 2015 governing thermal power plant emissions.
The UN Convention on the Rights of Persons with Disabilities (UNCRPD) describes persons with disabilities as people with long term physical, mental, intellectual or sensory impairments which, in interactions with various barriers, may hinder their full and effective participation on an equal basis with others. In our analysis, disability-related vulnerabilities were mentioned in just five times across all 19 policies analysed- the lowest of any vulnerability dimension studied, compared with nine instances for age-related vulnerabilities and eight for socioeconomic/occupational vulnerabilities. Only the National Programme on Climate Change and Human Health (NPCCHH) substantively addresses disability, through a checklist developed in collaboration with the WHO that helps healthcare facilities assess their readiness to serve people with disabilities, including asking whether facilities have separate, functional toilets for Divyang (differently-abled) users. This near-total silence means people with disabilities face compounded barriers, both physical and structural, that current policy is not designed to address.
Yes. The analysis found a sharp sectoral divide: all policies in the low-emission transport and waste management sectors were found to be gender-blind, failing to incorporate any gender equity considerations. This stands in contrast to the air pollution and health sector, where three NPCCHH sub-policies were rated GESI-responsive. This suggests that GESI considerations are currently treated as relevant mainly to health-focused policy, rather than integrated across the full range of sectors that shape air quality outcomes.
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