The application, filed before a bench headed by NGT Chairperson Justice Swatanter Kumar, sought exemption of women drivers from the scheme, saying it may affect the safety and security of women.
It sought that the exemptions be allowed for one year till the government procured 2,000 buses for public transport to tackle lakhs of commuters.
"The implementation of the scheme will cause great hardship to two-wheeler owners. This may affect the safety and security of women drivers also," the application, which is likely to be heard tomorrow, said.
"The crowding in public transport buses may deter the women passengers in using the bus mode because of safety and security reasons and therefore, the purpose of the Scheme will be defeated," it said.
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It sought exemption for two wheeler and women drivers from the odd-even scheme for a period of one year or till 2,000 more buses are engaged, it said.
The NGT had on November 11 given a conditional nod to the AAP government's decision to implement the odd-even scheme for five days from November 13, ordering that no exemption should be allowed to "any person or officer and two-wheelers".
The NGT had in its order said the odd-even scheme should be implemented "without any default" as and when PM (particulate matter) 10 level goes above 500 microgrammes per cubic metre and PM 2.5 level crosses the limit of 300 microgrammes per cubic metre during a span of 48 hours.
The national capital region has been experiencing dense smog for about a week, forcing the authorities to enforce emergency measures such as banning construction activities and brick kilns.
"Movement of trucks and construction works are under scrutiny, water is being sprinkled, we are continuously monitoring the situation," Rai told a press conference, adding "there is a meeting with Pawan Hans officials to discuss the plan of aerial sprinkling of water".
The Minister, who holds the transport portfolio along with several others, also hit out at the Haryana government for "playing blame game on stubble burning instead of taking action in his own state".
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