Gujarat's regulator upholds a penalty on a cold storage unit for running 9.95 kW of rooftop solar above its sanctioned 50 kW

The Gujarat Electricity Regulatory Commission has dismissed a challenge by M/s Tulsi Cold, an MSME cold storage unit in Mahuva, Bhavnagar, against a penalty imposed by Paschim Gujarat Vij Company Limited (PGVCL) for running rooftop solar above its approved capacity. The order in Petition No. 2565 of 2025 is dated 18 September 2026, and the bench was Chairman Pankaj Joshi with members Hiren Shah and Jatin N. Thakkar.

The unit has a contract demand of 99 kW and an interconnection agreement approving 50 kW AC of rooftop solar. PGVCL found it operating 59.95 kW, a 50 kW inverter plus a 10 kW inverter, and treated the 9.95 kW excess as unauthorised use under Regulation 16.2 of the GERC Net Metering Regulations. The utility issued a 24-hour disconnection notice in March 2026 and a penalty of 4,32,729.17 rupees, later revised to 1,40,110 rupees using a methodology taken from an Ombudsman order, which the consumer paid under protest (https://solarquarter.com/2026/09/21/gerc-upholds-penalty-for-unauthorized-rooftop-solar-capacity-beyond-50-kw-limit/).

Two findings carry beyond this consumer.

First, the Commission held that when the additional inverter was installed does not matter. Operating above the approved AC capacity is unauthorised use regardless of timing, which forecloses the argument that equipment predating the interconnection agreement is somehow outside it.

Second, and more consequential, it held that an approval from the Chief Electrical Inspector goes to the safety and compliance of the electrical installation, and does not amount to approval of generation capacity by GEDA or by the distribution licensee. A consumer who reads a CEI clearance as permission to generate has misread it. That is an easy mistake to make: a state electrical inspector has examined the installation and signed it off, and the intuition that this means the installation is allowed is not an unreasonable one. The Commission has now said plainly that it does not.

This is what the rooftop solar cap looks like at the point of enforcement. India's national conversation about distributed solar runs on installation targets, subsidy disbursement and scheme announcements. The operative constraint on a commercial consumer is none of those. It is a number written into an interconnection agreement, policed by the DISCOM, and enforceable by a 24-hour disconnection notice. A consumer with 99 kW of contracted demand may not self-generate beyond 50 kW without a fresh sanction, even where the additional capacity sits behind its own meter and serves its own cold storage load.

Whether 50 kW is the right number is a separate argument from whether it is being enforced. It is being enforced, against an MSME, with a disconnection notice, and the regulator has backed the licensee.

[UNVERIFIED] The GERC order itself could not be retrieved during this sweep: gercin.org failed TLS certificate verification. Every figure above rests on trade press readings of the order, corroborated in part by a second summary that cites Regulations 16.2 and 16.3 and reproduces the Commission's reasoning on the Chief Electrical Inspector. The petition number, order date, bench composition and both penalty figures should be checked against the Commission's own PDF before this publishes.