On 6 July 2011, a three-judge Bench of Chief Justice S.H. Kapadia, Justice Aftab Alam and Justice K.S. Panicker Radhakrishnan — within the T.N. Godavarman writ — dismissed the Shella Action Committee's challenge and upheld the revised environmental clearance, site clearance and Stage-I forest clearance granted to Lafarge for its limestone mine at Nongtrai, East Khasi Hills, Meghalaya. Part II of the judgment used the occasion to issue forward-looking guidelines under section 3(3) of the Environment (Protection) Act, 1986 — directing the appointment of a National Regulator, the expansion of Regional Offices, the constitution of Regional Empowered Committees, GIS-based decision-support databases, the sequencing of forest clearance before environmental clearance, and mandatory public hearing. A digest of the doctrinal architecture, the doctrine of proportionality, the anti-'fait accompli' principle, and the implementation record fifteen years on.
On 12 December 1996, a two-judge Bench of Justice J.S. Verma and Justice B.N. Kirpal in W.P.(C) 202/1995 held that the word 'forest' in the Forest (Conservation) Act, 1980 must be understood according to its dictionary meaning, irrespective of ownership or classification. The order constituted State Expert Committees, imposed felling moratoriums in the Northeast, J&K and other hill regions, protected workers in closed saw mills, and — through the formula 'this order is to continue, until further orders' — inaugurated what has become the longest-running environmental public interest litigation in Indian history. A digest of the foundational order, the 'deemed forest' doctrine, the subsequent architecture (CEC came in 2002, not 1996), and the doctrine's continuing engagement through 2026.