On 18 October 2000, a three-judge Bench of Chief Justice Dr A.S. Anand, Justice S.P. Bharucha and Justice B.N. Kirpal — by a 2:1 majority — allowed the construction of the Sardar Sarovar Dam to continue, subject to the condition that the dam height be raised in 5-metre slabs only after the Relief and Rehabilitation Sub-Group of the Narmada Control Authority certified that R&R for displaced families had been carried out pari passu with construction. The majority articulated a doctrine of narrow judicial review in major-project PILs, held the Narmada Water Disputes Tribunal Award binding, and treated sustainable development as a balancing exercise. Justice Bharucha dissented. A digest of the holding, the bench's reasoning, the dissent treated as the moral compass of environmental PILs, and the subsequent doctrinal arc.