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.