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.
On 28 August 1996, a three-judge Bench led by Justice Kuldip Singh held that 'sustainable development', the 'precautionary principle' and the 'polluter pays' principle are part of the law of the land — and ordered the discharge of pollution fees by tanneries in Tamil Nadu that had contaminated the River Palar and rendered 35,000 hectares of agricultural land unfit for cultivation. The judgment, together with *M.C. Mehta (Oleum Gas Leak)*, supplies the foundational architecture of Indian environmental law. A digest of the doctrines, the directions, and what they require.