Introduction

Public Interest litigation, itself says that this is a litigation for any public interest. In the words
of some learned people we can say that public interest litigation is a litigation which can be file
in any court of law by any public-spirited person for the protection of “public interest.” Now a
question comes in the mind that “what in public interest?” so answer is ‘any act for the benefit
of public is public interest.’ and those acts are such as pollution, Terrorism, Road safety,
constructional hazards etc. in all these activities we can clearly see the public interest. As it is
said that this petition can file by any public-spirited person so its mean that there should not be
interest of only himself.

Public interest litigation is not defined in any statute or any act. It has been interpreted by judge
to consider the intent of public at large. This is just like a writ petition which is file in high
court or supreme court under article 226 for high court and article 32 for supreme court. When
public interest in affecting at large then this can be filed but affection on only one person is not
a ground for filing this petition. There is some various area where a public interest litigation
can be filed.

• Violation of basic human rights of the poor.

• Content or conduct of government policy.
• Compel municipal authorities to perform a public duty.
• Violation of religious rights or other basic fundamental rights.

These are the main area where any public interest litigation can be filed against State/Central
Govt., Municipal Authorities, and not any private party. However private party can be included
in this as a respondent after making concern state authority. This petition is filed in high court
or supreme court just a same manner as other writ petition filed. There is some fee for this
purpose and its hearing proceeds is also just like other cases. In early 90’s a judge had treated
a complaining post card as public interest litigation so we can say that latter also may be treated
as writ of public interest litigation some other case are also there which we will discuss in this
project. There are various kind of remedies also there to secure the public interest as INTERIM
MEASURES, APPOINTING A COMMITTEE, FINAL ORDERS.

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In India the first case of PIL was filed in 1976 named ‘Majdur kaamgar sabha v Abdul bhai
Faizulla bhai’ [1]. Where Krishna Iyar allowed a group of people to file petition on behalf of
others. The rights of the member were violated Krishna Iyar held either one individual or group
of individuals together can come to the court. But some time misuse of this petition also comes
into picture. This is the problem in PIL that many times this misused by some people. There
are various cases in which PIL is misused as ‘S.P. Gupta v union of India’[2], In this case
misuse of PIL was came into picture. And the secondly in the case of ‘Shushes Kumar v Union
of India’. in this case there was a manager in a company and his boss faired him and he gave
a PIL in spite of not being any ground of PIL.

WHEN CAN A PIL BE FILED?

Public interest litigation can be filed only in that case where any “public interest” is affecting
at large. Because if only one person is affecting then that is not a ground for filing PIL. In this

Project we are giving some area or authorities where any public-spirited person can file PIL-

These are some of the possible areas where a PUBLIC INTEREST LITIGATION can be filed.

• Where a factory / industrial unit is causing air pollution, and people nearly are getting
effected.
• Where, in an area / street there are no street lights, causing inconvenience to commuters
• Where some “Banquet Hall” plays a loud music, in night causing noise pollution.
• Where some construction company is cutting down trees, causing environmental
pollution.
• Where poor people, are affected, because of state government’s arbitrary decision to
impose heavy “tax”.
• For directing the police / Jail authorities to take appropriate decisions in regards to jail
reforms, such as segregation of convicts, delay in trial, production of under trial before
the court on remand dates.
• For abolishing child labour, and bonded labour.
• Where rights of working women are affected by sexual harassment.
• For keeping a check on corruption and crime involving holders of high political officer.

1
(1976) 3 SCC 832
2
AIR 1982 SC 149

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 • For maintaining Roads, Sewer etc in good conditions.
• For removal of Big Hoarding and signboard from the busy road to avoid traffic problem.
• Recently, a PUBLIC INTEREST LITIGATION has been filed, for directing the
construction of Metro rail car-shed at Aarey, the Mumbai Metro Rail Corporation
Limited (MMRCL) not to the chopping of trees in the area.

So, these are the various area in which any public-spirited person can file any PIL for the
interest of public. As first point is talking about factory / industrial unit of the state. As per in
this point we want to focus that if any factory is producing any air pollution and public is
affecting by that then any person can file a PIL on the behalf of the that public group or
particular area. Secondly where is no street light and it should be must at that place cause of
meeting accident regularly. Hence there are many grounds when it can be filed.

As In the first PIL on prisoner’s rights ‘Hussainara Khatoon v State of Bihar’ [3], the attention
of the court was to the incredible situation of Bihar under trials who had been detained pending
trial for periods far excess of the maximum sentence for the offence they were charged with.

WHERE CAN A PIL BE FILED?

Now a chief question comes in the mind that where should a public-spirited person file this
petition to take remedy by this. So, the answer of this chief question is this that all PIL are used
to filed in high court or Supreme Court. If a person wants to go to high court to filing that then
he can go under article 226 of Indian constitutional law and if any person wants to go to
supreme court then he can go under article 32 of the Indian constitutional law but Article 226
is something distinguished from article 32 of constitutional law. Under article 32 that person
can go to supreme court whose only fundamental rights are violation nothing else but if any
person going through the violation of not only fundamental right but also constitutional right
and any other legal right also or secondly we can see by this view that It will purely and solely
depend on the “Nature of the case”, if the question involves only a small group of people being
effected by action of State authority, the PUBLIC INTEREST LITIGATION can be filed in
high court. For e.g. if there is a sewage problem in a locality effecting 50 families, the PUBLIC
INTEREST LITIGATION can be filed in High court. If a large section of people is affected
whether by State Government or Central Government, PUBLIC INTEREST LITIGATION can

3
1979 AIR 1369, 1979 SCR (3) 532

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be filed in Supreme Court For e.g. placing a ban on adult movies, prohibition industrial unit
from causing pollution etc. So, we can say that both of the court have power to entertain the
public interest litigation.

WHO CAN FILE A PIL?

As we already said that any public-spirited person even a foreigner can file a PIL on behalf of
others but this is necessary that only the person who is filing a PIL should not get benefit.
Meaning there by any PIL whoever is filing should be only and only in for the benefit of people.
If only one person is getting affected by any act then that is not a ground of filing PIL. Although
earlier only the person whose interest is directly along with others can use such litigation. So,
these are the essential point for that person who can file any public interest litigation.

• He is a member of the public acting bona fide and having sufficient interest in instituting
an action for redressal of public wrong or public injury.
• He is not a mere busy body or a meddlesome interloper.
• His action is not motivated by personal gain or any other oblique consideration.

As we can see that in the society there are some person who come in the picture for the same
behave as M.C. MEHTA, MACHILIPATNAM, Lankisetti Balaji are in the lime light in this
domain. There is a case named ‘M.C. Mehta V Union of India’ [4], in this case Shriram Food
and Fertilizers Industry a subsidiary of Delhi Cloth Mills Limited was producing caustic and
chlorine. On December 4th and 6th 1985, a major leakage of oleum gas took place from one of
the units of Shriram Food and Fertilizers Limited in the heart of the capital city of Delhi which
resulted in the death of several persons that one advocate practicing in the Trees Hazari Courts
died.

The leakage was caused by a series of mechanical and human errors. This leakage resulted
from the bursting of the tank containing oleum gas as a result of the collapse of the structure
on which it was mounted and it created a scare amongst the people residing in that area. Hardly
had the people got out of the shock of this disaster when, within two days, another leakage,
though this time a minor one took place as a result of escape of oleum gas from the joints of a
pipe.

4
1987 SCR (1) 819

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Shriram Foods and Fertilizer Industries had several units engaged in the manufacture of caustic
soda, chlorine, hydrochloric acid, stable bleaching powder, super phosphate, Vanaspati, soap,
sulphuric acid, alum anhydrous sodium sulphate, high test hypochlorite and active earth. All
units were set up in a single complex situated in approximately 76 acres and they are
surrounded by thickly populated colonies such as Punjabi Bagh, West Patel Nagar, Karmapa,
Ashok Vihar, Tri Nagar and Shastri Nagar and within a radius of 3 kilometres from this
complex there is population of approximately 2, 00,000.

On 6th December, 1985 by the District Magistrate, Delhi under Section 133(1) of Cr.P.C,
directed Shriram that within two days Shriram should cease carrying on the occupation of
manufacturing and processing hazardous and lethal chemicals and gases including chlorine,
oleum, super-chlorine, phosphate, etc at their establishment in Delhi and within 7 days to
remove such chemicals and gases from Delhi. At this juncture M.C. Mehta moved to the
Supreme Court to claim compensation by filing a PIL for the losses caused and pleaded that
the closed establishment should not be allowed to restart. So, this was one of the cases of PIL.

Indian council for ‘Enviro-legal action v union of India’ [5], chemical industry was causing
problem of pollution, affecting right to life, NGO filed petition on behalf of the aggrieved
people.

AGAINST WHOM CAN A PIL BE FILED?

A Public Interest Litigation can be filed against a State/ Central Govt., Municipal Authorities,
and not any private party. The definition of State is the same as given under Article 12 of the
Constitution and this includes the Governmental and Parliament of India and the Government
and the Legislature of each of the States and all local or other authorities within the territory of
India or under the control of the Government of India. According to Art.12, the term State
includes the Government and Parliament of India and the Government and the Legislatures of
each of the States and all local or other authorities within the territory of India or under the
control of the government of India.

Thus, the authorities and instrumentalities specified under Art.12 are –

• The Government and Parliament of India

5
1996 AIR 1446

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 • The Government and Legislature of each of the States
• All local authorities
• Other authorities within the territory of India or under the Government of India.

In ‘Electricity Board, Rajasthan v Mohan Lal’ [6]

, the Supreme Court held that other
authorities would include all authorities created by the Constitution of India or Statute on whom
powers are conferred by Law.

However, Private party can be included in the PIL as Respondent, after making concerned state
authority, a party. For example- if there is a Private factory in Delhi, which is causing pollution,
then people living nearly, or any other person can file a PIL against the Government of Delhi,
Pollution Control Board, and against the private factory. However, a PIL cannot be filed against
the Private party alone.

PROCEDURE TO FILING A PIL

Procedure to file a public interest litigation is just like a filing a general writ in high court or
supreme court.

(A) FILING

In High Court

If a PUBLIC INTEREST LITIGATION is filed in a High court, then two (2) copies of the
petition have to be filed. Also, an advance copy of the petition has to be served on each
respondent, i.e. opposite party, and this proof of service has to be affixed on the petition.

In Supreme Court

If a PUBLIC INTEREST LITIGATION is filed in the Supreme court, then (4) +(1) (i.e. 5) sets
of petition has to be filed, opposite party is served the copy only when notice is issued.

6
AIR 1967 SC 1857

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(B) Procedure

A Court fee of RS. 50, per respondent (i.e. for each number of opposite parties, court fees of
RS. 50) has to be affixed on the petition. Proceedings, in the PIL commence and carry on in
the same manner, as other cases. However, in between the proceedings if the Judge feels that
he may appoint the commissioner, to inspect allegations like pollution being caused, trees being
cut, sewer problems, etc. After filing of replies, by opposite party, or rejoinder by the petitioner,
final hearing takes place, and the judge gives his final decision.

1. Proceedings, in the PUBLIC INTEREST LITIGATION commence and carry on in the

same manner, as other cases.
2. However, in between the proceedings if the judge feels he may appoint a commissioner,
to inspect allegations like pollution being caused, trees being cut, sewer problems, etc.
3. After filing of replies, by opposite party, and rejoinder by the petitioner, final hearing
takes place, and the judge gives his final decision.

A LETTER CAN ALSO BE TREATED AS PIL

In early 90’s there have been instances, where judges have treated a post card containing facts,
as a PUBLIC INTEREST LITIGATION.

some of them are:

1. Letter alleging the illegal limestone quarrying which devastated the fragile environment
in the Himalayan foothills around Mussoorie, was treated as a PUBLIC INTEREST
LITIGATION
2. A journalist complained to the Supreme Court in a letter, that the national coastline was
being sullied by unplanned development which violated the central government
directive was treated as a PUBLIC INTEREST LITIGATION

In a landmark judgment, in ‘D.K. Basu v State of West Bengal’ [7], the court acted upon a letter
petition which drew attention to the repeated instances of custodial deaths in West Bengal. The
court further mandated that a relative of the arrested must be promptly notified. It made clear
that the failure to comply with this direction would be punishable as contempt of court. The

7
1991 (1) SCC 416

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early PILs had witnessed the award of compensation by the court to victims of human rights
violations.

In the case of ‘Upendra bakshi v Union of India’ a letter highlighting the pathetic condition
of the young offenders was sent to S.C judge which was taken into consideration.

RELIEFS AVAILABLE BY PIL

By such a petition many kinds of relief are available here to secure the public interest at large.
That relief is-

INTERIM MEASURES

The court can afford an early interim measure to protect the public interest till the final order
for example:

1. Release of under trial on personal bonds ordering release of all under trial who have
been imprisoned for longer time, than the punishment period, free legal aid to the
prisoners, imposing an affirmative duty on magistrates to inform under trial prisoners
of their right to bail and legal aid.
2. Closure of Industrial plant emitting poisonous gas, setting up victim compensation
scheme, ordering the plaint reopening subject to extensive directions etc.
3. Prohibiting cutting of trees or making provisions for discharge of sewage, till the
disposal of final petition.

Relief in most of the PUBLIC INTEREST LITIGATION cases in the Supreme Court is
obtained through interim orders.

APPOINTING A COMMITTEE

1. The court may appoint a committee, or commissioner to look into the matter, and
submit its report.
2. Such committee or commissioner may also be given power to take cognizance of
grievances and settle it right in the public intent.

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FINAL ORDERS

The court may also give final orders by way of direction to comply within a stipulated time.
An order or judgment of the Court that finally disposes of the rights of the parties.

CAN A WRIT PETITON BE TREATED AS A PIL?

Yes, a writ petition filed by the aggrieved person, whether on behalf of group or together with
group can be treated as a PUBLIC INTEREST LITIGATION however,

1. The writ petition should involve a question, which affects public at large or group of
people, and not a single individual.
2. Only the effected/Aggrieved person can file a writ petition.

There should be a specific prayer, asking the court to direct the state Authorities to take note
of the complaint/allegation.

MISUSE OF PIL

In the last few years, there have been serious concerns about the use and misuse of public
interest litigations and these concerns have been expressed at various levels. The time has come
for a serious re-examination of the misuse of public interest litigation. There are numerous
cases in the history of law where PIL has been misused.

As in the case of ‘Shubhash Kumar v state of Bihar’ [8], In this case there was a prole who was
fired by the director of the company so he filed a PIL that this company is acting something
wrong so this should be tried. So, in this case by the fact of the case we can see that this is
purely misuse of PIL nothing else.

In the case of ‘Sheela Barse v State of Maharashtra’ [9], In this case, on receiving a letter from
the petitioner, a journalist, the Supreme Court took notice of the complaint of custodial violence
to women prisoners in the lock-up in the city of Bombay. The court issued various directions
which included the following: “Four or five police lock-ups should be selected in reasonably

8
1991 (1) SCC 598
9
1983 AIR 378, 1983 SCR (2) 337

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good localities where only female suspects should be kept and they should be guarded by
female constables”. This misuse comes in various forms.

In the case of ‘Ashok Kumar Pandey v State of W.B.’, Described as “busybodies, meddlesome
interlopers, wayfarers or officious interveners who approach the court with extraneous
motivation or for glare of publicity”. Such litigation is described as “publicity interest
litigation” and the courts have been fraught with such litigation. How else would one describe
a public interest litigation filed for “reliefs” such as that the higher judiciary would be provided
with private planes and special transport? A petition to this effect was filed by a lawyer
practicing in U.P. As could be expected, it was summarily rejected, but not before the
gentleman had his day in the sun, however momentary it was. Examples of this kind of
litigation are innumerable. No sooner has an event of public interest or concern occurred than
there is a race to convert the issue into a PIL.

Questioning the High Courts on the misuse of the PIL, the Bench said “PIL is a weapon which
has to be used with great care and circumspection and the judiciary has to be extremely careful
to see that behind the beautiful veil of public interest an ugly private malice is there”. The
Bench made it clear that a PIL should be aimed at redressal of genuine public wrong or public
injury and not publicity oriented or founded on personal vendetta. It observed that it should not
be allowed to become “publicity interest litigation or private interest litigation or politics
interest litigation or, the latest trend, praise income litigation. The laudable concept of PIL was
for extending the long arm of sympathy to the poor, ignorant and oppressed”, the Bench said
and added the “brand name” should not be allowed to be used by imposters and meddlesome
interlopers impersonating as public-spirited holy men.

In the case of ‘Chhetriya pradushan sangarsh samiti v state of U.P’[10], the jhunjhunwala mills
purchased a land form the member of samiti long back because increasing land prices the heirs
of the persons, who sold the property asked to return it when they could not succeed in that
they started launching criminal offence complaints and that the that mills polluting the
environment. SC held that samiti has not come with clean intention and hence PIL cannot be
entertained. Because of those cases, the SC laid down certain condition for PIL.

10
1990 AIR 2060, 1990 SCR (3) 739

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In ‘S.P. Gupta v union of India’ [11], P.N. Bhagwati, in the instant case lays down certain
specific case where PIL cannot be entertained namely.

1. In the person is engaged in socio- economic crime then there is no PIL.

2. If offence is against the woman, no PIL should be filed on behalf of the t criminal.

CRITICISM OF PIL

Criticism of PIL has been given by many learned people of the field of law but one of the main
criticisms is given here:

Liberalizing the requirement of standing in PIL- M.N. Chaturvedi

Mr. Chaturvedi in his article points out 4 criticism against PIL namely:

1. It encourages vexatious litigation to file unmerited, odious, fictitious claims and abuse
of the process of the court.

Comment: - PIL has protected public interest.

2. It shows immobility & inefficiency in administration.

Comment: - administration to go according to the manner in which they want till the order of
the court. For example, in ‘Ratlam municipality v Yardhichan’ [12], only when the direction
came, the municipality worked but administrative inefficiency is also because of its supervisors
or offences.

3. In the PIL court sits in the judgment of the political branch of the state judiciary comes
into conflict with the political branch of the state judiciary comes into conflict with the
political branch.

Comment: - In wadhera vishakha case directions were issued, but no effective. This may be
true but in the most if the cases victims were given relief.

11
AIR 1982 SC 149
12
1980 AIR 1622, 1981 SCR (1) 97

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 4. PIL is trying to wither away the doctrine of separation on of power.

Comment: - montesques doctrine that there should be separation of power i.e. the organs of the
govt. should confine their role in the PIL judiciary encroaches into the domain of Legislation
and executive but to chturvedi, the doctrine is not followed strictly in India. When the
Executive and legislation has not taken any action, the judiciary has to take lead.

RECENT CASE OF PIL

Recently in the territory of India many cases from the area of PIL has come into picture which
has been filed in the court of law. This project put lights in few of the cases related to PIL.

Firstly, The Supreme Court, in a special hearing on October 7, 2019, ordered the
Brihanmumbai Municipal Corporation (BMC) to halt the felling of trees in the Aarey forest
and asked status quo to be maintained in the area. Aarey, situated in Goregaon, is famous
among nature enthusiasts for being the green lungs of the city. The court also ordered the
authorities to release people, arrested for protesting against the felling of trees.

It had admitted a Public Interest Litigation based on a letter sent to the court by a law student
Rishav Ranjan, seeking a stay on the cutting of trees and the releasing of protestors. The order
came after BMC had already cut around 1,500 trees on October 5. The Bombay High Court on
October 4 had dismissed petitions to declare Aarey Colony in Mumbai as forest and refused to
stop felling of more than 2,500 trees for a metro car shed project, according to media reports.
The question of classification of the land as forest or revenue isn’t relevant in the matter due to
the Supreme Court’s order of December 12, 1996 in the ‘TN Godavarman Thirumulkpad v
the Union of India’, according to experts. In the order, the apex court had observed that the
Forest (Conservation) Act, 1980, was brought in to prevent deforestation and goes on to add
that its nature of land classification doesn’t matter.

“The Forest Conservation Act, 1980 was enacted with a view to check further deforestation
which ultimately results in ecological imbalance; and therefore, the provisions made therein
for the conservation of forests and for matters connected therewith, must apply to all forests
irrespective of the nature of ownership or classification thereof,” the order read. Moreover, the
court had also said that forests will not just be areas recorded as forest land in government
records, but all areas which are similar to the dictionary definition of a forest, irrespective of
the classification of land.

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“The word forest must be understood according to its dictionary meaning. This description
covers all statutorily recognised forests, whether designated as reserved, protected or otherwise
for the purpose of Section 2(i) of the Forest Conservation Act. The term ‘forest land’, occurring
in Section 2, will not only include ‘forest’ as understood in the dictionary sense, but also any
area recorded as forest in the Government record irrespective of the ownership,” read the SC
order.

“I am surprised that the Bombay HC felt itself bound by the principle of ‘res judicata’ [13] with
regard to a previous decision of the same court. It did not acknowledge the binding nature of
the SC’s Godavarman decision of 1996, which is the law of the land under Article 141 of the
Constitution,” said Shomona Khanna, SC advocate and former legal advisor to the Union
Ministry of Tribal Affairs.

Under the Godavarman order, the states were supposed to identify and notify forests, said Stalin
Dayanand of Vanshakti, an environmental non-profit based out of Mumbai. Vanshakti is one
of the parties in the Aarey case in the Bombay High Court. “Most states have a criterion for
declaring forest lands, like in Gujarat they consider patches of land, which has an area of two
hectares and has 50 trees to be a forest,” Dayanand said.

Dayanand noted that the Maharashtra government has not notified any such criterion. In fact,
there are cases pending in this regard in the SC and the National Green Tribunal, he said. The
legality surrounding the classification of land is ambiguous.

“A reading of the court document indicates that whether or not Aarey was a deemed forest had
yet to be determined by both the state government and the judiciary. In the special hearing in
SC, it was stated that the area in question was unclassed state forest,” said Kanchi Kohli, senior
researcher at Centre for Policy Research, an environment think-tank based out of Delhi. “If
yes, then the dictionary meaning of forests according to the SC’s Godavarman case would be
applicable and prior permission for forest diversion must be sought,” Kohli said.

But it appears that felling of trees was undertaken before the court’s verdict on deemed forest
was out, she noted. Whatever the court orders in the next hearing on October 18, this case will
certainly open the pandora’s box of forest land classification in the country, Dayanand said.

13
RES JUDICATA is a phrase which has been evolved from a Latin maxim, which stands for ‘the thing has been
judged’, meaning there by that the issue before the court has already been decided by another court, between
the same parties.

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Secondly as in 2008 a case was decided by Supreme Court named ‘Common Cause (A Regd.
Society) v Union of India’, in this PIL Petitioner filed public interest litigation praying to court
to enact a Road Safety Act in view of the numerous road accidents but in this case court held
that court cannot direct legislation A perusal of the prayers made in this writ petition clearly
shows that what the petitioner wants the courts to do is legislation by amending the law, which
is not a legitimate judicial function so this Petition was dismissed by court of law.

CONCLUSION

So by the all discussion this is conclusion that Public interest litigation is a process to put any
public problem in the eyes of law but as it is said that nothing can be fully good, so there are
some good feature then some bad are also their as we have discussed about the misuse of PIL.
In the misuse of PIL it can be possible that any person of society sends PIL to tease any other
person of the society in Indian law, means litigation for the protection of public interest. It is
litigation introduced in a court of law, not by the aggrieved party but by the court itself or by
any other private party. It is not necessary, for the exercise of the court’s jurisdiction, that the
person who is the victim of the violation of his or her right should personally approach the
court. Public Interest Litigation is the power given to the public by courts through judicial
activism.

Public Interest Litigation is working as an important instrument of social change. It is working

for the welfare of every section of society. It's the sword of every one used only for taking the
justice. The innovation of this legitimate instrument proved beneficial for the developing
country like India. PIL has been used as a strategy to combat the atrocities prevailing in society.
It's an institutional initiative towards the welfare of the needy class of the society. In ‘Bandhua
[14]
Mukti Morcha v Union of India’ , Supreme Court ordered for the release of bonded
labourers. In ‘Murli S. Dogra v Union of India’, the Supreme Court banned smoking in public
places. In a landmark judgment of Delhi Domestic Working Women's Forum v. Union of India,
Supreme Court issued guidelines for rehabilitation and compensation for the rape on working
women. In ‘Vishaka v State of Rajasthan’[15], Supreme court has laid down exhaustive

14
(1997) 10 SCC 549
15
AIR 1997 SC 3011

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guidelines for preventing sexual harassment of working women in place of their work.

It would be appropriate to conclude by quoting Cunningham, Indian PIL might rather be a

Phoenix: a whole new creative arising out of the ashes of the old order.

A judicial system can suffer noa greater lack of credibility than a perception that its order can
be flouted with impunity. This court must refrain from passing orders that cannot be enforced,
whatever the fundamental right may be and however good the cause. It serves no purpose to
issue some high-profile mandamus or declaration that can remain only on paper. Although
usually the Supreme Court immediately passes interim orders for relief, rarely is a final verdict
given, and in most of the cases, the follow-up is poor.

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