Courts may record governmental assurances and direct expedited compliance without continuously monitoring project execution.

The appellant, a resident of Vaniyambadi, pursued the construction of a grade-separated crossing in lieu of Level Crossing No. 81, which connects the eastern and western parts of Vaniyambadi and is used by a substantial number of residents and commuters

The Government of Tamil Nadu initially sanctioned construction of a Road Over Bridge in 2007, but the proposal was later modified to a Road Under Bridge because of the substantial land acquisition and increased cost involved.

Proceedings for land acquisition were initiated under the Tamil Nadu Highways Act, 2001.

Following a joint inspection by the State Highways Department and Southern Railway, the project was again modified to a Limited Use Subway (“LUS”), requiring acquisition of approximately 5,009 square metres, and this change was approved by the State Government on 15.05.2025.

The appellant’s earlier writ petition seeking commencement of construction or reopening of the level crossing had been disposed of after the crossing was reopened for public use.

In 2025, he filed a further writ petition before the Madras High Court seeking expeditious construction and completion of the LUS within a stipulated time. The High Court disposed of the petition without prescribing a completion schedule, observing that granting the relief would require continuous judicial monitoring of the project.

During the appeal, the respondents placed on record the status of land acquisition, approvals, tendering, and the proposed execution schedule.

1. Whether, in light of the subsequent progress made by the State authorities and Southern Railway, the Supreme Court should issue directions for expeditious implementation and completion of the proposed LUS at Level Crossing No. 81

2. Whether the appeal should remain pending for continuous judicial monitoring of the project, or be disposed of after recording the respondents’ statements and assurances

The Court applied the public-law principle that constitutional courts may issue appropriate directions to public authorities to ensure timely performance of public infrastructure obligations where the authorities have undertaken and substantially progressed a public project.

The Court also relied on the principle that judicial review does not ordinarily require courts to supervise the day-to-day execution of governmental projects; once concrete assurances and an implementation framework are placed on record, the matter may be disposed of while making those assurances operative and requiring compliance reporting.

The land acquisition component was governed by the Tamil Nadu Highways Act, 2001, under which the State was required to complete the requisite acquisition proceedings.

No specific judicial precedent was relied upon in the judgment.

The Court found that the project had moved beyond mere consideration: the State had initiated steps concerning land acquisition, designs, drawings, estimates, and approvals, while Southern Railway had floated a tender for its portion of the LUS and had indicated that seven bidders had participated.

Southern Railway further stated that its portion could be completed within six months of the award of the contract, subject to the State making the necessary approach land available.

In view of these developments, the Court considered that the controversy had substantially narrowed and that continuing the appeal solely to monitor execution would serve no useful purpose.

Nevertheless, to prevent further avoidable delay, it converted the respondents’ statements and assurances into operative directions requiring coordinated action by the State authorities and Southern Railway.

The State authorities were directed to complete the pending land acquisition, approvals, designs, estimates, and other processes expeditiously, and to make the requisite land available to Southern Railway without avoidable delay.

Southern Railway was directed to finalise the tender within the time indicated to the Court and, after award of the contract and availability of land, to complete its portion of the LUS within six months from the date of award.

The State authorities and Southern Railway were directed to file compliance affidavits upon completion of their respective works and, in any event, within eight months from the judgment.

All pending applications were also disposed of.