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    INDEX

    S.No Particulars Pages

    1. Listing Proforma

    2. Checklist

    3. Synopsis and List of Dates

    4. Writ Petition under Article 32 of the Constitution of India withaffidavit

    1 - 56

    5. Annexure P1: Report of Worldwatch Institute on status ofnuclear industry 2010-2011

    6. Annexure P2: Report on proposed nuclear plants published inFrontline dated 26.03.2011

    7. Annexure P3 (Colly):

    a) News Report on protests at Kudankulam nuclear plant

    b) Article on nuclear plant in Kudankulam

    8. Annexure P4: Excerpt of the Russian report on safety of theirnuclear reactors

    9. Annexure P5: A report on the leaked Russian report dated21.06.2011

    10. Annexure P6: News Report on Kaiga nuclear plant dated

    19.08.2011

    11. Annexure P7: A report titled People power nukes PMs N-

    Power dream on local opposition published in Mail Today dated

    21.09.2011

    12. Annexure P8: Environment Impact Assessment Notification,2006, issued on 14.09.2006 under the Environment ProtectionAct

    13. Annexure P9: Study on public hearings regarding nuclearplants being rendered ineffective

    14. Annexure P10: A study on cancer risks people near nuclearpower stations published in the journal Environmental Healthdated 23.09.2009

    15. Annexure P11: A paper on the effects of radiological releasespublished by Greenpeace

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    16. Annexure P12: Research paper on demerits of nuclear poweras a way to meet energy needs, published in Journal of Land,Resources & Environmental Law in 2004

    17. Annexure P13: Article published in The Hindu on the possibleadverse affects of radiation exposure considered safe' byregulatory standards dated 15.09.2011

    18. Annexure P14 (Colly): Scientific analysis done by Prof. TShivaji Rao showing the far reaching impact of a nuclearaccident at

    a) Proposed nuclear site of Kovvada in Andhra Pradesh

    dated 17.08.2011

    b) Proposed nuclear site of Kudankulam in Tamil Nadudated 08.10.2011

    19. Annexure P15: Paper by Prof. Benjamin Sovacool published inEnergy Policy dated 02.06.2008 containing carbon-emissioncost of all the steps in the lifecycle of a nuclear plant

    20. Annexure P16 (Colly): News reports on top scientists askingfor a moratorium on construction of new nuclear plants

    a) Report dated 31.03.2011

    b) Report dated 24.08.2011

    21. Annexure P17: Article in The Hindu by TISS Chairman on theneed for safety review of nuclear plants sites dated 21.03.2011

    22. Annexure P18: Article on the exorbitant cost ofdecommissioning nuclear plants in United Kingdom published inGuardian dated 13.04.2011

    23. Annexure P19: Story in Frontline magazine on the damagingconsequences for the nuclear industry due to Fukushimadisaster dated 26.03.2011

    24. Annexure P20: A research paper written by Prof. Sovacool,titled Questioning a Nuclear Renaissance

    25. Annexure P21: Article by Prof. Brahma Chellaney, Centre forPolicy Research, on the stress on marine plant life and fish dueto location of nuclear plants on coasts dated 14.03.2011

    26. Annexure P22: A list of known cases of theft of nuclearmaterial worldwide

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    27. Annexure P23: Article published in Mail Today enlisting simpletheft of radioactive material as a potential cause of nuclearterrorism dated 28.07.2011

    28. Annexure P24: News report dated 17.08.2011 on the Ministerof State for Home Affairs acknowledging the atomicestablishments (including nuclear plants) are prime targets ofterrorist groups

    29. Annexure P25: Article by Prof. Sovacool on the excessivehuman and economic costs in the event of an attack or accidentat the nuclear power plant near New York City dated16.03.2011

    30. Annexure P26: A paper published in the Bulletin of the AtomicScientists dated 19.04.2011 on the major nuclear accidents andthe lessons to be learnt

    31. Annexure P27: Article on the likelihood of utter devastation inthe event of occurrence of a mischance due to location ofseveral nuclear sites in populated areas worldwide published inthe international science magazine Nature dated 21.04.2011

    32. Annexure P28: Article published in Frontline on need forhighest safety investments even in the unlikely event of amishap dated 26.03.2011

    33. Annexure P29: Article titled India must learn from Fukushimanuclear meltdown by former Chairperson, Atomic EnergyRegulatory Board

    34. Annexure P30 (Colly): Reports showing over 25% nuclear

    power plants in USA contaminating ground water and otherwater bodies with radioactive tritium

    a) Report dated Nil

    b) Report of A.P. dated Nil

    c) Report of Greenpeace dated 15.10.2010

    35. Annexure P31: A report dated 13.05.2011 alleging number ofUS nuclear reactors found unsafe indicate NRC (regulator) hasbecome too close to the nuclear establishment

    36. Annexure P32: Statement of Secretary General of the UnitedNations (UN) Mr. Ban Ki-moon after his recent visit to Chernobyl

    37. Annexure P33: A report on the health effects of the Chernobyldisaster dated April 2011

    38. Annexure P34: Article published by Centre for International

    Governance Innovation in December 2009 on Indian Nuclear

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    Industry

    39. Annexure P35: Article published in The Frontline magazinedated 13.03.1999 on the inadequate safety standards of Indias

    nuclear facilities

    40. Annexure P36: A compilation of the 99 major nuclear poweraccidents from 1950-2010 along with conservative costestimates

    41. Annexure P37: A list prepared by Greenpeace of the severalnuclear accidents and incidents that occurred in the 10 yearsfollowing the Chernobyl disaster

    42. Annexure P38: Abstract of research paper Prof Sovacoolstating hazards of Modern nuclear reactors published in Journalof Contemporary Asia

    43. Annexure P39:A study by Centre for Science & Environment(CSE) published in Down to Earth dated 15.06.1999

    44. Annexure P40: A study by Indian Doctors for Peace and

    Development confirming health issues and low life expectancyof people in Jadugoda dated 07.11.2008

    45. Annexure P41:A study by Toxics Link encapsulating the effectof uranium mining and presence of radioactive waste on Indianpeople dated March 2009

    46. Annexure P42: A report establishing that Uranium Mines arerun in disregard for health of workers and local communities,

    published in Tehelka dated 25.09.2010

    47. Annexure P43: Article by Ms. Helen Caldicott, president ofNuclear Policy Research Institute on inherent dangers withnuclear power, published in Australian dated 15.04.2005.

    48. Annexure P44 (Colly):

    a) A copy of the data on imports of nuclear reactors bydeveloping countries from developed countries released

    by IAEAb) Article on non funding of nuclear power plants by most

    international financial institutions like World Bank, AsianDevelopment Bank published in a journal of RoyalSwedish Academy of Sciences

    49. Annexure P45: Report by Stephan Leahy, globally renownedenvironmental reporter, on existence of nuclear industry dated30.08.2011

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    50. Annexure P46: A copy of the response under RTI of publicsector undertaking Bhartiya Nabhikiya Vidyut Nigam Ltd. ondiscrepancy between initial cost estimates and actual cost,dated 18.06.2011

    51. Annexure P47:Article by Prof. Sovacool establishing invalidityof industry cost estimates for new nuclear plants published inScitizen dated 02.11.2008

    52. Annexure P48:

    A statement issued by former Chairperson of Atomic EnergyRegulatory Board, Dr. Gopalakrishnan calling for completeabandonment of import of nuclear reactors dated 03.04.2011

    53. Annexure P49: Article by former Finance minister, Mr.Yashwant Sinha, on corruption involved in the Indo-US N-dealpublished in New Indian Express

    54. Annexure P50 (Colly): News reports on the call for halt onnuclear power projects by the BJP and the Left, published inThe Hindu

    a) Report dated 09.08.2011

    b) Report dated 28.08.2011

    55. Annexure P51: A report published by FICCI in 2009 urgentlyrecommending adoption of a law on liability such as the NuclearLiability Act

    56. Annexure P52: A report on The Liability Bill stating that it wasdrafted under pressure from and under the influence of thenuclear industry, published in Tehelka dated 04.12.2010

    57. Annexure P53: The Civil Liability for Nuclear Damage Act,2010 notified on 22.09.2010

    58. Annexure P54: Article by Dr. Gopalakrishnan on reasons forurgency in getting the liability bill passed, published in Rediffdated 13.08.2010

    59. Annexure P55: Article by Dr. Gopalakrishnan on pitfalls of very

    low operators liability published in the New Indian Expressdated 22.08.2010

    60. Annexure P56: Relevant pages from Debate in Rajya Sabhaon introduction and resistance to Nuclear Liability Bill

    61. Annexure P57 (Colly): Articles by physicists M V Ramana andSuvrat Raju on the dangers of indemnifying suppliers

    a) Economic & Political Weekly dated 17.04.2010

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    b) Hindustan Times dated 15.08.2010

    c) The Hindu dated 20.08.2010

    62. Annexure P58: Article by senior journalist Praful Bidwai stating

    that the Nuclear Liability Law is unconstitutional since it violatesseveral legal norms, published in Frontline

    63. Annexure P59: A release by CSE stating that India signed theConvention on Supplementary Compensation for NuclearDamage as a gift for the US President

    64. Annexure P60: Statement by the US President stating benefitsfor US in joining the Convention on Supplementary

    Compensation for Nuclear Damage as it allows them to keeptheir existing law while mandating others to change.

    65. Annexure P61: An IAEA publication giving the record ofsignatures and ratifications on Convention on SupplementaryCompensation for Nuclear Damage

    66. Annexure P62: Article by Dr. Gopalakrishnan published inFrontline on safety assurance and regulation by Nuclear

    Regulatory agency dated 24.06.2000

    67. Annexure P63: A report published in Tehelka, stating that rulesare consistently broken at Indias nuclear facilities dated02.12.2010

    68. Annexure P64: Article by Dr. Gopalakrishnan, published inFinancial Express, on NPCILs strategy and labeling nuclearsafety management in India as farce and worthless, dated18.03.2011

    69. Annexure P65: Article by Dr. Gopalakrishnan (Chairman,AERB) published in the DNA newspaper accounting nuclearsafety audits, dated 26.04.2011

    70. Annexure P66: Press statement released by Prime MinistersOffice declaring set-up of an independent regulator implyingacknowledgment of the current regulatory system being virtuallydysfunctional, dated 26.04.2011.

    71. Annexure P67: Nuclear Safety Regulatory Authority Bill 2011creating a Nuclear Safety Regulatory Authority (NSRA)

    72. Annexure P68: Article by Dr. Gopalakrishnan published inDNA, recommending independent status for nuclear regulator,and provisions for public participation and transparency in itsfunctioning, dated 26.05.2011

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    73. Annexure P69: Article published in The Hindu by Dr.Gopalakrishnan, analyzing the bill introduced by theGovernment, in the light of powers and independence of NSRA

    dated 16.09.2011

    74. Annexure P70: Letter issued by MoEF granting clearance toJaitapur nuclear project dated 26.11.2010

    75. Annexure P71: A press release by MoEF expressing difficultyto accord environment clearance to Jaitapur power generatingcomplex dated 28.11.2010

    76. Annexure P72: Report by Chairman, Western Ghats EcologyExpert Panel encapsulating the natural beauty of the WesternGhats region

    77. Annexure P73: News report on Governments plan to amendAtomic Energy Act to outlaw the residents from any area nearany proposed power plant

    78. Annexure P74: A joint press release by nuclear regulators ofUK, French and Finland on the safety aspect of reactors madeby Areva dated 26.11.2009

    79. Annexure P75: A press release issued by Nuclear RegulatoryCommission regarding safety issues of reactors built by Arevadated 23.07.2010

    80. Annexure P76: Report on safety concerns regarding FrenchEPRs published in New York Times dated 26.07.2010

    81. Annexure P77: Article by Dr. A Gopalakrishnan published inIndia Today bemoaning India becoming the dumping ground foruntested high-cost nuclear reactors dated 07.02.2011

    82. Annexure P78:Article published in The Mint by Prof. BrahmaChellaney stating imports for the Jaitapur project as a scandal,with safety implications dated 29.12.2010

    83. Annexure P79: A news report published in Times of India onthe frequency of earthquakes in and around Jaitapur dated16.03.2011

    84. Annexure P80: A report by Tata Institute of Social Sciencesstating huge negative impact on social and environmentaldevelopment by Jaitapur project dated 29.12.2010

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