Answers to paragraphs 21 to 28 in the counter submitted by Govt.

These paragraphs confirm the importance of undertaking a conclusive study with full

resources and participation of the Archaeological Survey of India, which is charged

with the protection of ancient monuments and archaeological sites/ remains.

The respondents are carrying on with the project, reporting about 7% progress in

the Adam’s Bridge segment of dredging (as reported in their website

http://sethusamudram.gov.in) , in violation of mandatory, statutory obligations in

the Ancient Monuments and Archaeological Sites and Remains Act, 1958 and that

they have proceeded without any conclusive material despite the religious and

archaeological significance of Rama Setu.

No investigation has been done of the Rama Setu structure to determine if it

is deserving of protection as an ancient monument or an archaeological site under

the Ancient Monuments Act, 1958.

There is considerable scientific evidence accumulated that the Rama Setu is

man-made. Article 51A(f) of the Constitution enjoins protection of the cultural

heritage of India. Therefore, it is respectfully submitted that the Archaeological

Survey of India is required to determine under the Ancient Monuments Act, 1958 as

to whether or not the Rama Setu is man-made. If it is man-made, its origins stretch

back into antiquity, and certainly more than the 100 years required under the said

Act. If so, it would be fit and proper for this Hon’ble Court to stop the project before

it destroys the Rama Setu and to direct the Archaeological Survey of India to have

the Rama Setu declared as an ancient monument or an archeological survey as the

case may be and to ensure that it gets all the protection that such a monument

requires.

Paragraph 23, repeatedly uses the verb "might be", which means the deponent

himself is admitting that he is not sure.

Paragraph 26, admits that the result of the investigation by GSI was only a

"preliminary conclusion" again, there is a doubt. Moreover, paragraphs 24 and 25 no

where states explicitly that the boreholes drilled were on Adam's Bridge. The

paragraph 27 in turn is based on the views of a team of geologists invited by

respondent SCL, which has an extremely strong self interest in denying the historical

significance of Rama Setu.

As against this a reputed Government body such as the NIOT, has undertaken

studies that strongly suggest, if not confirm, that Adam's Bridge is man made.

Comments made on Page 24, Paragraph 27 about tombolo are excerpted – out of

context -- from the following source :

Shuttle Mission STS-056 Date taken: 1993-04-17 Photo ID: STS056-78-083

Title: STS-56 Earth observation of a sun-glinted ocean along the coast of Somalia

Description:

STS-56 Earth observation taken aboard Discovery, Orbiter Vehicle (OV) 103, is of a

sun-glinted ocean along the northeastern coast of Somalia. The small island of

Xaafuun is connected to the mainland by a well-developed double tombolo-two sand

bars. Between the two toombolos a lagoon is formed which gradually fills with

sediment and becomes a flat sand bar. Better known double tombolos include those

of Gibraltar, the now-partially submerged giant tombolos forming Adam's Bridge

(Palk Strait) connecting Sri Lanka to India, Monte Argentario in Italy, and Long

Island, New York. Such tombolos usually indicate a constant sediment source and a

strong unidirectional or bi-directional (monsoonal) long shore current. In this case,

sediment is provided by the plumes of the major African rivers debauching into the

Mozambique Channel. The sediment is carried predominately to the northeast along

the coast by the swiftly moving monsoonal Agulhas Current. Visible in this scene are

internal waves, shear

http://images.jsc.nasa.gov/luceneweb/caption_direct.jsp?photoId=STS056-78-083

It is clear that the description principally relates to the observation made in April

1993 of “a sun-glinted ocean along the coast of Somalia”. Subsequent to this date,

many earth observations have been made not only by NASA but also by ISRO.

It is also clear from the following observations that these views of NASAcited by the

deponent, are NOT NASA’s considered view.

“Tombolo is an Italian name—accent on the tom—derived from the Latin for burial

mound. A tombolo is a pile of sediment that, unlike any other formation on a beach,

leads straight offshore from the mainland to an island (or sometimes from one island

to another).“ http://geology.about.com/cs/gorgeous_pictures/a/aa082999.htm

From the geological and geotechnical surveys done so far, it is clear that Rama Setu

is more than a tombolo. It contains 1.5 to 2.5 m layers of coral rocks transported

from the shore.

Reports by NASA specifically about Rama Setu (Adam’s Bridge) clearly refer to it as a

land-bridge.

Date: 1989-11-25 STS033-74-74

Date acquired: February 2000 PIA06670 Shuttle Radar

Topography Mission reports: “Sri Lanka is shaped like a giant

teardrop falling from the southern tip of the vast Indian

subcontinent. It is separated from India by the 50km (31mi)

wide Palk Strait, although there is a series of stepping-stone

coral islets known as Adam's Bridge that almost form a land

bridge between the two countries. The island is just 350km

(217mi) long and only 180km (112mi) wide at its broadest,

and is about the same size as Ireland, West Virginia or

Tasmania.” http://www2.jpl.nasa.gov/srtm/srilanka.htm

Gemini XI, Image 193

"This photograph from an altitude of 410 miles encompasses all of India, an area of

1250 000 square miles," GEORGE M. LOW, then the Deputy Director, Manned

Spacecraft Center, NASA, notes. "Bombay is on the west coast, directly left of the

spacecraft's can-shaped antenna New Delhi is just below the horizon near the upper

left. Adam's Bridge between India and Ceylon, at the right, is clearly visible. A

cloudless region surrounds the entire subcontinent. Differences in color, green near

the west coast, and brown inland, delineate regions of heavy vegetation and

semiarid areas." http://history.nasa.gov/SP-168/section3b.htm

The Encyclopedia Britannica describes the bridge thus, 'Adam's Bridge also called

Rama's Bridge, chain of shoals, between the islands of Mannar, near northwestern

Sri Lanka, and Rameswaram, off the southeastern coast of India.'

Proposed Navigational Channel Alignment – Sethu Samudram Project- Drilled

Borehole Locations.

See the articles by Dr. S. Badrinarayanan, Retd. Director of Geological Survey of

India (Pages 22 to 24 of Rama Setu book), V. Srinivasan, Geologist (Page 26 of

Rama Setu book) and Dayananda Saraswati (Page 27 of Rama Setu book)

Badrinarayanan reports: “In all about 10 boreholes have been drilled along this ridge

upto the international boundary. Out of the ten boreholes six boreholes were in the

sea. The result” of the bore logging clearly showed about 1.5m to 4 m marine sand

followed by 1.5 to 2.5 m of boulders of calcareous sand stones and coral followed

again by marine sand to various depths end at continuous compact formation. It is a

well known fact that the coral reefs can only form in clean and unpolluted water and

these being marine organisms required firm and compact formation as foundation.

The presence of loose marine sand below these clearly indicated that these are not

natural and are transported. Unless somebody has transported and dumped them

these could not have come there. Some of the boulders are so light they could float

on water. Apparently whoever has done it has identified it as light and strong

boulders to make it easy for transportation. Since the boulders are strong they can

withstand lot of weight. There are corals that are present on land in Rameswaram,

Pamban and Tuticorin areas. A study of them and dating them clearly show that the

age of the coral is about 7300 years and the sea level at that time was 4 m above

the present day level. Then there has been a lowering of sea level and between 4 to

5 thousand years Before Present the sea level was about 1.5 m above present day

sea level. The 1.5 to 2.5 m. thick zone of corals and rock presently occurring at

shallow depths in the sea atop the crustal portion of the Adams Bridge appeared to

be an ancient causeway.”

Many research documents during the British colonial period refer to it as Rama’s

bridge. Many maps in Schwartzberg South Asia Atlas of Univ. of Chicago, refer to it

as Setubandha or Setu or Setuka and in some cases with Adam’s Bridge in

parenthesis. The 1788 map of Hindoostan or Mogul Empire calls it Ramar Bridge. A

1747 map drawn by Netherlands calls the tip on Indian side as Ramarcoil I.

1799 Asiatic Researches Transactions of Asiatic Society specify that the bridge was

inhabited and with trees growing on it. Until 1480, it served as a land link between

Sri Lanka and India, when a cyclone caused some breaches. A cyclone in 1964 led to

the submergence of Dhanushkodi.

The word Setu in Tamil means ‘man-made bund’ according to Abhidaanakos’am

(which translates it as ceyar-karai). A Setu is a bund and distinguished from anai

(dam) or paalam (with pillars creating a bridge).

Advanced Earth Observing Satellite (ADEOS) launched in December 2002 has also

produced an imaging showing Rama Setu, using GLI (Global Imager) at 250 m

resolution. This image is dated February 2003.

International Space Station Expedition 6 February 23, 2003 shows the land bridge

linking Dhanushkodi and Talaimannar.

ISRO Resource Satellite image of Oct. 2003 also shows the Rama Setu (Adam’s

Bridge)