50. 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 quot;might bequot;, 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
quot;preliminary conclusionquot; 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

51. 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

52. 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

53. Gemini XI, Image 193
quot;This photograph from an altitude of 410 miles encompasses all of India, an area of
1250 000 square miles,quot; GEORGE M. LOW, then the Deputy Director, Manned
Spacecraft Center, NASA, notes. quot;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.quot; 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.'

54. 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.”

55. 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).

56. 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.

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