for monetary interest were on the rise. A bench of the high court had also expressed concern over the misuse of PILs. The bench issued a set of guidelines it wanted all courts in the country to observe when entertaining PILs. In a September 2008 speech, Prime Minister Manmohan Singh expressed concern over the misuse of PILs: “Many would argue that like in so many things in public life, in PILs too we may have gone too far. Perhaps a corrective was required and we have had some balance restored in recent times”. In what may be a tool against frivolous PILs, the Union Ministry of Law and Justice (assisted by Bhagwati and Iyer) prepared a law regulating PILs. The judgment said: “This court wants to make it clear that an action at law is not a game of chess. A litigant who approaches the court must come with clean hands. He cannot prevaricate and take inconsistent positions”. For example, a petition drafted by Amar Singh was vague, not in conformance with the rules of procedure, and contained inconsistencies; the court did not explore his primary grievance (infringement of privacy). A positive outcome of the case was the court’s request that the government “frame certain statutory guidelines to prevent interception of telephone conversation on unauthorised requests”. In this case, Reliance Communications acted upon a forged request from police. In Kalyaneshwari vs Union of India, the court cited the misuse of public-interest litigation in business conflicts. A writ petition was filed in the Gujarat High Court seeking the closure of asbestos units, stating that the material was harmful to humans. The high court dismissed the petition, stating that it was filed at the behest of rival industrial groups who wanted to promote their products as asbestos substitutes. A similar petition was then submitted to the Supreme Court. The plea was dismissed, and the plaintiff was assessed a fine of 100,000. The judgment read: “The petition lacks bona fide and in fact was instituted at the behest of a rival industrial group, which was interested in banning the activity of mining and manufacturing of asbestos. A definite attempt was made by it to secure a ban on these activities with the ultimate intention of increasing the demand of cast and ductile iron products as they are some of the suitable substitute for asbestos. Thus it was litigation initiated with ulterior motive of