the agencies have investigated them expeditiously, and to their logical conclusion. Philippines The Manila Bay Case led to the formal placement of the procedural innovation of continuing mandamus in statute books in the Philippines, where it is being resorted to by litigants in other cases. South Africa The Constitutional Court of South Africa in 2002, recognised the need for structural interdicts in their supervisory jurisdiction, where declaratory orders go unheeded. This need should be coupled with a meaningful engagement of all the parties to the litigation in securing socio-economic rights. Canada Courts would give time to authorities for compliance, by suspending or delaying declarations of invalidity. In 2003, the Supreme Court of Canada in Doucet-Boudreau v Nova Scotia (Minister of Education) held that, in constitutional cases a court could keep the final outcome in a case pending in a post-judgment supervisory jurisdiction, and would not become functus officio. United States Structural injunction, formulated possibly first by American courts, has been applied to try remedy schools, prisons, environmental cleanup and traditional rights of indigenous people. Notes Law of India Writs