In what scenarios would it be advisable to avoid using JavaScript for pop-up windows in PHP?

Using JavaScript for pop-up windows in PHP may not be advisable in scenarios where users have disabled JavaScript in their browsers, as the pop-up window functionality will not work for those users. In such cases, it would be better to rely solely on PHP for generating pop-up windows to ensure a consistent user experience for all visitors.

<?php
echo "<a href='popup.php' target='_blank'>Open Pop-up Window</a>";
?>