INDEX

S.NO. PARTICULARS PAGE

NO.
1. List of leading cases on Locus Standi & PIL 7-9

2. Abbreviation 10

3. CHAPTER -1 11–27
Prologue, Background, Objectives, Problems, Concept of
Locus Standi, Evolution of Concept

I. Prologue
II. Background
III.Objectives
IV. Problems
V. Concept of Locus Standi
VI. Evolution of Concept
4. CHAPTER - 2 28–54
Introduction, Concept, Writ Jurisdiction, Subjects of PIL,
Judicial Pronouncements, Summary of Cases
I. Introduction
II. Concept
III. Writ Jurisdiction
a) Habeas Corpus
b) Mandamus
c) Quo-Warranto
d) Prohibition
e) Certiorari
IV. Subjects of PIL
a) Personal Injury
b) Causation
c) Redressability
V. Judicial Pronouncements
a) Any Person
b) Voluntary Organisation
c) Report on News Paper
VI. Summary of Cases

Page | 1
5. CHAPTER - 3 55–61
Public Interest Litigation and Judicial Activism
I.Public Interest Litigation and Judicial Activism
II.Strengths
III.Weaknesses
IV.Steps Necessary To Stop Abuse
6. CHAPTER -4 62–66
Proposals, Conclusion
I.Proposals

II.Conclusion

7. Bibliography 67–68

8. Website Research 69

Page | 2
 LEADING CASES ON LOCUS STANDI

1. S.P. Gupta vs President Of India And Ors.

2. Janata Dal vs H.S. Chowdhary And Ors.
3. Fertilizer Corporation Kamgar ... vs Union Of India
And Others
4. JasbhaiMotibhai Desai vs Roshan Kumar, Haji
Bashir Ahmed & ...
5. S.P. Gupta vs Union Of India & Anr
6. State Of Uttaranchal vs Balwant Singh Chaufal &
Ors
7. Union Of India And Another vs W.N. Chadha
8. B. Srinivasa Reddy vs Karnataka Urban Water
Supply & ...
9. Maharaj Singh vs State Of Uttar Pradesh & Others
10. Ghulam Qadir vs Special Tribunal & Ors
11. S.K. Gupta &Anr vs K. P. Jain & Anr
12. M/S Northern Plastics Ltd vs Hindustan Photo Films
Mfg.Co. Ltd
13. M/S Jayaraj vs Commissioner Of Excise, Kerala ...
14. M/S Meghal Homes Pvt. Ltd vs Shree Niwas
GirniK.K.Samiti & Ors
15. Umesh Chand Vinod Kumar And Ors. vs Krishi
Utpadan Mandi Samiti And ...
16. Mutukdhari Singh vs Smt. Prem Debi And Ors.
17. Andhra Pradesh Scheduled Tribes ... vs Aditya
Pratap Bhanj Dev And Ors.
18. Dhronamrajti Satyanarayana vs N.T. Rama Rao And
Ors.
19. Sailesh Developers, A Registered ... vs The Joint
Charity Commissioner ...
20. K. Sudarsan And Ors. vs The Commissioner,
Corporation Of ...
21. Tracstar Investments Limited And ... vs Gordon
Woodroffe Limited And Ors.
22. S. Vasudeva And D.P. Sharma And C. ... vs State Of
Karnataka
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23. India Cable Co. Ltd. vs The Government Of Andhra
Pradesh ...
24. Sand Carrier'S Owner'S Union And ... vs Board Of
Trustees For The Port Of ...
25. Mary Ulahannan vs Union Of India
26. Santosh Chopra vs Teja Singh Sardul Singh
27. Uttam Das Chela Sunder Das vs Shiromani
Gurdwara ...
28. Rakesh Kumar Sharma And Ors. vs State Of U.P.
And Anr.
29. Hari Krishna Kanoi And Anr. vs Appropriate
Authority An dOrs.
30. The Workmen Of Karnataka State ... vs The State Of
Karnataka Repr. By Its ...

Page | 4
 LEADING CASES ON LOCUS STANDI & PIL

1. Janata Dal vs H.S. Chowdhary And Ors.

2. Ajai Kumar Singh {P.I.L.} vs State Of
U.P.ThruSecreatry ...
3. Sri. Tennydard M Marak vs The State Of Meghalaya
4. Rajiv Ranjan Singh 'Lalan' &Anr vs Union Of India &
Ors
5. Andhra Pradesh Scheduled Tribes ... vs Aditya
Pratap Bhanj Dev And Ors.
6. Jaskaran Singh Brar vs State Of Punjab And Ors.
7. Prof. Manohar Dhonde And Indian ... vs The State Of
Maharashtra Through ...
8. K. Hanumantha Rao And Ors. vs Prl. Sub-Judge And
Ors.
9. Dr. Subramanian Swamy vs The Election
Commission Of India ...
10. Niranjan Tripathy vs State Of Orissa & Others ...
Opp. ...
11. Suraj Narain Srivastava vs State Of U.P. And Ors.
12. State Of West Bengal vs Union Of India And Others
13. Nand Kishore Nautiyal vs Tehri Hydro Development
14. Yatin N. Oza vs State Of Gujarat And Ors.
15. GramaSevaPratishthana And Anr. vs State Of
Karnataka And Ors.
16. RajeshkumarJayantilal Joshi vs Govindbhai K.
Shekhda And Ors.
17. Krishan Banon vs State Of Himachal Pradesh And
Ors.
18. Venkatarajaiah And Another vs Osmania University,
Hyd. And ...
19. Yatin N Oza vs State of Gujurat and Others
20.. Bhavesh ChandubhaiThakrar& vs Mansinhbhai
Kishabhai Chavda & 5

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 LIST OF ABBREVIATIONS
 AC -Appeal Case
 ACJ –American Communication Journal
 AIR - All India Reporter
 All - ALLAHABAD
 ALL ER- All England Law Reports
 Art- Article
 AP- ANDHRA PRADESH
 Bom - BOMBAY
 Cal - CALCUTTA
 Ch- Chapter
 Co.-Company
 Del - DELHI
 Edn-Edition
 HL-House of Lords
 K.B. - KINGS BENCH
 M.P.-Madhya Pradesh
 Maha- Maharashtra
 p. - PAGE
 Para- paragraph
 Pat - PATNA
 PC - PRIVY COUNCIL
 QB –Queen’s Bench
 SC-Supreme Court
 Pun -PUNJAB AND HARYANA
 SCC-Supreme Court Cases
 SCR- Supreme Court
 U.P. - UTTAR PRADESH
 W.L.C. - WESTERN LAW CASES

Page | 6
 DOCTRINE OF LOCUS STANDI AND PUBLIC
INTEREST LITIGATION : AN ANALYTICAL
STUDY
CHAPTER -1
PROLOGUE, BACKGROUND, OBJECTIVES,
PROBLEMS, CONCEPT OF LOCUS STANDI,
EVOLUTION OF CONCEPT

PROLOGUE

In the past the paradise of justice was the monopoly of

the affluent who alone possessed its golden key. This
class-oriented common law system of dispensation of
justice is now giving way to a new mass oriented
jurisprudence. A wave of public interest litigation which
brings the goddess of justice to the illiterate and
exploited has set in. This new trend drives away the past
evils of legal technicality and procedural rigidity.
Liberalisation of the need to prove locus standi for
invoking the jurisdiction of the court is the most notable
phenomenon of this change.

Page | 7
BACKGROUND

The rudiments of public interest litigation can be traced

to Roman Law under which it was open to any person to
bring what was called an actio popularis in respect of
public delict or to sue for a prohibitory or restitutory
interdict fore protection of res sacrae and res publicae.
The actio popularis may be the ancestor of our public
interest litigation.

In England, there was, from the very early days, the

device of relator action. The foundation of this principle
is the interest of the Crown as parents patriae in
upholding the law for the benefit of the general public.
The Crown is interested in seeing that public bodies
discharge their functions properly and that they do not
abuse or misuse their powers. This device imposes a
measure of control over situations where, otherwise,
members of the public might bring uncoordinated
actions, resulting in confusion. Basically, this is a
regulated form of actio popularis.

Page | 8
In U.S.A., the administrative agencies were considered to
represent the public interest. The agency proceedings
were to be the forums for vindicating public interest.
Litigation in public interest began acquiring popularity in
the U.S. in the early sixties. The reason was the failure of
the administrative agencies, referred to as the fourth
headless branch of the State, after the Executive,
Legislature and the Judiciary were conceived as
instruments to regulate the powerfully organized private
sector.

They were intended to streamline the administration in

such a way as to better serve the interests of the public.
The agencies had to discharge a variety of functions
ranging from dispensation of social benefits to control of
multinationals, protection of environment and the
consumer public. In these matters, they were vested with
powers to take important decisions and to implement
them. But, by sixties, it became clear that, these
agencies had failed in protecting the public interest due
to their purposive inaction where action was called for.

Page | 9
Two factors that led to the failure of the agencies helped
the development of public interest litigation. The first
was, what the Americans call 'agency capture'.
Powerfully organised private sector which was to be
regulated by the agencies, captured the agencies
themselves and, they began to play to the tune of those
against whom they were expected to act. The second
factor was the failure of the agencies to recognize the
existence of large and diffuse interests in society which
were badly disarrayed and unorganised. Thus, the
administrative agencies became what are called the 'low
visibility' areas of decision-making.

The diffuse interests could not get redress for their

grievances either in the Legislatures or administrative
forums because, both these forums were controlled by
powerfully organized vested interests. So, these interests
had only the judicial forum to turn to. The 'public
interest' law emerged as a means to vindicate the rights
of minorities and weaker sections in society like women,
children, the physically andlor mentally handicapped,
the poor, the consumer public, environmentalists, etc.
The existing legal system failed to protect these interests

Page | 10
because of the problem of access to court, lack of
standing to litigate, or economic disabilities. The public
interest lawyers were instrumental in finding a way out
of this impasse.

With financial support from the Office of Economic

Opportunity (0E0) of the Federal Government of the
United States, these lawyers mobilized law students and
social-action groups to articulate within the legal frame-
work, the diffuse interests of several million
unrecognized people in the lower socioeconomic strata
and to force the system to change its priorities,
procedures and politics for the benefit of those who were
till then kept outside it.

Page | 11
OBJECTIVES

The objectives of this device, therefore, are principally,

four:

1. Representing the diffuse interests in society.

2. Securing justice, political as well as social, to the

extent possible, to the economically and socially
handicapped.

3. Ensuring that the administrative and other political

machinery work in a way subservient to the interests of
the general public, and,

4. Bridling the law-enforcement machinery itself to move

towards social justice.

The courts try to further these objectives by increasingly

allowing resort to public interest litigation. But, our
current procedural norms place innumerable hurdles in
the way of a prospective litigant. Those seeking justice
will have to overcome these hurdles.
Page | 12
THE PROBLEM

We have the adversary system of court procedure as

opposed to the inquisitorial. Adversary system requires
parties opposed to each other to place evidence before
the court to prove each other's case. The court decides
the case on the basis of who has given the best evidence
and does not enquire further.

So also, the court will adjudicate only if a matter is

brought before it by somebody. Therefore, as far as
public interest litigation is concerned, all members of
society must be encouraged to bring before court,
situations that warrant courts' intervention.

Such a course will help bringing before court vital issues

of public interest which require urgent solutions,
converting the Judiciary into a machinery sensitive to
the injustice suffered by people and thus securing the
ends of distributive justice and participative democracy.
But, the biggest road-block obstructing the judiciary
against adopting a social justice oriented and liberal
attitude is the traditional concept of locus standi or
Page | 13
standing, which the courts are reluctant to discard even
today.

Page | 14
LOCUS STANDI

This concept prescribes that, unless a person has

suffered a direct injury or is aggrieved by the act he
proposes to challenge, his action is not maintainable in a
court of law. Thus, when an environmentalist
approaches a court with an environmental problem,
instead of considering the larger public interest, the
objects of environmental law, the need for distributive
justice and participative democracy, the court focuses its
attention on the identity of the person who brings the
action. The questions asked are: Who is he? Is he
personally affected? Has he sufficient personal interest in
the matter in issue?

Page | 15
EVOLUTION OF THE CONCEPT

Locus standi is a vintage doctrine. Its genesis is in the

Common Law of the laissez faire dominated England. The
king ruled the country, collected taxes, waged wars and
maintained a general order in society. The subjects were
left free in all their activities, provided they obeyed the
laws. In individual disputes alone conflicting parties
sought justice. The nature of litigation in courts in the
early days was essentially contractual. The rule of 'privity
of contract' governed the field.

The laissez faire philosophy left the individual absolutely

free and, freedom of contract was regarded as inviolable
and sacrosanct. The Soverign did not interfere with that
freedom except in very few cases opposed to public
policy.

With the advent of democracy, the centre of power

shifted from the king to the representatives of the people
elected and assembled in Parliament. They had to face
elections periodically. To ensure their re-election, it was
imperative for them to serve public interest. In their
Page | 16
endeavour to promote a Welfare State, the representative
institutions assumed more and more powers and welfare
legislations proliferated. This involved more and more
regulation of the citizens' freedom and conduct. Thus,
the man in the street began to come into constant
contact with the State in his everyday life. With its
spawning laws and increased power, the State frequently
infringed the rights of the individuals. This threw up a
new type of litigation with the citizen pitted against the
State.

Rule of Law required that every executive action should

be supported by law. Therefore, unlawful acts of the
State were questioned in courts. The question then arose
as to who could question such illegal State acts. The
courts answered that their legality could be challenged
only by a person adversely affected. Under the
circumstances, this was the only way in which the
executive powers could be accommodated. It was thus
that the concept of locus standi was evolved.

Standing or locus standi is the right of a person to sue or

to seek relief in a court of law, as distinguished from a

Page | 17
substantive right or interest possessed by him and which
is alleged to be infringed or endangered by a State action.
It is this factor that gives the litigant the personal
qualification to challenge an illegal administrative or
legislative act. Two principles have been held to underlie
the concept of locus standi.

1) The petitioner (litigant) himself must have a

grievance. He cannot base his claim on the grievance
of another person. But, this is not necessary in writs
of Habeas Corpus or Quo Warranto because personal
liberty and usurpation of public office are accepted
to be of general public concern.

2) No one can bring to court a purely acadmic dispute.

Some legal right or interest of the petitioner must be
infringed, threatened or clouded so that the
controversy which he raised in court should be
focussed on his individual grievance and interest, on
which the court can pronounce.

This traditional concept of locus standi was strictly

enforced and consistenly insisted upon by the courts in
Page | 18
India, England and the U.S.A. for a long time. Different
pronouncements regarding the personality of litigants
governed the field then. No concrete criteria could be
spelt out from these decisions to determine the locus
standi of a litigant beforehand. The courts used to insist
interchangeably on requirements like `legal right',
'special interest'," 'sufficient interest' and whether the
duty sought to be enforced is owed to him.

In India also, the situation was analogous. The

uncertainty in the law of standing can be best
demonstrated by referring to the cases where a
shareholder's locus standi was in issue. In Chiranjit Lal
v. Union of India" it was held that a fully paid-up
shareholder of a company had no locus standi to
challenge the taking over of the company by the State.
On the contrary, a preference share-holder was held to
have locus standi in Dwarakdas v. Sholapur Spinning
and Weaving Co." In the Bank Nationalisation Case," the
locus standi of a share-holder was recognised as
sufficient in as much as his right to receive dividend
from his investment had ceased. Following this decision,
shareholders of newspapers were held to have locus
standi to challenge

Page | 19
a law affecting newspapers in Bennet Coleman Co. v.
India. But, it is still not clear whether a fully paid-up
shareholder will have locus standi.

The trend to liberalise the principle of locus standi

started with the realisation by the Judiciary of the
pitfalls in insisting strictly on the traditional
requirements of locus standi. It was felt that locus standi
should not be reduced to a Procrustean bed. Public
interest litigation and legal aid movement also demanded
more relaxed standing rules. But, the liberalising trend
also has served to add to the confusion already existing
with regard to the concept. Two factors have created this
confusion.

Firstly, the relaxation of the requirements of standing

has proceeded exactly on the same lines on which the
strict rules were rigorously enforced. That is to say,
depending on the personality of the litigant. The
resultant confusion is the same as that prevailed before
the liberalising trend began. The court has only been
qualifying the persons who have locus standi. The only
difference is that it has been liberal in conferring locus

Page | 20
standi on more and more persons. This can be seen from
the decisions of the Supreme Court recognising the
standing of unrecognised trade unions, the legal
profession, 1aw teachers etc. Even now, our Supreme
Court asserts as a general rule that a total stranger
cannot enforce the fundamental rights of another person.
In cases where the affected party is in some way
disadvantaged, the court will allow a member of the
public acting bonafide, to espouse the cause of such
person or class of persons. So, not only that the
beneficiaries of the action should be socially
disadvantaged, but the litigant should be acting
bonafide. Such requirements as above are wholly
unnecessary and can breed only confusion and
uncertainty.

Secondly, the courts have been hopping back and forth

between the traditional and liberal requirements of
standing." To quote a recent example, in the Judges
Transfer case," the Supreme Court unanimously upheld
the liberal rules of locus standi. But, the conservative
attitude of the court surfaced soon, creating of
uncertainties in the future course of liberalisation of
locus standi.

Page | 21
In November, 1982, Mr. Sudeep Mazumdar, a
newspaperman invited the attention of the Supreme
Court, by a letter, to the injuries and accidental killings
of tribal’s in the largest ammunition testing range of the
army near Itarsy in Madhya Pradesh. People were dying
in large numbers, while collecting scrap from the
exploding shells. This was a typical situation where the
court should have been only eager to interfere. But,
strangely enough, the court framed a set of ten questions
on public interest litigation, doubting its legitimacy and
questioning the liberal approach to locus standi adopted
in earlier cases and, referred them to a Constitution
Bench for decision.

Both the factors mentioned above have created an

unsatisfactory situation. If public interest litigation is to
serve as a means to facilitate access to courts and to
render justice to the seven hundred million people of
India, then a change in judicial attitude in relation to the
concept of standing is absolutely essential. The
uncertainty that clouds the concept will discourage
prospective litigants from approaching the courts in

Page | 22
public interest, because, until his locus standi is upheld,
he would not know whether he can get relief. There are
innumerable classes of people in our society with varied
interests and to qualify them for locus standi on the
basis of identity of `person' would be impossible. For
example, a lawyer has locus standi to challenge transfer
of judges, but, can he challenge misappropriation of
funds by a municipality? Or should he be a rate-payer
too at the same time? Similarly, can the prospective
purchaser of a motor car challenge non-maintenance of
roads by the municipality? Or should he be a car-owner?
It is difficult to assess one way or the other.

The further question is, if roads are not maintained

properly, is it not in public interest that the
municipalities be compelled to do their duty. If so, does it
matter whether the litigant is a car owner, a prospective
car-owner or x, y, or z?

Page | 23
 CHAPTER -2
INTRODUCTION, CONCEPT, WRIT JURSIDICTION,
SUBJECTS OF PIL, JUDICAL PRONOUNCEMENTS,
SUMMARY OF CASES

INTRODUCTION

In general rule is that right to move to the court is right

whose fundamental right is violated. the supreme court
can only exercise the for the enforcement of fundamental
right under Art. 31 of the Indian constitution. In law,
standing orlocus standi is the term for the ability of a
party to demonstrate to the court in sufficient connection
to and harm from the law or action challenged to support
that party’s participation in the case. Otherwise, the
court will rule that the plaintiff “lacks standing” to bring
the suit and will dismiss the case without considering
the merits of the claim. But the public interest litigations
developed the concept of public interest standing which
is a form to widen the scope of the locus standi. Public
Interest litigation demanded for objectivity, forensic skill,
procedural gamesmanship and socio-legal perception.

Page | 24
The Constitution of India recognises as fundamental
rights many of the individual rights that comprises the
International Covenant on Civil and Political Right.These
include the right to life, to equality, to the freedom of
speech and expression and the right to seek judicial
redress before the Supreme Court and 21 High Courts of
India for enforcement and protection of these rights.

Though the Constitution of India guarantees equal rights

to all citizens, irrespective of race, gender, religion, and
other considerations, and the "directive principles of
state policy" as stated in the Constitution obligate the
Government to provide to all citizens a minimum
standard of living, the promise has not been fulfilled. The
greater majority of the Indian people have no assurance
of two nutritious meals a day, safety of employment, safe
and clean housing, or such level of education as would
make it possible for them to understand their
constitutional rights and obligations. Indian newspapers
abound in stories of the exploitation - by landlords,
factory owners, businessmen, and the state's own
functionaries, such as police and revenue officials - of
children, women, villagers, the poor, and the working
class.

Page | 25
Though India's higher courts and, in particular, the
Supreme Court have often been sensitive to the grim
social realities, and have on occasion given relief to the
oppressed, the poor do not have the capacity to represent
themselves, or to take advantage of progressive
legislation. In 1982, the Supreme Court conceded that
unusual measures were warranted to enable people the
full realization of not merely their civil and political
rights, but the enjoyment of economic, social, and
cultural rights, and in its far- reaching decision in the
case of PUDR [People's Union for Democratic Rights] vs.
Union of India , it recognised that a third party could
directly petition, whether through a letter or other
means, the Court and seek its intervention in a matter
where another party's fundamental rights were being
violated. In this case, adverting to the Constitutional
prohibition on "begar", or forced labor and traffic in
human beings, PUDR submitted that workers contracted
to build the large sports complex at the Asian Game
Village in Delhi were being exploited. PUDR asked the
Court to recognize that "begar" was far more than
compelling someone to work against his or her will, and
that work under exploitative and grotesquely humiliating
conditions, or work that was not even compensated by
Page | 26
prescribed minimum wages, was violative of fundamental
rights. As the Supreme Court noted, The rule of law does
not mean that the protection of the law must be available
only to a fortunate few or that the law should be allowed
to be prostituted by the vested interests for protecting
and upholding the status quo under the guise of
enforcement of their civil and political rights. The poor
too have civil and political rights and rule of law is meant
for them also, though today it exists only on paper and
not in reality. If the sugar barons and the alcohol kings
have the fundamental right to carry on their business
and to fatten their purses by exploiting the consuming
public, have the charmers belonging to the lowest strata
of society no fundamental right to earn an honest living
through their sweat and toil? Thus the court was willing
to acknowledge that it had a mandate to advance the
rights of the disadvantaged and poor, though this might
be at the behest of individuals or groups who themselves
claimed no disability. Such litigation, termed Public
Interest Litigation or SocialAction Litigation by its
foremost advocate, Professor Upendra Baxi, has given
the court "epistolary jurisdiction".

Page | 27
CONCEPT

According to the jurisprudence of Article 32 of the

Constitution of India, “The right to move the Supreme
Court by appropriate proceedings for the enforcement of
the rights conferred by this part is guaranteed”.
Ordinarily, only the aggrieved party has the right to seek
redress under Article 32. In 1981 Justice P. N. Bhagwati
in SP Gupta vs. Union of India1, articulated the concept
of PIL as follows, “Where a legal wrong or a legal injury is
caused to a person or to a determinate class of persons
by reason of violation of any constitutional or legal right
or any burden is imposed in contravention of any
constitutional or legal provision or without authority of
law or any such legal wrong or legal injury or illegal
burden is threatened and such person or determinate
class of persons by reasons of poverty, helplessness or
disability or socially or economically disadvantaged
position unable to approach the court for relief, any
member of public can maintain an application for an
appropriate direction, order or writ in the High Court
under Article 226 and in case any breach of fundamental
rights of such persons or determinate class of persons, in
this court under Article 32 seeking judicial redress for

Page | 28
the legal wrong or legal injury caused to such person or
determinate class of persons.”

The rule of locus standi have been relaxed and a person

acting bonafide and having sufficient interest in the
proceeding of Public Interest Litigation will alone have a
locus standi and can approach the court to wipe out
violation of fundamental rights and genuine infraction of
statutory provisions, but not for personal gain or private
profit or political motive or any oblique consideration.

The Supreme Court in Indian Banks’ Association,

Bombay and ors v. M/s Devkala Consultancy Service
and Ors ., held that “In an appropriate case, where the
petitioner might have moved a court in her private
interest and for redressal of the personal grievance, the
court in furtherance of Public Interest may treat it a
necessity to enquire into the state of affairs of the subject
of litigation in the interest of justice. Thus a private
interest case can also be treated as public interest case”.

Page | 29
In Guruvayur Devaswom Managing Commit. And Anr. v.
C.K. Rajan and Ors , the Supreme Court held, “The
Courts exercising their power of judicial review found to
its dismay that the poorest of the poor, depraved, the
illiterate, the urban and rural unorganized labour sector,
women, children, handicapped by 'ignorance, indigence
and illiteracy' and other down trodden have either no
access to justice or had been denied justice. A new
branch of proceedings known as 'Social Interest
Litigation' or 'Public Interest Litigation' was evolved with
a view to render complete justice to the aforementioned
classes of persona. It expanded its wings in course of
time. The Courts in pro bono public granted relief to the
inmates of the prisons, provided legal aid, directed
speedy trial, maintenance of human dignity and covered
several other areas. Representative actions, pro bono
publico and test litigations were entertained in keeping
with the current accent on justice to the common man
and a necessary disincentive to those who wish to by
pass the, real issues on the merits by suspect reliance on
peripheral procedural shortcomings… Pro bono publico
constituted a significant state in the present day judicial
system.

Page | 30
They, however, provided the dockets with much greater
responsibility for rendering the concept of justice
available to the disadvantaged sections of the society.
Public interest litigation has come to stay and its
necessity cannot be overemphasized. The courts evolved
a jurisprudence of compassion. Procedural propriety was
to move over giving place to substantive concerns of the
deprivation of rights. The rule of locus standi was
diluted. The Court in place of disinterested and
dispassionate adjudicator became active participant in
the dispensation of justice”.

Page | 31
WRIT JURISDICTION
(under Articles 32 and 226 of the Constitution of India,
1950)

The Writ Jurisdiction of Supreme Court can be invoked

under Article 32 of the Constitution for the violation of
fundamental rights guaranteed under Part – III of the
Constitution. Any provision in any Constitution for
Fundamental Rights is meaningless unless there are
adequate safeguards to ensure enforcement of such
provisions. Since the reality of such rights is tested only
through the judiciary, the safeguards assume even more
importance. In addition, enforcement also depends upon
the degree of independence of the Judiciary and the
availability of relevant instruments with the executive
authority. Indian Constitution, like most of Western
Constitutions, lays down certain provisions to ensure the
enforcement of Fundamental Rights. These are as under:

(a) The Fundamental Rights provided in the Indian

Constitution are guaranteed against any executive and
legislative actions. Any executive or legislative action,
which infringes upon the Fundamental Rights of any

Page | 32
person or any group of persons, can be declared as void
by the Courts under Article 13 of the Constitution.

(b) In addition, the Judiciary has the power to issue the

prerogative writs. These are the extra-ordinary remedies
provided to the citizens to get their rights enforced
against any authority in the State. These writs are -
Habeas corpus, Mandamus, Prohibition, Certiorari and
Quo-warranto. Both, High Courts as well as the Supreme
Court may issue the writs

(c) The Fundamental Rights provided to the citizens by

the Constitution cannot be suspended by the State,
except during the period of emergency, as laid down in
Article 359 of the Constitution. A Fundamental Right
may also be enforced by way of normal legal procedures
including a declaratory suit or by way of defence to legal
proceedings.

However, Article 32 is referred to as the "Constitutional

Remedy" for enforcement of Fundamental Rights. This
provision itself has been included in the Fundamental

Page | 33
Rights and hence it cannot be denied to any person. Dr.
B.R.Ambedkar described Article 32 as the most
important one, without which the Constitution would be
reduced to nullity. It is also referred to as the heart and
soul of the Constitution. By including Article 32 in the
Fundamental Rights, the Supreme Court has been made
the protector and guarantor of these Rights. An
application made under Article 32 of the Constitution
before the Supreme Court, cannot be refused on
technical grounds. In addition to the prescribed five
types of writs, the Supreme Court may pass any other
appropriate order. Moreover, only the questions
pertaining to the Fundamental Rights can be determined
in proceedings against Article 32. Under Article 32, the
Supreme Court may issue a Writ against any person or
government within the territory of India. Where the
infringement of a Fundamental Right has been
established, the Supreme Court cannot refuse relief on
the ground that the aggrieved person may have remedy
before some other court or under the ordinary law.

The relief can also not be denied on the ground that the
disputed facts have to be investigated or some evidence
has to be collected. Even if an aggrieved person has not

Page | 34
asked for a particular Writ, the Supreme Court, after
considering the facts and circumstances, may grant the
appropriate Writ and may even modify it to suit the
exigencies of the case. Normally, only the aggrieved
person is allowed to move the Court. But it has been held
by the Supreme Court that in social or public interest
matters, any one may move the Court. A Public Interest
Litigation can be filed before the Supreme Court under
Article 32 of the Constitution or before the High Court of
a State under Article 226 of the Constitution under their
respective Writ Jurisdictions. There are mainly five types
of Writs – (i) Writ of Habeaus Corpus, (ii) Writ of
Mandamus, (iii) Writ of Quo-Warranto, (iv) Writ of
Prohibition, and (v) Writ of Certiorari.

(I) Writ of Habeas Corpus:

It is the most valuable writ for personal liberty. Habeas

Corpus means, "Let us have the body." A person, when
arrested, can move the Court for the issue of Habeas
Corpus. It is an order by a Court to the detaining
authority to produce the arrested person before it so that
it may examine whether the person has been detained
lawfully or otherwise. If the Court is convinced that the

Page | 35
person is illegally detained, it can issue orders for his
release.

(II) The Writ of Mandamus:

Mandamus is a Latin word, which means "We

Command". Mandamus is an order from a superior court
to a lower court or tribunal or public authority to
perform an act, which falls within its duty. It is issued to
secure the performance of public duties and to enforce
private rights withheld by the public authorities. Simply,
it is a writ issued to a public official to do a thing which
is a part of his official duty, but, which, he has failed to
do, so far. This writ cannot be claimed as a matter of
right. It is the discretionary power of a court to issue
such writs.

(III) The Writ of Quo-Warranto:

The word Quo-Warranto literally means "by what

warrants?" It is a writ issued with a view to restraining a
person from acting in a public office to which he is not
entitled. The Writ of quo-warranto is used to prevent
illegal assumption of any public office or usurpation of

Page | 36
any public office by anybody. For example, a person of
62 years has been appointed to fill a public office
whereas the retirement age is 60 years. Now, the
appropriate High Court has a right to issue a Writ of
quowarranto against the person and declare the office
vacant.

(IV) The Writ of Prohibition:

Writ of prohibition means to forbid or to stop and it is

popularly known as 'Stay Order'. This Writ is issued
when a lower court or a body tries to transgress the
limits or powers vested in it. It is a Writ issued by a
superior court to lower court or a tribunal forbidding it to
perform an act outside its jurisdiction. After the issue of
this Writ proceedings in the lower court etc. come to a
stop. The Writ of prohibition is issued by any High Court
or the Supreme Court to any inferior court, prohibiting
the latter to continue proceedings in a particular case,
where it has no legal jurisdiction of trial. While the Writ
of mandamus commands doing of particular thing, the
Writ of prohibition is essentially addressed to a
subordinate court commanding inactivity. Writ of
prohibition is, thus, not available against a public officer
not vested with judicial or quasi-judicial powers. The
Page | 37
Supreme Court can issue this Writ only where a
fundamental right is affected.

(V) The Writ of Certiorari:

Literally, Certiorari means to be certified. The Writ of

Certiorari is issued by the Supreme Court to some
inferior court or tribunal to transfer the matter to it or to
some other superior authority for proper consideration.
The Writ of Certiorari can be issued by the Supreme
Court or any High Court for quashing the order already
passed by an inferior court. In other words, while the
prohibition is available at the earlier stage, Certiorari is
available on similar grounds at a later stage. It can also
be said that the Writ of prohibition is available during
the tendency of proceedings before a sub-ordinate court,
Certiorari can be resorted to only after the order or
decision has been announced. There are several
conditions necessary for the issue of Writ of Certiorari,
which are as under:

(a) There should be court, tribunal or an officer having

legal authority to determine the question of deciding
fundamental rights with a duty to act judicially..
Page | 38
(b) Such a court, tribunal or officer must have passed an
order acting without jurisdiction or in excess of the
judicial authority vested by law in such court, tribunal or
law. The order could also be against the principle of
natural justice or it could contain an error of judgment
in appreciating the facts of the case.

Page | 39
SUBJECTS OF PUBLIC INTEREST LITIGATION

Public Interest Litigation is meant for enforcement of

fundamental and other legal rights of the people who are
poor, weak, ignorant of legal redressal system or
otherwise in a disadvantageous position, due to their
social or economic background. Such litigation can be
initiated only for redressal of a public injury,
enforcement of a public duty or vindicating interest of
public nature. It is necessary that the petition is not filed
for personal gain or private motive or for other
extraneous consideration and is filed bona fide in public
interest. There are three basic requirement to file the
public interest litigation. They are:-

1. Personal Injury

2. Causation

3. Redressability

1. Injury:

The plaintiff must have suffered or imminently will suffer

injury- an invasion of a legally protected interest that is
concrete and particularized. The injury must be actual or

Page | 40
imminent, distinct and palpable, not abstract. This
injury could be economic as well as non-economic.

2. Causation: -

There must be a casual connection between the injury

and the conduct complained of, so that injury is fairly
traceable to the challenged action of the defendant and
not the result of the independent action of some third
party who is not before the court.

3. Redressability: -

It must be likely, as opposed to merely speculative, that

a favorable court decision will redress the injury.
Prudential Limitations of Locus Standi:- Additionally
there are three major prudential limitations or judicially
created standing principles. Those principles were
widened depending on the circumstances.

Page | 41
JUDICAL PRONOUNCEMENTS
(following are the considerations by the court on Locus
Standi)

Petitions received by post even though not in public

interest can be treated as writ petitions if so directed by
the Hon’ble Judge nominated for this purpose. Individual
petitions complaining harassment or torture or death in
jail or by police, complaints of atrocities on women such
as harassment for dowry, bride burning, rape, murder
and kidnapping, complaints relating to family pensions
and complaints of refusal by police to register the case
can be registered as writ petitions, if so approved by the
concerned Hon’ble Judge. If deemed expedient, a report
from the concerned authority is called before placing the
matter before the Hon’ble Judge for directions. If so
directed by the Hon’ble Judge, the letter is registered as
a writ petition and is there after listed before the Court
for hearing. But this traditional rule was considerably
relaxed by the Supreme Court in its recent rulings:

Page | 42
1) Any person

Peoples Union for Democratic Rights v. Union of India

The court now permits Public Interest Litigation or Social

Interest Litigation at the instance of " Public spirited
citizens" for the enforcement of constitutional & legal
rights of any person or group of persons who because of
their socially or economically disadvantaged position are
unable to approach court for relief. Public interest
litigation is a part of the process of participate justice
and standing in civil litigation of that pattern must have
liberal reception at the judicial door steps.

In the Judges Transfer Case

Court held Public Interest Litigation can be filed by any

member of public having sufficient interest for public
injury arising from violation of legal rights so as to get
judicial redress. This is absolutely necessary for
maintaining Rule of law and accelerating the balance
between law and justice. It is a settled law that when a
person approaches the court of equity in exercise of
extraordinary jurisdiction, he should approach the court
not only with clean hands but with clean mind, heart
and with clean objectives.
Page | 43
Shiram Food & Fertilizer case

Through Public Interest Litigation directed the Co.

Manufacturing hazardous & lethal chemical and gases
posing danger to life and health of workmen & to take all
necessary safety measures before reopening the plant.

In the case of M.C Mehta V. Union of India

In a Public Interest Litigation brought against Ganga

water pollution so as to prevent any further pollution of
Ganga water. Supreme court held that petitioner
although not a riparian owner is entitled to move the
court for the enforcement of statutory provisions , as he
is the person interested in protecting the lives of the
people who make use of Ganga water.

Parmanand Katara V. Union of India

Supreme Court held in the Public Interest Litigation filed

by a human right activist fighting for general public
interest that it is a paramount obligation of every
member of medical profession to give medical aid to every
injured citizen as soon as possible without waiting for
any procedural formalities.

Page | 44
2) Voluntary organisation

Council For Environment Legal Action V. Union Of

India :

Public Interest Litigation filed by registered voluntary

organization regarding economic degradation in coastal
area. Supreme Court issued appropriate orders and
directions for enforcing the laws to protect ecology.

3) Report of research paper or newspaper

A report entitled "Treat Prisoners Equally HC" published

in The Tribe , Aug 23 Punjab & Haryana High Court
quashed the provisions of jail manual dividing prisoners
into A , B & C classes after holding that there cannot be
any classification of convicts on the basis of their social
status, education or habit of living .This is a remarkable
ruling given by High Court by declaring 576-A paragraph
of the manual to be " Unconstitutional".

During the last few years, Judicial Activism has opened

up a new dimension for the Judicial process and has
given a new hope to the millions who starve for their
livelihood. There is no reason why the Court should not

Page | 45
adopt activist approach similar to Court in America , so
as to provide remedial amplitude to the citizens of India.

Supreme Court has now realised its proper role in

welfare state and it is using its new strategy for the
development of a whole new corpus of law for effective
and purposeful implementation of Public Interest
Litigation. One can simply approach to the Court for the
enforcement of fundamental rights by writing a letter or
post card to any Judge. That particular letters based on
true facts and concept will be converted to writ petition.
When Court welcome Public Interest Litigation , its
attempt is to endure observance of social and economic
programmers frame for the benefits of have-nots and the
handicapped. Public Interest Litigation has proved a
boon for the common men. Public Interest Litigation has
set right a number of wrongs committed by an individual
or by society. By relaxing the scope of Public Interest
Litigation, Court has brought legal aid at the doorsteps of
the teeming millions of Indians; which the executive has
not been able to do despite a lot of money is being spent
on new legal aid schemes operating at the central and
state level. Supreme Court's pivotal role in expanding the
scope of Public Interest Litigation as a counter balance to

Page | 46
the lethargy and inefficiency of the executive is
commendable

Page | 47
SUMMARY OF CASES
(Important Subjects in PIL from the above Judicial
Pronouncements)

1) Worker’s exploitation, resultant of payment less then

minimum wages to the workers.

2) Under trial Prisoners, The Indian Express exposing the

plight of Bihar under trial prisoners. This under trial
prisoners were behind the bar from last ten years and
violating there right to speedy trial.

3) Dehumanized Case, most of the time the police

atrocity causes damage to the persons’ health and
reputation,

a) Apex Court direction to provide medical aid to

police’s blinded victims.

b) Death of a person due to police atrocity provided the

compensation amount.

Page | 48
4) Eviction of Gudalur farmers

Persons who had for many years cultivated the land were
sought to be summarily evicted without adhering to
principles of Natural Justice. The case considered
sympathetically and provided, the farmers provided on
the compassionate ground.

5) Child welfare

Release of children below the 16 years of age and giving

separate treatment to the under-trial juvenile offenders.

6) Women Atrocity

There is more cases of the Women atrocities in the

Nation and PIL Guideline provided to the police officer to
launch the cases.

a) In cases of the gang rape Police officer guideline

provided to file the cases.

Page | 49
 b) Custodian violence to the Women Ill-treatment and
custodian violence to the women prisoners in the
police lockup.

7) Environmental Cases

a) In order to tackle the problem of water pollution

Ganga river case the Supreme Court order to close
down industries which damage the Ganges river by
water pollution.

b) In order to tackle the Air pollution Court order that

limestone quarries in the Mussoories Hills range to
save the ecology of the Himilayan region and avoid
hazard to public health.

Page | 50
 CHAPTER -3
PUBLIC INTEREST LITIGATION
AND JUDICAL ACTIVISM

PIL AND JUDICAL ACTIVISM

Public interest litigation or social interest litigation today

has great significance and drew the attention of all
concerned.

The traditional rule of “Locus Standi” that a person,

whose right is infringed alone can file a petition, has
been considerably relaxed by the Supreme Court in its
recent decisions. Now, the court permits public interest
litigation at the instance of public spirited citizens for the
enforcement of constitutional o- legal rights. Now, any
public spirited citizen can move/approach the court for
the public cause (in the interests of the public or public
welfare) by filing a petition:

1) in Supreme Court under Art.32 of the Constitution;

2) in High Court under Art.226 of the Constitution;
and
3) in the Court of Magistrate under Sec.133, Cr. P.C.

Justice Krishna layer fertilizer Corporation Kamgar

Union vs. Union of India, (1981) enumerated the

Page | 51
following reasons for liberalization of the rule of Locus
Standi:-

1) Exercise of State power to eradicate corruption may

result in unrelated interference with individuals’
rights.
2) Social justice warrants liberal judicial review
administrative action.
3) Restrictive rules of standing are antithesis to a
healthy system of administrative action.
4) “Activism is essential for participative public
justice”.

Therefore, a public minded citizen must be given an

opportunity to move the court in the interests of the
public.

In order to ensure that Fundamental Rights did not

remain empty declarations, the founding fathers made
various provisions in the Constitution to establish an
independent judiciary.

Provisions related to Fundamental Rights, Directive

Principles and independent judiciary together provided a
firm constitutional foundation to the evolution of PIL in
India. The founding fathers envisaged ‘‘the judiciary as a
bastion of rights and justice’’. An independent judiciary

Page | 52
armed with the power of judicial review was the
constitutional device chosen to achieve this objective.
The power to enforce the FRs was conferred on both the
Supreme Court and the High Courts—the courts that
have entertained all the PIL cases.

STRENGHTS

1) In Public Interest Litigation (PIL) vigilant citizens of

the country can find an inexpensive legal remedy
because there is only a nominal fixed court fee
involved in this.

2) Further, through the so-called PIL, the litigants can

focus attention on and achieve results pertaining to
larger public issues, especially in the fields of
human rights, consumer welfare and environment.

WEAKNESSES

1) The genuine causes and cases of public interest

have in fact receded to the background and
irresponsible PIL activists all over the country have
started to play a major but not a constructive role in
the arena of litigation. Of late, many of the PIL
activists in the country have found the PIL as a
Page | 53
 handy tool of harassment since frivolous cases could
be filed without investment of heavy court fees as
required in private civil litigation and deals could
then be negotiated with the victims of stay orders
obtained in the so-called PILs.

2) The framers of Indian constitution did not

incorporate a strict doctrine of separation of powers
but envisaged a system of checks and balances.
Policy making and implementation of policy are
conventionally regarding as the exclusive domain of
the executive and the legislature. Vishakha v State
of Rajasthan which was a PIL concerning sexual
harassment of women at work place. The court
declared that till the legislature enacted a law
consistent with the convention on the Elimination of
All Forms of Discrimination Against Women which
India was a signatory, the guidelines set out by the
court would be enforceable.

3) The flexibility of procedure that is a character of PIL

has given rise to another set of problems. It gives an
opportunity to opposite parties to ascertain the
precise allegation and respond specific issues.

Page | 54
4) The credibility of PIL process is now adversely
affected by the criticism that the judiciary is
overstepping the boundaries pf its jurisdiction and
that it is unable to

5) Supervise the effective implementation of its orders.

It has also been increasingly felt that PIL is being
misused by the people agitating for private grievance
in the grab of public interest and seeking publicity
rather than espousing public cause.

Page | 55
Steps Necessary To Stop Abuse

With the view to regulate the abuse of PIL the apex court
itself has framed certain guidelines (to govern the
management and disposal of PILs.) The court must be
careful to see that the petitioner who approaches it is
acting bona fide and not for personal gain, private profit
or political or other oblique considerations. The court
should not allow its process to be abused by politicians
and others to delay legitimate administrative action or to
gain political objectives. There may be cases where the
PIL may affect the right of persons not before the court,
and therefore in shaping the relief the court must
invariably take into account its impact on those interests
and the court must exercise greatest caution and adopt
procedure ensuring sufficient notice to all interests likely
to be affected.

At present, the court can treat a letter as a writ petition

and take action upon it. But, it is not every letter which
may be treated as a writ petition by the court. The court
would be justified in treating the letter as a writ petition
only in the following cases-

(i) It is only where the letter is addressed by an aggrieved

person or

Page | 56
(ii) a public spirited individual or

(iii) a social action group for enforcement of the

constitutional or the legal rights of a person in custody
or of a class or group of persons who by reason of
poverty, disability or socially or economically
disadvantaged position find it difficult to approach the
court for redress.

Even though it is very much essential to curb the misuse

and abuse of PIL, any move by the government to
regulate the PIL results in widespread protests from
those who are not aware of its abuse and equate any
form of regulation with erosion of their fundamental
rights. Under these circumstances the Supreme Court Of
India is required to step in by incorporating safe guards
provided by the civil procedure code in matters of stay
orders /injunctions in the arena of PIL.

Page | 57
 CHAPTER -4
PROPOSALS AND CONCLUSION

PROPOSALS

It is submitted that, the identity of the litigant is

immaterial in deciding the merits of the case. In the
same way, the motive or intention of the litigant is also
immaterial. He may be a publicity-monger, a professional
litigant or a busy-body. If his allegations are true and
made in public interest, he should be heard.

In England, even when the strict rules of locus standi

held sway, there was a device for vindicating public
interest, namely, Relator Actions. The Attorney-General
used to represent public interest. He, by lending his
name to a private action, could convert it into an action
in public interest. In U.S.A., the administrative agencies
were forums for representing public interest. But, in
India, we had no such means to enforce public interest
without the constraints of locus standi. The Supreme
Court of India held that relator action is not possible in
India as in England because the Attorney General of
India and Advocate General of States are not the
Page | 58
guardians of public interest. But, now that we have
evolved the mechanism of public interest litigation, we
have a forum for representing public interest effectively.

The objective of public interest litigation outlined earlier

delineates the role that this device can play in our
contemporary society. This mode of litigation should
exist as a means whereby public interest could be
enforced. Here, the identity of the person should not be
material. What should be, is the public interest. This
field should be a 'no locus standi zone'. Therefore, any
person who comes before the court seeking to vindicate
public interest should be heard. He need only show that
his action is a public interest litigation. This criterion of
'public interest' would also give the courts enough leeway
to exclude frivolous litigation, And, this criterion would
be more meaningful and conducive to the ends of public
interest litigation than enquiring into the identity of the
litigant and his personal qualification.

Public interest litigation is a very potent instrument

which can serve as the means of rendering justice within
the existing framework of our legal system. Its relevance

Page | 59
in a hierarchical, caste-ridden, economically and socially
backward society like ours, is beyond question.
Particularly so, in a decadent, colonial jurisprudence in
which there is still no awareness and initiative for legal
and judicial reforms. Therefore, it is necessary to enlarge
the scope of, and to streamline, this new device so as to
make it effectively serve the inarticulate masses of our
people. It is time that the doctrine of locus standi is given
a decent burial by the Supreme Court in relation to
public interest litigation.

Page | 60
CONCLUSION

Public interest litigation is social litigation that provided

remedies for all, locus standi is concept evolved from
America, locus standi means standing before the court or
file case before the court. This PIL concept is concept of
locus standi that whole society not standing before court
but the some social worker or jurist file before court on
behalf of public or society, so locus standi is concept
evolved from public interest litigation, which is changing
there dimension and concept in broad. Some time latter
are consider to be the PIL likewise Newspaper report in
the Hussainera Khatoon Case research material of the
jurist or student other thing which the Hon’ble judge
consider the source of the public interest. so the medium
through which the court are consider the matter are
public interest litigation and stand before the court. The
liberalization of the principle of locus standi make
possible for the court to recognize a general interest in
any litigant on a matter as sufficient to have locus
standi. So the concept of individual interest, changed to
special interest, again to class interest and now to
sufficient interest.

Page | 61
There is no special person required to the file the case
locus standi in this cases are the report which the court
are get matter to consider the case as public interest
litigation.

Public Interest Litigants, all over the country, have not

taken very kindly to such court decisions. They do fear
that this will sound the death-knell of the people friendly
concept of PIL. However, bona fide litigants of India have
nothing to fear. Only those PIL activists who prefer to file
frivolous complaints will have to pay compensation to
then opposite parties. It is actually a welcome move
because no one in the country can deny that even PIL
activists should be responsible and accountable. In any
way, PIL now does require a complete rethink and
restructuring. Anyway, overuse and abuse of PIL can
only make it stale and ineffective. Since it is an
extraordinary remedy available at a cheaper cost to all
citizens of the country, it ought not to be used by all
litigants as a substitute for ordinary ones or as a means
to file frivolous complaints.

Page | 62
 BIBILOGRAPHY

1. Public Interest Litigation A hand Book by Dr. B L

Wadhera Second Edition Universal Law Publishing
co.

2. The Oxford Handbook of the Indian Constitution

Edited by Sujit Choudhry, Madhav Khosla, and
Pratap Bhanu Mehta

3. Public Interest Litigation in India: A Renaissance in

Social Justice by Mamta Rao

4. Public Interest Litigation Legal Aid and Lok Adalats

by Mamta Rao Edition: 5th Edition, 2018

5. Public Interest Litigation – 2018 by Justice P.S.

Narayana

6. Law Relating to Public Interest Litigation by

Chakraborty

7. Locus Standi and Judicial... by S. M. Thio

8. German law on standing to sue by Eckard Rehbinder

9. Standing Up for Your Right(s) in Europe by Mariolina

Eliantonio, Chris Backes

Page | 63
10. The Admissibility of Human Rights Petitions by
Tom Zwart

11. Widening the rules of LOCUS STANDI by R.S.

Gupta Published by: Indian Law Institute

Page | 64
 INTERNET /WEB RESOURCES

1. www.legalservicesindia.com

2. www.shareyouressays.com

3. www.scribd.com

4. www.lawyersclubindia.com

5. www.Manupatra.com

6. www.indiakanoon.com

7. www.scconline.com

8. www.wikipedia.com

9. www.sscrn.com

10. www.articlesbase.com

11. www.livelaw.in

12. barandbench.com

Page | 65
 An old man walks up
to the King pleading to
save the city from an
ever expanding river
and pledges the
savings of his lifetime.
Baimundi, the
foremost of public
interest litigants will
always remain as a
brightest ray of
inspiration for
generations to come.

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