1

THE CULTURE OF PUBLIC INTEREST LITIGATION IN INDIA

The aim of this article is to analyse the cachet and efficaciousness of the instrument
of Public Interest Litigation (PIL) in India. At the same time an attempt is made to
evaluate the sociological aspect of the PIL in India. The article further vocalizes the
scope and nature of PIL in India. The article assumes significance as the reservation
issue is pending before the Hon’ble Supreme Court of India which can declare the
reservation policy of the Government as Unconstitutional.

I. Introduction

The Constitution of India is not intended to be the arena of legal quibbling for men with
long purses. It is made for the common people. It should generally be so construed as that
they can understand and appreciate it. The more they understand it the more they love it
and the more they prize it. It is really the poor, starved and mindless millions who need
the court’s protection for securing to themselves the enjoyment of Human Rights[1]. The
Constitution precedents cannot be permitted to be transformed into weapons for defeating
the hopes and aspirations of our teaming millions, half-clad, half-starved, half-educated.
These hopes and aspirations representing the will of the people can only become
articulate through the voice of their elected representatives. If they fail the people, the
nation must face the death and destruction. Then, neither the court nor the Constitution
will save the country[2]. This line of thinking has been now recognised and adopted by
various social reformers, lawyers, judges and social workers. Even, general public now
knows that the court has constitutional power of intervention, which can be invoked to
ameliorate their miseries arising from repression, governmental lawlessness and
administrative deviance[3]. The socio-justice tool through which these aspirations of the
Constitution and people of India are achieved is known as “Public Interest Litigation”
(PIL). Before proceeding further, it would be appropriate to appreciate the meaning of the
expression PIL. A matter of “public interest” does not mean that which is interesting or
gratifying curiosity or a love of information or amusement but that in which a class or
community have a pecuniary interest or some interest by which their legal rights or
liabilities are affected[4]. The expression “public interest” or “probity in governance”
cannot be put in a straightjacket. Public interest takes into fold several factors. There
cannot be any hard and fast rule to determine whether government action was taken in
public interest or was taken to uphold probity in governance. The role model for
governance and decision taken thereof should manifest equity, fair play and justice. The
cardinal principle of governance in a civilised society based on rule of law not only has to
base on transparency but also must create an impression that the decision-making was
motivated on the consideration of probity[5]. The expression “litigation” means a legal
action including all proceedings therein, initiated in a court of law with the purpose of
enforcing a right or seeking a remedy. Therefore, lexically the expression PIL means a
legal action initiated in a court of law for the enforcement of public interest or general
interest in which the public or a class of the community have pecuniary interest or some
interest by which their legal rights and liabilities are affected[6].
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II. Evolution of PIL

The legal movement, which has resulted in the shaping of PIL in India, has been
influenced stalwartly by the benign movement in U.S.A. The “Council for Public Interest
Law” set up by the “Ford Foundation” in the U.S.A defined public interest law as
follows: “Public interest law is the name that has recently been given to efforts to provide
legal representation to previously non-represented groups and interests. Such efforts have
been undertaken in the recognition that the ordinary market place for legal services fails
to provide such services to significant segments of the population and to significant
interests. Such groups and interests include the poor, environmentalists, consumers, racial
and ethnic minorities and others. It was born out of the need of a large number of people
who individually lacked the economic resources or operational capacity to vindicate
important social values and their own specific interest through court”. In India, the courts
exercising their power of judicial review found to its dismay that the poorest of the poor,
depraved, the illiterate, women, children and other downtrodden have either no to justice
or had been denied justice. A new branch of litigation known as PIL was evolved with a
view to render complete justice to the aforesaid classes of persons. It expanded its wings
in course of time. The courts granted relief to the inmates of the prisons, provided legal
aid, directed speedy trial, maintenance of human dignity and covered several other areas.
The court has intervened when there had been callous neglect as a policy of the State, a
lack of probity in public life, abuse of power in control and destruction of environment.
The court interferes and gives appropriate directions when there has been an element of
violation of Art1cle 21 or of Human Rights or where the litigation has been initiated for
the benefit of the poor and the underprivileged that are unable to come to the court due to
some disadvantage[7].

The evolution of PIL in India has an interesting background. In the famous case of
Kesavananda Bharati v State of Kerala[8] the Supreme Court ultimately put a brake on
the arbitrary and unreasonable power of legislature to destroy the “Basic features” of the
Constitution. Thus, the seeds of PIL could never have been planted had the Supreme
Court not brought justness and fairness in the “Indian Legal System” in the year1973, by
formulating the “Doctrine of Basic Structure”. Justice Krishna Iyer sowed the seeds of
the new dispensation in Mumbai Kamgar Sabha v Abdulbhai Faizullabhai[9] and
used the expression PIL and “ epistolary jurisdiction” in Fertilizer Corporation
Kamgar Union v U.O.I[10]. In between, the Supreme Court interpreted the expression
“procedure established by law” as a procedure which must be just, fair and reasonable in
the year 1978[11]. This led to the testing of any “law” on the touchstone of Articles 14,
19 and 21 collectively and thus brought justness and fairness in the State’s dealing with
the general public. The Supreme Court in the year 1993 declared “independence of
judiciary” a “basic feature” and acquired autonomy in the selection and appointment of
judges[12]. This made the interference of “Executive” in the appointment of judges a
forgotten practice and made the judges more free and impartial to render justice. In the
year 1993 the Supreme Court held that judicial review U/A 32 and 226 is a basic feature
of the Constitution, which is beyond the pale of amendability[13]. Thus, the discretion to
entertain a dispute or petition was reserved exclusively with the judiciary. This was a
landmark judgment since all the PILs are either filed U/A 226 or U/A 32. This means that
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the discretion to entertain a PIL itself can be considered to be a part of basic feature and
the only limitation could be the self-imposed restriction by the court itself. To supplement
all this, the collective powers of Articles 32, 136, 141 and 142 made the Indian Supreme
Court one of the most powerful court of the world.

The courts in India found that the oppression of the weaker and disadvantaged groups
was considerably greater in India as compared to U.S.A. The political and legislative
sensitivity was also missing. The Supreme Court was left with no choice but to assume a
much more concerned guardian and protector of Fundamental Rights. The resources in
India were always claimed to be limited, hence the financing of legal aid programme for
giving a boost to PIL was ignored by the government as much as possible. This led to the
relaxing of the requirement of “procedures” and “locus standi” by the Supreme Court.
The court treated even a simple letter as a PIL. Since the coffers of the State were not
burdened by this practice, the “Executive” did not object to the growth of PIL as a
measure for emancipation of the poor and the weaker sections. Even the public at large
supported the PIL drive. It is interesting to note that the tool of PIL proved to be a grand
success in India as compared to its counterpart in U.S.A. This may be because the
strategy for giving the poor and oppressed meaningful access to justice is not, as in the
U.S.A, to provide funds so that they may participate in the traditional system on an equal
economic footing. Instead the strategy is to change the system. Thus, volunteer social
activists are allowed standing; a simple letter can be accepted as a writ petition, the court
itself will shoulder much of the burden of establishing the facts through the commissions,
and whenever possible the case will move swiftly to the issue of remedy, by-passing the
time-consuming and costly process. The substantial accomplishments of Indian PIL
surely prove that it is a development worthy of the most serious consideration by jurists,
lawyers and judges from all societies, and particularly from the United States where the
parallel and contrasts are so striking[14].

III. Scope of PIL in India

The scope of PIL, reflecting its sociology, is very wide which is clear from the following
principles:

(1) The court in exercise of powers U/A 32 or 226 of the Constitution of India can
entertain a petition filed by any interested person in the welfare of the people who are in a
disadvantaged position and, thus, not in a position to knock the doors of the court. The
court is constitutionally bound to protect the Fundamental Rights of such disadvantaged
people so as to direct the state to fulfill its constitutional promises.
(2) Issues of public enforcement, enforcement of fundamental rights of large number of
public vis-a-vis the constitutional duties and functions of the state, if raised, the court
treat a letter or a telegram as a PIL upon relaxing the procedural laws as also the law
relating pleadings.
(3) Whenever injustice is meted out to a large number of people, the court will not
hesitate to step in. Articles 14 and 21 of the Constitution of India as well as the
International Convention on Human Rights provide for a reasonable and fair trial.
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(4) The common rule of locus standi is relaxed so as to enable the court to look into the
grievances complained on behalf of the poor, deprived, illiterate and the disabled who
cannot vindicate the legal wrong or legal injury caused to them for any violation of any
constitutional or legal right.
(5) When the court is prima facie satisfied about variation of any constitutional right of a
group of people belonging to the disadvantaged category, it may not allow the State or
the government from raising the question as to the maintainability of the petition.
(6) Although procedural laws apply to PIL cases but the question as to whether the
principles of res judicata or provisions analogous thereto would apply depend on the
nature of the petition as also facts and circumstances of the case.
(7) The dispute between two warring groups purely in the realm of private law would not
be allowed to be agitated as a PIL.
(8) However, in an appropriate case, although the petitioner might have moved a court in
his private interest and for redressal of the personal grievances, the courting furtherance
of the public interest may treat it necessary to enquire into the state of affairs of the
subject of litigation in the interest of justice.
(9) The court in special situations may appoint commission, or other bodies for the
purpose of investigating into the allegations and finding out facts. The court will not
ordinarily transgress into policy.
(10) The courts would ordinarily not step out of the known areas of judicial review. The
High Courts although may pass an order for doing complete justice to the parties, it does
not have a power akin to Article 142 of the Constitution of India.
(11) Ordinarily the High Court should not entertain a writ petition by way of PIL
questioning constitutionality or validity of a statute or a statutory rule[15].

The sociology of PIL makes it clear that through this mechanism the courts seeked to
protect Human Rights and Fundamental Rights in the following ways:
(1) By creating a new regime of Human Rights by expanding the meaning of
Fundamental Rights to equality, life and personal liberty. In this process right to speedy
trial, free legal aid, dignity, means of livelihood, education, housing, medical care, clean
environment, etc emerged as Human rights. These new reconceptualised rights provide
legal resources to activate the courts for their enforcement.
(2) By democratization of access to justice. This has been done by relaxing the traditional
rule of locus standi. Any public-spirited citizen or social action group can approach the
court on behalf of the oppressed classes. Court’s attention can be drawn even by writing a
letter or sending a telegram. This has been called “epistolary jurisdiction”.
(3) By fashioning new kinds of reliefs under the court’s writ jurisdiction.
(4) By judicial monitoring of State institutions such as jails, women’s protective homes,
juvenile homes, mental asylums, and the like. Through judicial invigilation, the court
seeks gradual improvement in their management and administration. This has been
characterized as creeping jurisdiction in which the court takes over the administration of
these institutions for protecting Human Rights.
(5) By devising new techniques of fact finding. In most of the cases the court has
appointed its own socio-legal commissions of inquiry or has deputed its own officials for
investigations. Sometimes it has taken the help of National Human Rights Commission or
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Central Bureau of Investigation or experts to inquire into Human Rights violations. This
may be called investigative litigation[16].

The court may face the following challenges of the social-justice mandate, which they are
competent to tackle:
(1) The expanded role of the judges in modern social state and the new demands for
judicial responsibility.
(2) The rise and growth of varied system of judicial review and legitimacy of such
growth.
(3) The emergence of the notion of “access to justice” as a judicial answer to egalitarian
ideals and demands for effectiveness, and the development of PIL.
(4) The role of the courts in promoting its legal system in terms of PIL[17].
These challenges can be effectively met if we select an appropriate locus standi strategy,
which advances the cause of social justice.

IV. Social justice and locus standi

The social justice requirement of India mandates that the concept of locus standi should
be treated with a pragmatic approach. The present socio, economic and political
conditions of India requires a “liberal locus standi” policy. Thus, PIL should be
entertained as much as possible, by diluting the concept of locus standi. It must be noted
that the right to move the Supreme Court U/A 32 itself is a Fundamental Right, which
along with Article 226 has acquired a status of basic feature. The concept of PIL must be
looked in the light of the judicial review power of the Supreme Court and the High Court
in India, which is also a basic feature of the Constitution. This means that whenever a
violation of any Fundamental Right is seeked to be protected either U/A 226 or U/A 32,
the courts are “duty bound” to take note of the same. The doctrine of basic structure is not
meant for “executive” or “legislature” alone but it equally binds the courts to exercise
their power of judicial review wherever the situation demands so. If enforcement of
Fundamental Right U/A 32 were refused by the Supreme Court, then the whole purpose
of providing the Fundamental Rights under Part III would become futile. Thus, the
doctrine of basic structure takes away the “discretion” of the High Courts and the
Supreme Court to refuse to entertain a PIL, except in cases of abuse of process of law or
abuse of process of court.

Some people discourage the expanded role of PIL by arguing that the PIL are
overburdening the already overburdened courts. The fallacy of this argument is apparent
and it suffers from at least two weaknesses. Firstly, the problem of overburdening is an
“administrative” problem whereas the rights sought to be enforced are Constitutional and
legal in nature. It is difficult to appreciate how the sacrosanct Fundamental Rights and
Human Rights can be brushed aside simply on the basis of a hyper-technical
“administrative argument”. Even if we prohibit the entertainment of PIL absolutely, it
will not solve the problem of overburdening of courts. The problem of overburdening of
the courts can be solved only by adopting a positive attitude by the judges and lawyers
and it has no relationship whatsoever with the benevolent concept known as PIL. It must
be appreciated that two wrongs cannot make a thing right. Thus, the overburdening of
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courts cannot be lessened by limited use of PIL. The solution lies in administrative
efficiency and not in curbing the essentially required PILs. Secondly, the doctrine of
basic structure and the socio-economic conditions of India obligates the Constitutional
courts to liberally use the tool of PIL. If we look back at the past what would have been
India had the tool of PIL not been used by the courts in India. In any case, the
maintainability of a writ petition which is correlated to the existence and violation of a
Fundamental Right is not always to be confused with the locus to bring a proceeding
under Article 32. These two matters often mingle and coalesce with the result that it
becomes difficult to consider them in watertight compartments. The question whether a
person has the locus to file a proceeding depends mostly and often on whether he
possesses a legal right and that right is violated. But, in an appropriate case, it may
become necessary in the changing awareness of legal rights and social obligations to take
a broader view of the question of locus to initiate a proceeding be it under Article 226 or
under Article 32 of the Constitution. If public property is dissipated, it would require a
strong argument to convince the Court that representative segments of the public or at
least a section of the public which is directly interested and affected would have no right
to complain of the infraction of public duties and obligations. The civil remedies for
administrative wrongdoing thus depend upon the action of individual citizens. In such an
action, the individual is pitted against the State-always an unequal contest. The individual
does not have even the few procedural devices that the common law imports into criminal
actions to try to redress the balance. At his own expense, he must challenge the vast
panoply of State power with all its resources in personnel, money, and legal talent, by a
civil action for a declaratory judgment or for an extraordinary remedy-injunction, writ of
mandamus, or writ of prohibition. Aside from the manifold technical insufficiencies of
these forms of action, the financial impediments to such an action are staggering. In
simple terms, locus standi must be liberalized to meet the challenges of the times. Ubi
just ibi remedium must be enlarged to embrace all interests of public-minded citizens or
organisations with serious concern for conservation of public resources and the direction
and correction of public power so as to promote justice in its triune facets .Law is a social
auditor and this audit function can be put into action only when some one with real public
interest ignites the jurisdiction. We cannot be scared by the fear that all and sundry will
be litigation-happy and waste their time and money and the time of the court through
false and frivolous cases. In a society where freedoms suffer from atrophy and activism is
essential for participative public justice. Some risks have to be taken and more
opportunities opened for the public-minded citizen to rely on the legal process and not be
repelled from it by narrow pedantry now surrounding locus standi. Public interest
litigation is part of the process of participate justice and 'standing' in Civilization of that
pattern must have liberal reception at the judicial doorsteps. If the courts cannot, or will
not, give relief to people who' are in fact concerned about a matter then they will resort to
self-help, with grave results for other persons and the rule of law. Some may reply that if
there is no evidence of a great increase in numbers there is no evidence of need for
enlarged standing rights. The reply would overlook two considerations. One case may
have a dramatic effect on behaviour in hundreds of others; this is the whole notion of the
legal 'test case'. Secondly, the mere exposure to possible action is likely to affect the
behaviour of persons who presently feel themselves immune from legal control[18]. It is
of utmost importance that those who invokes this court's jurisdiction seeking a waiver of
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locus standi rule must exercise restraint in moving the court by not plunging into areas
wherein they are not well versed. Besides, it must be remembered that a good cause can
be lost if petitions are filed on half -baked information without proper research or by
persons who are not qualified or competent to raise such issues as the rejection of such a
petition may affect the third party's rights. Lastly, it must also be borne in mind that no
one has a right to the waiver of the locus standi rule and the court should permit it only
when it is; satisfied that the carriage of proceedings is in the competent hands of a person
who is genuinely concerned in public interest and is not moved by other extraneous
considerations[19]. It must be noted that even where a writ petition has been held to be
not entertainable on the ground or otherwise of lack of locus, the court in larger public
interest has entertained a writ petition. In an appropriate case, where the petitioner might
have moved a Court in his private interest and for redressal of the personal grievance, the
Court in furtherance of e-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[20].

V. Abuse of PIL

PIL is a weapon, which has to be used with great care and circumspection, and the
judiciary has to be extremely careful to see that behind the beautiful veil of public
interest, an ugly private malice, vested interest and/or publicity seeking is not lurking. It
is to be used as an effective weapon in the armory of law for delivering social justice to
citizens. The court must not allow its process to be abused for oblique considerations.
The petition of such persons should be thrown out at the threshold and in appropriate
cases exemplary costs should be imposed. PIL cannot be invoked by a person or body of
persons to satisfy his or its personal grudge and enmity. If such petitions U/A 32 were
entertained it would amount to abuse of process of the Court, preventing speedy remedy
to other genuine petitioners from this court. Personal interest cannot be enforced through
the process of this court U/A 32 of the Constitution in the garb of a PIL. A person
invoking the jurisdiction of this court U/A 32 must approach this court for the vindication
of the fundamental rights of affected persons and not for the vindication of his personal
grudge or enmity. It is the duty of this court to discourage such petitions and to ensure
that the course of justice is not obstructed or polluted by unscrupulous litigants by
invoking the extra ordinary jurisdiction of this court for personal matters under the garb
of the P.I.L[21]. It is thus clear that only a person acting bona fide and having sufficient
interest in the proceeding of PIL will alone have a locus standi and can approach the
court to wipe out the tears of the poor and needy, suffering from violation of their
fundamental rights, but not a person for personal gain or private profit or political motive
or any oblique consideration. Similarly, a vexatious petition under the colour of PIL
brought before the court for vindicating any personal grievance deserves rejection at the
threshold[22]. It must be noted that once the court has accepted the PIL, its withdrawal is
not permissible unless the court permits the same. Thus, the petitioner is not entitled to
withdraw his petition at his sweet will unless the court sees reason to permit withdrawal.
In granting the permission the court would be guided by considerations of public interest
and would also ensure that it does not result in abuse of process of law. Courts must
guard against possibilities of such litigants settling the matters out of the court to their
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advantage and then seeking withdrawal of the case[23]. Thus, a writ petitioner who
comes to the court for relief in public interest must come not only with clean hands like
any other writ petitioner but also with a clean heart, clear mind and clear objective. It is
depressing to note that on account of the trumpery proceedings initiated before the courts,
innumerable days are wasted, which time otherwise could have been spent for disposal of
cases of genuine litigants. Further, The court has to be satisfied about (a) the credentials
of the applicant; (b) the prima facie correctness or nature of Information given by him;
and (c) the information being not, vague and indefinite. The information should show
gravity and seriousness involved. The court has to strike a balance between two
conflicting interests: (i) nobody should be allowed to indulge in wild and reckless
allegations besmirching the character of others, and (ii) avoidance of public mischief and
to avoid mischievous petitions seeking to assail, for oblique motives, justifiable executive
actions. In such case, however, the court, cannot afford to be liberal. It has to be
extremely careful to see that under the guise of redressing a public grievance, it does not
encroach upon the sphere reserved by the Constitution to the executive and the
legislature[24].

VI. Social justice through PIL

The Supreme Court has played an active role in attaining social justice through the mode
of PIL. In Hussainara Khatoon v State of Bihar[25] the PIL was filed by an advocate
on the basis of a news report highlighting the plight of thousands of undertrial prisoners
languishing in various jails in Bihar. This litigation exposed the failure of criminal justice
system and led to a chain of proceedings resulting in the release of over 40,000 undertrial
prisoners. The right to speedy trial was recognised as a Fundamental right U/A 21 of the
Constitution. In Bandhua Mukti Morcha v U.O.I[26] the Supreme Court considered the
plight of bonded labourers engaged in the stone quarries of Haryana. An action in the
form of PIL was initiated for the identification, release and rehabilitation of the bonded
labourers. The court issued direction to the Haryana Government in this regard, which
were updated from time to time to meet the end of justice. In Sheela Barse v U.O.I[27] a
PIL was filed to assist the release of juveniles kept in jails. The Supreme Court issued
directions for the release of such juveniles and asked for the information regarding the
number of such juveniles who are placed in jails. In P.U.D.R v Commissioner of Police,
Delhi[28] the attention of the Supreme Court was drawn to the police atrocities
committed against poor people who were forcibly taken to a police station in Delhi to
work there without wages. As a consequence of such atrocities, one person died. The
while granting a compensation package to the legal representatives of the deceased, the
court directed the recovery of the same from the erring policeman. In M.C.Mehta v
State of Tamil Nadu[29] a PIL was brought before the Supreme Court complaining that
thousands of children were employed in match factories in Sivakasi. These children were
exposed to fatal accidents occurring frequently in the manufacturing process of matches
and fireworks. The court directed the State Government to enforce various welfare
legislations including the Factories Act and to provide facilities for recreation, medical
care and basic diet to the children during working hours and facilities for education. The
court further directed for the formulation of a scheme requiring a compulsory insurance
of both adult and children employed in hazardous industries. In Delhi Domestic
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Working Women’s Forum v U.O.I[30] the Supreme Court took a serious note of the
sexual assault by seven army personnel against six domestic servants travelling in the
train. The Supreme Court laid down various guidelines to protect and assist rape victims.
The guidelines include the legal assistance, anonymity, compensation and rehabilitation
of rape victims. The National Commission for women was directed to evolve a scheme
for providing adequate safeguards to these victims. In the landmark judgment of Vishaka
v State of Rajasthan[31], the Supreme Court declared that sexual harassment of women
at work place constitutes violation of gender equality and right to dignity, which are
Fundamental Rights.

VII. Conclusion

The role of PIL in bringing and maintaining the concept of “social justice and equality”
cannot be either doubted or rejected. The roads ahead are, however, very tedious, difficult
and complex in nature. The toughest competition is from the “executive” wing of the
Constitution as it is careless about and ignorant of its noble role, which the founding
fathers of the Constitution have framed for it. The court may keep on recognising the
basic Human Rights and Fundamental Rights, but their “enforcement” is equally
important. The “executive” seems to be indifferent towards the goals set by the
Constitution and is interested in self-fulfillment only. This process is reflected by the
increasing judicial activism of the Supreme Court, which is encroaching upon, though
rightly and justly, those areas which primarily and exclusively were reserved “executive”
and the “Legislature”. The abdication of the “Constitutional duties” by the Executive and
the Legislature has left no choice for the Supreme Court but to assume the role of
“limited policy making and law making”. This further has necessitated the acceptance of
“unlimited qualitative quantity” of PILs in India. This means that the deserving cases
should be admitted and appropriate reliefs should be granted irrespective of the number
of PILs involved. Thus, the wings of PIL are required to be spread further till Executive
and Legislature wake up and fulfill their duties and responsibilities.

© Praveen Dalal. All rights reserved with the author.

* Arbitrator, Consultant and Advocate,
Supreme Court of India.
Contact at: pd37@rediffmail.com/ perry4law@yahoo.com

[1] Justice Dwivedi in Kesavananda Bharati v State of Kerala, (1973) 4 SCC 225.
[2] Justice Chandrachud in Kesavananda Bharati v State of Kerala, (1973) 4 SCC 225.
[3] Upendra Bakshi; “Taking suffering seriously: Social Action Litigation in the Supreme
Court of India” Law and Poverty (ed) Upendra Bakshi, pages 387-415 (1988).
[4] Janta Dal v H.S. Chowdhary, AIR 1993 SC 892.
[5] Onkarlal Bajaj v U.O.I, (2003) 2 SCC 673.
[6] S.R.Pandian. J in Janta Dal v H.S.Chowdhary, AIR 1993 SC 892.
[7] Balco Employees Union v U.O.I, AIR 2002 SC 350.
[8] (1973) 4 SCC 225.
[9] (1976) 3 SCC 832.
[10] AIR 1982 SC 344.
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[11] Maneka Gandhi v U.O.I, AIR 1978 SC 597.

[12] Supreme Court Advocate on record v U.O.I, (1993) 4 SCC 441.
[13] Kihoto v Zachilhu, AIR 1993 SC 412.
[14] Clark D. Cunningham; “ Public Interest Litigation in Indian Supreme Court: A study
in the light of American Experience”, J.I.L.I, V-29: 4. P-494 (1987).
[15] Guruvayur v C.K.Rajan, 2003 (6) SCALE 401.
[16] Parmanand Singh, “ Public interest litigation in India”
[17] S.R.Pandian. J, in Janta Dal v H.S.Chowdhary, AIR 1993 SC 892.
[18] Fertilizers Corporation Kamgar Union v U.O.I, AIR 1981 SC 344.
[19] S.P.Anand v H.D.Deva Gowda, AIR 1997 SC 272.
[20] S.N Patil v M.M.Gosavi, AIR 1987 SC 294.
[21] Subhash Kumar v State of Bihar, (1991) 1 SCC 598.
[22] Janta Dal v H.S.Chowdhary, (1992) 4 SCC 305.
[23] S.P.Anand v H.D.Deva Gowda, AIR 1997 SC 272.
[24] Ashok Kumar Pandey v State of West Bengal, JT 2003 (9) SC 140.
[25] AIR 1979 SC 1360.
[26] (1984) 4 SCC 161.
[27] AIR 1986 SC 1773.
[28] 1989 (1) SCALE 114.
[29] AIR 1991 SC 417.
[30] (1995) 1 SCC 14.
[31] (1997) 6 SCC 241.